PRIVACY POLICY

GENERAL

Thank you for your interest in FrSky Electronic Co., Ltd. and its affiliated companies (“FrSky”, “we,” or “us”) and in the various hardware, firmware, software, websites, applications, and services provided by us and on which a link to this Privacy Policy (this “Policy”) is displayed (each, a “Product” or “Service” and, collectively, the “FrSky Products and Services”).

This Policy describes:

• the information that we gather from you,
• how we use and share this information,
• the rights and choices you have regarding this information,
• the steps we take to protect this information,
• the limitations of this Policy regarding third party websites and content,
• how we transfer your information,
• how we may change this Policy, and
• how you may contact us.

By using FrSky Products and Services, you consent to the privacy practices described in this Policy. This Policy is incorporated into and is subject to the Terms of Use for the FrSky Products and Services you use.

INFORMATION COLLECTED

Information We Collect on the FrSky Products and Services

• User-provided Information. When you use FrSky Products and Services, you may provide us with information about you, including your name, email address, mailing address, mobile phone number, and payment information (if you use FrSky Products and Services to engage in purchases or financial transactions). You may provide us with information in various ways when using FrSky Products and Services. For example, you provide us with information when you register for a FrSky account, use FrSky Products and Services, submit credentials or other information for account verification, upload or share photos or videos on or through FrSky Products and Services, or send us customer service-related requests using FrSky Products and Services or other means of communication.
• User-provided Information About Others. We may also collect and store information about other people that you or other users provide to us. If you use FrSky Products and Services to send others (friends, relatives, colleagues, etc.) information that may interest them or messages (such as invitations to use FrSky Products and Services, or participate an event) through FrSky Products and Services, we may store information about you and information relating to each such recipient. Similarly, if you use FrSky Products and Services to upload, share and/or distribute content(including  photos, videos, flight data, or other submissions)  and such content contains information about others, we may store, process, and disclose that information as provided for under this Policy.
• Cookies and Automatically Collected Information. When you use certain FrSky Products and Services, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device.  We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies, you may not be able to utilize the features of FrSky Products and Services to their fullest potential.

We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use a Product or Service, the pages or other content you view or otherwise interact with on a Product or Service, and the dates and times that you visit, access, or use FrSky Products and Services. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you.

Our use of cookies and other automatically collected information is explained further in our Cookie Policy.

• Device-Related and Flight-Related Information. When you use FrSky Products and Services, you will provide us with information relating to (i) your FrSky Product or Service, your non-FrSky device on which the FrSky Product or Service is used. This information may include: (i) information about your non-FrSky device (including your device ID, hardware version, and operating system); (ii) information about your FrSky device (including the model and serial number of your device); (iii) other technical information, including the IP address used by your non FrSky device; and (iv) data associated with your FrSky account.

In order to use certain Location-based Services, you may be required to enable certain features of your mobile phone (such as GPS, Wi-Fi, and Bluetooth), which enable FrSky to identify your location through a variety of means, including GPS location, IP address, cell tower location, geo-fencing technology, or detection by physical on-location Wi-Fi or Bluetooth sensors.  If your location is collected through Wi-Fi or Bluetooth sensors, please be aware that such sensors, and the associated data services, may be provided by a third party, which may access such information for the purpose of providing such data services to FrSky.

• Third Party Web Beacons and Third Party Buttons. We may display third-party content on or through FrSky Products and Services, including third-party advertising.  We also may enable you to connect your FrSky account to, or otherwise interface with, third party services, including third party social networks and communications services.  In addition, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by FrSky. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.

[For further information, please review our Cookie Policy.]

• Information from Other Sources. We may obtain information from third parties and sources other than FrSky Products and Services, such as our business partners, contractors, advertisers, and other third parties.

USES OF COLLECTED INFORMATION

How We Use the Information We Collect

We use information we collect through FrSky Products and Services in a variety of ways in providing the FrSky Products and Services and operating our business, including the following:

• We use the information that we collect through FrSky Products and Services to operate, maintain, enhance and provide features of the FrSky Products and Services, to verify and manage FrSky user accounts, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to by FrSky.
• We use the information that we collect through FrSky Products and Services to understand and analyze the usage trends and preferences of our users, to improve the FrSky Products and Services, and to develop new products, services, features, and functionality.
• We may use your information to contact you for administrative, informational, and marketing purposes. This may include providing customer service or sending communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. We aim to obtain appropriate consent (where required under applicable) to send you marketing communications.
• We may use information we collect to: (i) personalize FrSky Products and Services; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of FrSky Products and Services and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) review your entries, submissions, and status in any promotions or other activities involving FrSky Products and Services.

When We Disclose Information

We will not disclose your information that we collect through FrSky Products and Services to third parties except as described in this Policy or as we disclose to you at the time the information is collected. We may disclose information to third parties in the following circumstances:

• We may share your information with our affiliates and subsidiaries in order to provide you with FrSky product and services.
• Any information that you voluntarily choose to upload to a publicly accessible site or venue using FrSky Products and Services (including sharing information on FrSky’s online community forum, the “FrSky Forum”), or that you elect to make public, will be available to anyone who has access to that content, including other users.
• We work with third party service providers to provide payment facilitation, parcel transportation, application development, hosting, maintenance, flight environment data, account verification, and other services for us. We generally require these service providers to use or disclose the information they process on our behalf only as necessary to perform services on our behalf or comply with legal requirements.
• We may preserve and disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena, warrant or request, or to otherwise cooperate with law enforcement or other governmental agencies.
• We also reserve the right to preserve and disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the FrSky Products and Services and any facilities or equipment used to make the FrSky Products and Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• FrSky uses a third party verification service provider to verify certain users of FrSky Products and Services and FrSky may disclose information to this service provider. The service provider may retain credential information provided as part of account verification for compliance and other purposes and may provide such information, as well as your user login ID or email address, to government authorities, law enforcement agencies, regulatory agencies and other duly authorized parties as may be required by or permitted under applicable laws. We require this service provider by contract to use or disclose the information they process on our behalf only as necessary to perform services on our behalf or comply with legal requirements.
• If you consent to our disclosure of information to a third party, such as business partners, or as otherwise authorized under applicable law.
• Information about our users, including information you provided and any information collected through FrSky Products and Services, may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• We may make certain aggregated, de-identified, or non-identifying information about users of FrSky Products and Services available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; (iii) product safety analysis; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality of FrSky Products and Services.

RIGHTS REGARDING COLLECTED INFORMATION

Your Rights and Choices you have regarding this information

Subject to applicable law, you may have the right to request access to and receive information about the information we maintain about you, update or correct inaccuracies in the information we maintain about you, and have the information blocked or deleted, as appropriate.Your right to access information we maintain about you may be limited under local law. You also have the right to object to the processing of your information or to withdraw your consent to our processing of information about you, including to the transfer of information to other countries. Note, however, that if you exercise your right to object or your rights of blocking or deletion, if you decline to share certain information with us, or if you withdraw your consent to our processing of information about you, we may not be able to provide to you some of the features and functionality of FrSky Products and Services.

You may update, correct, or delete certain FrSky account information and preferences by accessing your account preferences page, available through certain FrSky Products and Services, including the frsky-rc.com and certain FrSky mobile applications. If you wish to access or amend any other information we hold about you, you may contact us at frsky@frsky-rc.com. Likewise, if you close your FrSky account, you will not be able to sign in to FrSky Products or Services or access any of your information. However, you can open a new account at any time. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit, as authorized under applicable law, for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

If you receive commercial email or text messages from us, you may unsubscribe at any time by following the instructions contained within the email or text message. You may also opt out from receiving commercial email or text messages from us by sending your request to us by email at frsky@frsky-rc.com.

Third-Party Services

FrSky Products and Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through FrSky Products and Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through FrSky Products and Services.

Children’s Privacy

FrSky Products and Services are not directed to children under the age of 13. We do not knowingly collect information from children under the age of 13 without obtaining parental consent.

DATA SECURITY

We use certain physical, organizational, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards.

International Visitors and Users

FrSky Products and Services connect to servers hosted in China. If you choose to use FrSky Products and Services from the European Union or other regions of the world, then please note that you may be transferring your information outside of those regions for storage and processing. Also, we may transfer your data from China to other countries or regions in connection with storage and processing of data, fulfilling your requests, and providing the services associated with FrSky Products and Services. By providing your information on or through FrSky Products or Services, you consent to such transfer, storage, and processing.

Legal Basis for the Processing of Personal Information

If you are located in the European Economic Area (“EEA”), our processing of your personal information will be based on the following: To the extent that we obtain your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). If the processing of your personal information is necessary for the performance of a contract between you and us or for taking pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for us to comply with a legal obligation, we will process your personal information on basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).
Please note that where you have given your consent to the processing of your personal information you may withdraw your consent, for example by sending an e-mail to frsky@frsky-rc.com at any time which withdrawal will not affect the lawfulness of any processing previously made on basis of your consent.

POLICY CHANGES AND UPDATES

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available on or through theFrSky Products and Services, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. Your continued use of FrSky Products and Services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.

Our Contact Information

Please contact us with any questions or comments about this Policy or our data practices by email at frsky@frsky-rc.com.