Flock Cover App - Privacy Policy

This App (the “App”) is provided by Flock Limited, a company registered in England and Wales with a registered office at: Geovation Hub, 1 Sekforde Street, London, EC1R 0BE (ICO Data Protection Registration Number ZA263304) (“Flock”, “we”, “us“, "our”).

We are committed to respecting your privacy. The purpose of this Privacy Policy is to explain how we may use any data we collect about you, how you can instruct us if you prefer to limit the use of that data and for us to tell you about the policies and procedures that we have in place to respect your privacy.

Please read this privacy policy carefully to understand how we handle your data.

By accessing or using the App, you confirm that you have read and understood the entirety of this privacy policy.

Summary

"Your data" means any data about you from which you can be identified. When you sign up to our App, use our real-time data mapping services, static geo-located data services or buy insurance policies with Allianz through the App, we will use your data to provide you with the App and the services which you have requested. We may share your data with Allianz, Worry & Peace and our distribution partners, which includes software developers, hardware developers and any other company that distributes pay-as-you-fly insurance policies on our behalf. 

Some of these organisations may be situated in countries outside the European Economic Area. If we transfer your data to these countries we will take steps to ensure your information is appropriately protected.

If you have consented, we will also use your data for providing you with newsletters or other alerts when you sign up to the App, which will let you know about any additional products or services we offer and will provide you with useful flight tips.

When you use this App we may track data about how you navigate the App to analyse App usage, to manage the App, and to report aggregate information to trusted third parties as mentioned above.

We reserve the right to use your data for other purposes set out in this privacy policy, for example to respond to legal or regulatory requests, or to transfer your data to a purchaser of our business.

If you would like to learn more about our data collection policies and practices, please read the following.

1. Who we are and what we do

Flock operate an insurance distribution platform for commercial drone pilots located in the United Kingdom that provides access to real-time mapping data and static geo-located data relevant to flying drones, and enables commercial drone pilots to purchase pay-as-you-fly drone insurance through the App. 

The pay-as-you-fly drone insurance is provided by Allianz and will be governed by Allianz's policy terms which can be accessed here . Allianz's use of your data is described in its privacy policy which can be accessed here. The App only acts as a distributor of Allianz's insurance policies.

2. Information collection

2.1 Information you give us. You may give us information about yourself by registering within our App. The information you give us may include your:

a) name; 

b) address; 

c) telephone number; 

d) location data;

e) browsing and transaction history through use of the App;

f) email address;

g) flight history; 

h) flights you have got a quote for; 

i) licences and permissions; 

j) experience as a drone operator; and

k) other data which you may disclose to Us via the App at any time.

2.2 What other data do we collect? Each time you use the App, we may automatically collect any of the following information: technical information, the files requested, hardware device model, operating system, platform and device ID.

2.3 Information we receive from other sources. We will receive information about you if you use any of the other websites or apps we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with other data we collect through the App. We work closely with third parties (including, for example, advertising networks, analytics and search information providers, software providers and hardware manufacturers) and may receive information about you from them.

2.4 IP addresses and click-stream data. An IP address is a number which is automatically assigned to your mobile device whenever you access the Internet. When you access our App, we log your IP address and can identify you from it. Click-stream data is information collected by us when you navigate the App, for example the specific sections of the App you looked at, the order you looked at them and the time of your use. We collect this information using our systems, Google Firebase and Intercom.

2.5 Aggregated data. We may collect and aggregate on an anonymous basis information about you, your spending and your use of the App with information about other users of the App in order to identify trends ("Aggregated Data"). Aggregated Data will not contain information from which you may be personally identified.

3.How We use your data

3.1 All data that we obtain about you will be used in accordance with current data protection legislation and this Privacy Policy. We, or third parties acting on our behalf, will collect, use and store your data listed above for the following reasons:

a) to process your registrations and allow you to access and use the App; 

b) to verify your identity for security purposes;

c) to provide you with the information and services that you request from us, including accessing real-time mapping data and static geo-located data ; 

d) to process your insurance transactions (including claims) and policy requests to enable us to quote insurance for you;

e) to price insurance and identify different pricing models that are tailored to your profile and drone usage;

f) to ensure the security of our services and App;

g) with your express consent only, we may also use your data to send you information about related products or services that may be of interest to you;

h) to contact you regarding administrative matters or notices or to deal with any enquiries made by you, to resolve disputes and to troubleshoot problems; 

i) to analyse information about you including your searching and browsing within the App and location data on a personalised or an aggregated basis; 

j) to provide guidance on how to use the App; and

k) to improve our risk models and algorithms.

3.2 We may track data about how you navigate the App to analyse App usage and how visitors navigate the App, to manage the App and to see what content is most popular. 

3.3 We may pass Aggregated Data to the third parties referred to in the section below, such as partners, to give them a better understanding of our business and to bring you a better service.

3.4 In processing your data as discussed in this Privacy Policy, we consider this processing is necessary for our legitimate interests in providing the App and ensuring it operates in a commercially suitable way which is tailored to your use and interests. In some cases, this processing is also subject to your consent (which can be withdrawn at any time, as described below).

3.5 Where you have given your consent for us to use your information in a particular way, but later change your mind, you should adjust the settings in the App by clicking through to the "Personal Details" tab through the "Main Menu" of the App, or contact us and we will stop doing so.

4. Disclosure of your data to third parties

4.1 We will share your information with Allianz, and will also share it with our broker, Worry & Peace. Allianz's use of your data is described in its privacy policy which can be accessed here, including where it uses your data if you make a claim under your insurance policy. 

4.2 We may also share your data with the following categories of third parties, including:

a) our employees, service providers, sub-contractors and agents to administer your account and the products and services provided to you by us now or in the future, including but not limited to our payment processors;

b) analytics providers that assist us in the improvement and optimisation of Our App; and

c) our distribution partners, which includes software developers, hardware developers and any other company that distributes pay-as-you-fly insurance policies on our behalf. 

4.3 Except for Allianz and Worry & Peace (for more information on how these companies are regulated, please look at our FAQ here), any third parties with whom we share your data are limited (by law and by contract) in their ability to use your data for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your data are subject to privacy and security obligations consistent with this Privacy Policy and applicable laws.

4.4 We may also disclose your data to third parties:

a) if we sell or buy any business or assets, we may disclose your data to the prospective seller or buyer of such business or assets;

b) if we, or substantially all of our assets, are acquired by a third party, your data held by us may be one of the transferred assets;

c) if we are under a duty to disclose or share your data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

d) if we are contacted by regulator or other government body, we may disclose whether you are a licenced drone operator and provide details of any specific flight you have made whilst using the App; 

e) in order to enforce or apply our Terms of Use or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

f) to protect the rights, property, or safety of us, our customers or other persons. This may include exchanging information with other organisations for the purposes of fraud protection and credit risk reduction.

4.5 Except as detailed above, we will never share, sell or rent any of your data to any third party without notifying you and/or obtaining your consent.

5. Optional and Future Services. There are optional services which you may choose to sign up to. The information required will vary for each service which is offered. This section explains the information we collect for each service, and how we may use it. These uses are in addition to the uses described in sections 3 and 4 of this Privacy Policy.

(a) Newsletters, emails and alerts. You may sign up to receive a newsletter or other emails and alerts when you sign up to the App, which will let you know about any additional products or services we offer and will provide you with useful flight tips. If you agree, we may share your information with them. You can cancel your subscription to newsletters, emails and alerts by contacting us via the email address or other methods which you will normally find at the bottom of the newsletter, email and alert in question.

Remember, if you consent to receive texts from us, your mobile network may impose a charge on incoming texts. Please check with your mobile network provider for details.

6. Retention of information

We retain your data for as long as you use the App, any other services we provide to you to which your data is relevant and then as required to comply with applicable laws for 10 years. 

7. Transfers of information 

7.1 Your data may be transferred to, and stored in the United States or another location outside of the European Economic Area.  

7.2 In particular, your data may also be processed by staff operating in the United States or outside the EEA working for us or third party data processors. Such staff may be engaged in, among other things, the provision of our services to you, the processing of transactions and/or the provision of support services. 

7.3 Some of these countries do not have laws that protect your privacy rights as extensively as those in the United Kingdom. However, if we do transfer your data to other territories, we will take proper steps to ensure that your data is properly protected and processed only in accordance with this Privacy Policy. 

7.4 By providing us with your data, you acknowledge that such transfer, storage and processing of your data may take place.

8. Your rights 

8.1 You may contact us by email at support@flockcover.com at any time, to request that we:

a) update any of your data which is out of date or incorrect;

b) delete any of your data which we are holding;

c) restrict the way that we process your data;

d) provide your data to a third party provider of services; or

e) provide you with a copy of your data which we hold about you.

8.2 Your request must include your name, email address used to register with the App and postal address, and we may also request proof of your identity. Please allow at least seven working days for us to process your request.

8.3 Without limiting the above, you have the right to ask us to not process your data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.Alternatively, you can contact us by email at support@flockcover.com at any time

8.4 If you have previously given your consent to the use of your data for marketing purposes, you can choose to stop receiving marketing communications which we send to you from time to time by following the unsubscribe instructions included in such communications. Alternatively, you can opt out of such communications at any time by contacting us by email at support@flockcover.com.

9. How do we protect your data?

We use industry standard efforts to safeguard the confidentiality of your data. All the data collected by us is stored on a secure server. Although we make every effort to protect your data, the transmission of data over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your transmitted data, and that any such transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to prevent unauthorised access. 

10. Links to other websites or apps

The App may contain links to other websites or apps, for example links to our website and any additional websites hosted on our website which can be accessed here. We are only responsible for the privacy practices and security of this App and our website. We are not responsible for the privacy policies, content or security of any linked websites or apps. We recommend that you check the privacy and security policies of each and every website or app that you visit through our App. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or apps or third party terms and conditions or policies.

11. Notification of changes to the Privacy Policy 

We reserve the right to change this Privacy Policy from time to time. Any such changes will be posted on this page, so that we can keep you informed of our information collection practices. However, we encourage users to be responsible about their privacy and recommend that you consult this page frequently so that you are aware of our latest policy and can update your preferences if necessary. Your continued use of this App shall constitute that you have read and understood the revised privacy policy. 

12. Contact Us 

If you have any comments or questions about this Privacy Policy, the practices of this App, or your dealings with this App, please address them to us at support@flockcover.com.  

If you are located in the EEA, you may also make a complaint to a supervisory body for data protection matters in the country in which you are based. In the UK, this would be the UK Information Commissioner's Office (https://ico.org.uk/). Alternatively you may seek a remedy through local courts if you believe your rights have been breached.

The practices described in this privacy policy statement are our current privacy policies and procedures as of 20/09/17.

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