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D-Fly Group Ltd Privacy Policy

Effective Date 1st April 2023

D-Fly Group Ltd, d/b/a Dragonfly, and its subsidiaries and affiliates (e.g., D-Fly USA Inc ) (collectively, "D-Fly Group Ltd", "we", “us” or "our") are committed to the privacy of your personal data. This Privacy Policy (“Policy”) describes how we collect and process the personal data that we collect from or about you through our website, www.d-fly.com, the D-Fly app from which you are accessing this Policy, or through a connected product (“D-Fly product” and collectively with our website and D-fly apps, the “Service”).

We do not need to collect every personal detail about you. Our main reason for collecting your personal data is to provide and improve the Service, our products and the experiences that you and our customers expect from us. Personal data is any information that could be used to identify you or another individual. 

By using the Service, you agree to the terms and conditions of this Policy, including our Terms & Conditions and our Cookie Policy. If you do not agree with any part of this Policy, you are not authorized to use the Service.

To contact us

Information on D-Fly Group Ltd and how to get in touch with us is available on our contact page.

If you would like to receive this Policy or any other, notice in another format or have any questions, comments or concerns about how we use the personal data we hold about you, please contact our Customer Services by email at hello@d-fly.com or in writing at:

 

Customer Services

D-Fly Group Ltd

136 Kensington Church Street

London

United Kingdom

W8 4BH 

 

You can also contact the regulator or authority in your country that is responsible for handling complaints about the use of personal data.

Who is responsible for your personal data?

We, D-Fly Group Ltd, D-Fly USA Inc and any other D-Fly company, take responsibility for the personal data that we hold about you. 

How do we collect personal data?

We collect personal data about you in a number of different ways including:
 

1. Information you share with us through our website or app, in person at stands and events or otherwise.

2. Information from your connected D-Fly product – products that are “intelligent” or “smart”, internet enabled or operated through a D-Fly App.

3. Information from your online interactions through cookies and similar tracking technologies. Please see the “Cookies and other passive collection technologies” section below in this Policy and our Cookie Policy for further information).

 

4. Information within communications from you (such as emails, live chats [ACN1] or via the D-Fly App) and information about how you have engaged with email and App communications that we have sent you. 

5. Publicly available information from your social media interactions with us or posts about us.

 

6. Information from third-party service providers that help us provide or improve the Service, such as to host our website or to analyse how our Service is used.

 

7. Information from third- party data providers, including social media platforms, to whom you have given your permission to share your data.

How do we collect personal data?

The personal data that we process about you will mainly fall into one of the following categories:

Contact, Account and Internet and Electronic Network Activity Information

Full name, telephone number, email address, physical address, IP address, cookie ID, account login information (e.g., username and password), information about your device (e.g., ID or IMEI number) and other similar information you choose to provide to us.

Order information

Order number, including product(s) purchased and return history, payment information, delivery records, repair records and warranty information.

Location data

Approximate geographical location (e.g., country, state, etc.) and precise geographical location (e.g., GPS data of a connected device).

Internet activity

Website traffic data, including information about user site traffic patterns and usage (e.g., data about how users navigate our Services, browsing information, search queries) and other information collected from online tracking technologies (e.g., cookies).

Preference and profile data

Marketing choices, language preferences, demographic information, information about your interests and information that you voluntarily share with us through your Account selections, in response to surveys or other forms of communication voluntary market research).

If you share information, including personal data, about or on behalf of another party with us (for example, if you have bought a D-Fly product for another person or if you register another person to access or use the Service), then you need to verify with that person that you are authorized to share their personal data with us, and for us to use it in accordance with this Policy.

How do we use personal data?

We use personal data submitted by you or otherwise collected through the Service for the purposes described in this Policy and as otherwise described to you at the point of collection. Generally, we use the information you provide for the reason for which it was provided. We may also use your personal data as specifically described below:

 

TO COMPLETE ORDERS AND PROVIDE THE SERVICE

 

This processing includes:

1. Managing and coordinating the purchase, delivery and after sales service of your products.

 

2. Responding to your enquiries and requests, both online and offline, including enquiries and requests communicated to us through a social media platform (e.g., Instagram, Facebook, Twitter, LinkedIn or YouTube), or over the phone, and WhatsApp.

 

3. Documenting, monitoring and recording the lifecycle of D-Fly products, including stock management, quality control, Service improvement, dispute resolution and enforcement. 

 

4. Contacting you when products or models are next in stock.

 

TO PROVIDE SUPPORT OR TO IMPROVE THE SERVICE
 

Occasionally, we may use your personal data to help you with any issue you may face with your D-Fly product(s). We may do this by monitoring your previous purchases for software or connectivity issues or for suspected mechanical failures, and sending you relevant Service support communications. 

We use data to also optimise product performance and your experience when using the Service. In particular, we want to be able to identify when there may be an issue with the Service so that we can let you know about it as soon as possible. Monitoring products also lets us raise issues before they may become apparent. It also helps us provide updates and services to our products, like software or app upgrades. 

TO COMMUNICATE WITH YOU

 

Sending you product support communications enables us to:

 

1. Provide information about or in connection with the Service, including any D-Fly product(s) you purchase, that we think may be of interest to you, such as essential product service updates; reminders about how to carry out maintenance for optimal performance; alerts for recommended app or software updates or upgrades that we think will improve the performance of your product; information about how and where to get help from the D-Fly team should you need support; information about warranty; and alerts regarding any important product safety or recall announcements.

 

2. Provide improved owner experiences via new technologies such as our mobile applications.
 

TO KEEP YOU UPDATED

 

We always want to keep you up to date! Whether it’s on our latest product developments, offers, opportunities to test new D-Fly products, or upcoming events. We really want to make sure you’re happy with the communications you receive from us. We do this by either offering you the opportunity to opt out, e.g., service emails, or requiring you to opt in, e.g., consent to marketing emails. We may contact you in various ways, including e-mail, text messaging, social media platforms and by phone. We may use profiling and statistical analysis to identify which communications from D-Fly Group Ltd are relevant and interesting to you. We do this by:

 

1. Analysing and improving the information that we collect;

 

2. Producing user profiles, reports and targeted advertisements;

3. Only including you in selected marketing campaigns;

 

4. Measuring the effectiveness of our promotional campaigns and advertising; and

 

5. Customising and improving the way that you shop and engage with us in the future. 

TO PROTECT D-FLY GROUP LTD AND OUR CUSTOMERS

 

D-Fly Group Ltd may also process personal data to:

 1. Detect and prevent unauthorized activity, including fraud and other wrongdoing;

 

2. Keep our website, app, products and IT systems up to date and help better secure the Service;

 

3. Assist in resolving any disputes, claims or investigations relating to the Service, including warranty matters;

 

4. Comply with and enforce applicable legal obligations; and

5. Provide updates to you about significant changes to D-Fly Group Ltd’s policies, terms and conditions and any other matters which we may need to inform you about.

 

As part of the activities described above, we combine different categories of personal data that we collect about you. For example, we combine personal data from your online interactions, information you share with us, or information from D-Fly products, for the identification and analysis of product popularity, of your user behaviour when you use our website or app, or to understand how our products are being used.

By providing your phone number, you agree to receive text messages from D-Fly USA Inc. Message and data rates may apply. Message frequency varies. D-Fly USA Inc will not share your contact phone number with any other parties

How long do we keep your data?

We only keep your personal data for as long as we need to, to be able to use it for the reasons given in this Policy, and for as long as we are required to keep it by law.

 

The actual period for which we store your personal data will vary depending on the type of personal data and how it is used. For example, when you buy a product from us, we will store information about you and your purchase for at least the term of your warranty.

Our justification for handling your personal date

Data protection and privacy laws in certain countries require us to have what's called a "legal basis" or "lawful ground" for handling personal data. Largely, that means that we have to have a legal justification for handling your personal data.

To process your data, we will mainly use the following legal bases:

1. Contract – e.g. we have to process your delivery and payment details to provide you with the product that you have purchased

2. Consent – e.g. we will send you marketing communications where you have provided consent

 

3. Legitimate interests – e.g., we will process order information to detect fraudulent activities and protect D-Fly Group Ltd and our customers

In some circumstances, we will need to handle your personal data in a certain way to be able to comply with our legal obligations; for example, if we receive a request for your personal data from a regulatory body or law enforcement authority.

We handle your personal data in this way so that we can directly or indirectly, improve the Service and your overall experience of D-Fly Group Ltd as a business. Whatever our justification for handling your personal data, we will strive to uphold our commitment to protect your privacy.

Sharing and transferring your personal data

Sharing within D-Fly Group Ltd

We may share your personal data with our affiliates and its and their staff for purposes consistent with this Policy. Our affiliates and staff will be bound to maintain that data in accordance with this Policy and to understand how and why we protect your personal data.

Sharing with third parties

We share your personal data with certain third- party service providers that we hire to provide services to us. We will only grant these service providers access to the personal data they need to perform those services. For example, order and delivery details will be shared with third-party logistics partners with whom we contract with to help us fulfil purchase orders. These third-party service providers will be required to keep your personal data confidential, and not use it other than instructed by us.

The third parties providing services fall into the following categories:

1. Business Service Providers: Those helping us to deliver the Service, including online and offline components of the Service, to you;

2. Marketing Service Providers: Those helping us to provide you with relevant and interesting communications - e.g., social media platforms, analytics companies, marketing and advertising agencies;

3. Agents and Consultants: Those helping us with mailing services, product services and repairs, processing product purchases, financial services, audit services, administrative services, IT technologies - e.g., data storage, security services and insurance claims; and

4. We also share certain personal data with third parties who help us to detect and prevent criminal activity, such as fraudulent transactions. The information we share with those third parties includes some of the information that you share with us;, for example, your contact details and information about your transaction, and some of the information from your online interactions (such as the IP address of your device). That information is used to determine whether a transaction could be fraudulent.

We will also share your personal data if we believe it is necessary or appropriate under applicable law, including in response to a legal process, (e.g., a court order or subpoena), to respond to requests from public and government authorities; to comply with national, state, provincial or local laws; to enforce our terms and conditions, to protect our business or the business operations of an affiliated party, to protect our rights, privacy, safety or property, and/or that of others; and to allow us to pursue available remedies or limit damages that we may sustain.

Finally, in the process of purchasing a D-Fly Group Ltd product you may interact with a third party who will be independently responsible for the personal data that you provide. For example, if you purchase a D-Fly product under finance, your finance agreement will be directly with that third party, and you should read their privacy notice(s) separately. If you access or interact with that third party’s product, service, platform or feature, any information you disclose through that third party is not subject to this Policy. For more information, please see “Links to third party websites” in this Policy. As part of an acquisition or liquidation, including if we undergo liquidation or bankruptcy proceedings.

Transfer and the global handling of your personal data

D-Fly Group Ltd, will collect personal data from you in the country in which you live. We, and those third parties that we share your personal data with, then host, store and otherwise handle that information through servers located in the United States. 

If we transfer your personal data from one country to another, we will comply with the data protection and privacy laws which apply to us.

European data protection laws, in particular, include specific rules on transferring personal data outside the European Economic Area (“EEA”). We do not currently transfer data from the EEA.

When transferring personal data outside the EEA, we will:

1. Include standard data protection contractual clauses approved by the European Commission for transferring personal data outside the EEA into our contracts with those third parties.

2. In any case, our transfer, storage and handling of your personal data will continue to be governed by this privacy notice.

Children's data

D-Fly Group Ltd’s Service is not directed at individuals under the age of 18 (“children”). We do not knowingly collect personal data through the Service from children. We reserve the right to delete any information identified as having been provided through the Service from children under the age of 18. 

Links to third party websites

We may provide links to other websites which are not operated and controlled by D-Fly Group Ltd. We have no control over and are not responsible for the content of those sites or how the third parties responsible for them collect and use your personal data. We do not endorse or make any representations about third party websites.

Third party websites usually have their own privacy notices explaining how they use and share your personal data. You should carefully review those privacy notices before you use these websites to make sure that you are happy with how your personal data is being collected and shared.

Cookies and other passive collection technologies

As you navigate the Service online, certain Traffic Data may be passively collected, meaning it is gathered without your actively providing it. This is done using passive collection technologies such as cookies, including third-party cookies, web beacons and pixels.

Like many companies, our website(s) may use “cookies” to help make sure the website is meeting the needs of its users and to help us make improvements. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies set by us on our website to tell us, for example, whether you have visited us before or if you are a new visitor. We use third-party cookies set by our service provider, Google Analytics, to collect information about how visitors use the Service, including how long you spend on each page, and how you got to the website. We may combine data collected by cookies with other information collected from or about you for our targeted marketing purposes and intent-based advertising.

You can visit https://www.google.com/analytics/learn/privacy.html to learn more about Google Analytics’ use of cookies and https://tools.google.com/dlpage/gaoptout for information on how to opt out of Google Analytics cookies.

You can refuse our use of some or all cookies by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies, you may not be able to access all or parts of our Service or functionality may be limited. Please see the following links for more information with respect to how you can block or erase cookies via your particular browser: Google ChromeFirefoxInternet ExplorerSafariEdgeOpera.

 

Alternatively, you may visit http://www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers.

"Do Not Track" signals

D-Fly Group Ltd does not currently take any action when we receive a “Do Not Track” request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

Your controls and choices

Whenever possible, we try to give you control over the personal data we collect about you, to ensure it is accurate and reflects your preferences. You have the right to access, update and amend personal data that we hold about you; you can do that in relation to some of your personal data through your Account settings.

We will only send you marketing communications when you have told us that you are happy for us to do so. If you have previously said that you would like us to contact you but would like to change or update the way that we do so, you can update your preferences by:

1. Contacting D-Fly Group Ltd customer service and stating that you would like to change or update the way that we contact you;

 

or

 

2. Logging onto your account on our website and changing your preferences and information.

 

In certain circumstances, you also have the right to ask us to:

1. Stop using your personal data for certain purposes;

 

2. Limit or restrict our use of your personal data;

 

3. Remove or delete personal data about you; or

 

4. Provide your personal data to a third- party provider of services.

 

For example, you have the right to object to our monitoring of your use of our websites and product app, and how you engage with our promotional campaigns and advertising online for these purposes.

 

Please note that those rights do not always apply and there are certain exceptions to them.

If you, or a party authorised to act on your behalf, would like to exercise any of your rights in relation to your personal data, please email hello@d-fly.com. We will also need to confirm your identity before acting on certain requests. We may not be able to respond to your request or provide you with personal data if we cannot verify your identity, or authority to make the request on someone else’s behalf.

 

If the law in your country allows us to impose a fee for giving you access to your personal data, or to exercise any of your other rights in relation to your personal data, we will let you know. You will not be discriminated against for exercising any of the rights that apply to you.

Your California Privacy Rights

Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, information about certain personal information we shared, if any, with other businesses for their own direct marketing uses in the previous calendar year. To request a copy, please contact us at the email provided in the “How to Contact Us” section, below. Please be aware that not all information sharing is covered by the “Shine the Light” law requirements and only information on covered sharing will be included in our response.

Protecting your data

We are committed to protecting your personal data. We use what we believe to be appropriate technical and organisational measures, including encryption, to protect your personal data and privacy, and review those regularly. We protect your personal data using a combination of physical and IT security measures, including access controls that restrict and manage the way in which data is processed, managed and handled. We also strive to ensure that our staff are adequately trained in protecting your personal data. Our procedures mean that we may occasionally request proof of identity to verify a request before we share your personal data with you.

Where we have given you (or where you have chosen) a password which enables you to access any portal or account, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.

Changes to this Privacy Policy

We will regularly review and update this Policy. Modifications to this Policy will be posted on this web page and the new Effective Date will be displayed at the top of this Policy. If we change our Policy in a way that significantly changes how we process the personal data that we hold about you, we will notify you of those changes through the most appropriate method (e.g. in email or a notification on our website). Where required by applicable law, we will apply changes only with your consent.

Please review this Policy periodically, and especially before you provide any personal data. Your continued participation in our Service, both online and offline, following the effectiveness of any modifications to this Policy constitutes your acceptance of those modifications. If any modification to this Policy is not acceptable to you, you should cease accessing, browsing and otherwise utilizing the Service.

Translations of this Privacy Policy

This Policy has been translated from English into the official language of a number of different countries. We have done this to make sure that the Policy is clear and accessible to all users. If there are any conflicts or inconsistencies between the translated versions of this Policy, the English version will prevail.

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