Effective Date: April 5, 2023.

Your privacy is important to us.  Eagle’s Flight is committed to maintaining the confidentiality and protection of any Personal Information we may collect while operating the URVU™ application (app). Our collection, use and disclosure of Personal Information are governed by applicable privacy legislation.  For the purposes of this Privacy Policy, the term “Personal Information” means any information that is defined to be ‘Personal Information’ under applicable Canadian privacy laws.  Usually, this refers to any information about an identifiable individual or any information that can be used to identify an individual.

Accordingly, we have developed this Privacy Policy for you to understand how we collect, use, communicate, disclose and otherwise make use of Personal Information. This Privacy Policy also describes our practices regarding the privacy of information that we collect through the URVU™ app, which is hosted and operated from Canada.

We have outlined our Privacy Policy below.

• We will collect Personal Information by lawful and fair means and, if applicable, with the knowledge or consent of the individual concerned.
• Before or at the time of collecting Personal Information, we will identify the purposes for which information is being collected.
• We will collect and use Personal Information solely for fulfilling those purposes specified by us, unless we obtain the consent of the individual concerned or as required by law.
• We will only retain Personal Information for as long as necessary for the fulfilment of those purposes.
• We will protect Personal Information by using reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
• We will make readily available to customers information about our policies and practices relating to the management of Personal Information.

We are committed to conducting our business in accordance with these principles to ensure that the confidentiality of Personal Information is protected and maintained. Eagle’s Flight reserves the right to change this Privacy Policy from time to time at its sole discretion without prior notice.  We will inform you on the URVU™ app if we have amended the Privacy Policy.

Information Collected by URVU™

 When the URVU™ app is installed on your phone, a list of permissions appears and are needed for the app to function effectively. There is no option to customize the list. The permissions that Eagle’s Flight requires and the data that shall be accessed and its use is as below:

1. Device & URVU™ App History: We need your device permission to get information about your device, such as: operating system (OS) name, OS version, mobile network, hardware model, unique device identifier, preferred language. Based on these inputs, we intend to optimize your overall app experience, use OS specific capabilities to drive great in-funnel experiences using components of device OS, etc.
2. Contacts: If you grant the URVU™ app permission to access your contacts, it enables us to provide you a feature where you can easily send across referral links to your contacts to invite them to Eagle’s Flight’s URVU™ app. Access to contacts only at the point of distributing invites, no contact information is stored by the URVU™ app.
3. Personal Information: Your name, phone number and email will be kept for records to act as an identifier for your feedback (as provided in item #4 below). Additionally, feedback submitted to you will be kept for your review (as provided in item #4 below).
4. Your Personal Information will be kept for the duration of your subscription, and automatically deleted: (i) six months after ceasing the subscription; or (ii) after 6 months of inactivity (whichever is longer). Nevertheless, you may delete your Personal Information at any point.
5. After a period of six months of inactivity or after ceasing subscription (whichever is longer), feedback provided or received will be anonymized for the purpose of aggregate analysis.
6. The Personal Information is stored on a server located within Canada.
7. Certain third-party providers are used to enable URVU™ to function and collect Personal Information for purposes related to notification, subscription payment, SMS and database.

Third Party Providers

Eagle’s Flight may also share your Personal Information with other third parties (e.g. financial institutions to process payments; lawyers and auditors; our affiliates, etc.) to the extent required to provide our services and to comply with our legal or regulatory obligations.  Such transfer is subject to data protection agreements, where legally required, whereby the recipients agree on technical and organizational security measures to protect your data adequately.

Data Transfer to Third Countries

Where data transfer involves the transmission of your Personal Information to countries outside the EU/EEA that are deemed by the European Commission as to not offering an adequate level of data protection, Eagle’s Flight enters into standard contractual clauses with any such recipients.

Accuracy

Upon request, you may review the Personal Information we have collected and, where appropriate, you may request that we update it or correct any errors, by contacting us at the phone number or email address provided below.   Eagle’s Flight will endeavour to respond to and comply with your request for updating or correction as soon as reasonably possible.

Privacy Rights: European Economic Area and the UK

Depending on your location and the applicable law, you have or might have the following data protection rights:

• Right of access: You have the right to obtain information on the processing of your personal data and to receive a copy of these data.

• Right to rectification: If your personal data is inaccurate or incomplete, you have the right to request that we correct or complete it. If we shared your personal data with others, we will inform them about the correction where possible.  Upon request, we will inform you with whom we shared your personal data. 

• Right to erasure: Under certain circumstances, you have the right to request that we delete your personal data, such as where you withdraw your consent. If we shared your personal data with others, we will inform them about the erasure where possible. Upon request, we will inform you with whom we shared your personal data.
• Right to restrict processing: Under certain requirements, you may ask us to restrict the processing of your personal data. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will inform them about the restriction where possible. Upon request, we will inform you with whom we shared your personal data.
• Right to data portability: You have the right to receive your personal data in a structured, common, and machine-readable format and request that these data are transferred to another data controller, if applicable under the specific circumstances.
• Rights in relation to automated decision-making: Under certain circumstances, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

• Right to object: You might have the right to object to certain types of processing of your Personal Data, in particular where this processing is carried out in connection with: (i) the necessity of the performance of a task in the public interest, or (ii) legitimate interests.  We will then stop the processing of your personal data unless we remain legally authorized to do so.

• Right to withdraw consent: In case you granted us your consent to process your personal data, you have the right to withdraw your consent at any time. The withdrawal of consent has effect for future processing operations only and shall not affect the lawfulness of processing based on consent before its withdrawal.

To withdraw your consent, you may send an email to dataprotection@eaglesflight.com  If you withdraw your consent, you may no longer be able to use the services affected by the withdrawal.

• Right to lodge a complaint with a supervisory authority: You might have the right to lodge a complaint with the applicable supervisory authority against the processing of your personal data if you believe that the processing of your personal data infringes the applicable data protection regulations.

Requests for Information Access and/or Corrections

If you have any questions about this Privacy Policy or would like to make a request to access, review or correct the Personal Information we have collected about you, please contact Eagle’s Flight using the information below:

Privacy Contact

Eagle’s Flight

103 Beechwood Avenue

Guelph, ON

Canada  N1H 5Z7

+1-226-820-3155

Dataprotection@eaglesflight.com

Contact us at Dataprotection@eaglesflight.com if you have any questions regarding this privacy policy.