This Privacy Policy (the “Policy”) describes what Personal Information Kespry Inc. (“Kespry”, “we”, “us”, “our”) gathers about you, how we use and disclose that information, and what we do to protect it. This Policy applies to Personal Information we collect to operate our website, and to market, provide and improve our products and services.

If you are a Kespry Customer, this Policy is incorporated into and is subject to the End User License Agreement and your Customer Agreement, and capitalized terms used but not defined in this Policy have the meanings given to them in those agreements.

The practices described in this Policy apply only to Kespry’s use of Personal Information. This Policy does not apply to the practices of companies that Kespry does not own or control, or to people that Kespry does not employ or manage, such as third-party web services made available to you through the Online Services or our website. Before using such third party services, you should familiarize yourself with the privacy policies provided by such third parties to understand their practices with respect to the collection, use, and disclosure of Personal Information.

This Privacy Policy only applies to the activities for which Kespry is a “data controller” which means that Kespry decides why and how Personal Information is processed. Kespry may also process Personal Information as a data processor in the context of the services we provide to our business customers. When we process Personal Information on behalf of our business customers, they determine why and how the Personal Information is processed. To learn more about the processing of your Personal Information in this context, please refer to their respective privacy policies.
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Information We Collect

For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable individual.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from Kespry’s products and services if that information is necessary to provide you with them or if we are legally required to collect it. We obtain Personal Information relating to you from various sources described below.

Information Provided by You

• Contact details of business customers, partners and vendors. When employees at our customers register our Software Application or otherwise interact with us, they may provide to Kespry Personal Information, such name, email address, physical address, telephone number, and other information that can be used to identify them. We may also receive contact details of other business partners’ and vendors’ employees as provided by them in furtherance of the relevant partner or vendor relationship, such as first and last name, email address and phone number.
• Communications. If you contact us directly, we may receive additional information about you. For example, when you use our online contact form, we ask you to provide your first and last name, email address, company, phone, country, industry, title, and information on what you are interested in (e.g., a demo, partnership with Kespry etc.). We also offer a chatbot functionality powered by Drift on our website to allow you to ask us questions and send files. When you contact us via the chatbot or directly via email, we will receive the content of your message and any attachments thereto, the date and time of your message, our reply and the email address you used if you are sending an email.
• Job applications. You may submit your job application via our online career page or by sending us an email. You may also click on the “Log in with LinkedIn” button to apply via LinkedIn by granting us access to your LinkedIn profile information. If you submit your application via the online career page, we ask you to provide your resume, first and last name, email address, phone, city and LinkedIn profile. In addition, you may choose to provide a cover letter, website and information on how you heard about this job. If you click on “Locate me”, we will use information collected via automated means to determine your approximate location.

Information Collected via Automated Means

• Flight data. When you use a Kespry Drone System, the Equipment will capture information during flight and other information that is related to the operation of the System such as raw sensor data, telemetry data, geolocation of the drone, flight and application logs, diagnostic information, performance information, and Software Application usage information. This information may be uploaded to Kespry’s Online Services before, during, or after use of the System.
• Geolocation data. The Software Application provides features that enable Kespry to tailor customer experience based on location (“Location-based Services”). To use Location-based Services, you must allow Kespry access to your position through your mobile device, which Kespry may accomplish through a variety of means, including GPS location, if available. If you choose to disable location-based services, you will not be able to utilize certain features of the Software Application.
• Cookies and similar technologies. When you use the Online Services, visit our website, or open one of our HTML emails, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer and automatically record certain information from your web browser and/or email by using different types of technology, including standard logging, “clear gifs,” or “web beacons”. Kespry 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. Persistent cookies can be removed. This information may include Internet Protocol address or other device address or ID, web browser and/or device type and operating system, the web pages or services that referred you to our website or the Online Services, the pages you view, and the dates and times that you visit, access, or use our website or the Online Services. 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 from the Services, you may not be able to utilize the features of our website or the Online Services to their fullest potential.
• Google Analytics. We also work with analytics providers such as Google Analytics, MixPanel, and Heap which use cookies and similar technologies to collect and analyze information about use of our website and report on activities and trends. You can learn about Google’s practices by going to https://www.google.com/policies /privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at: https://tools.google.com/dlpage/gaoptout.

Information Collected via Third Parties

• Social Sign-On. We may collect Personal Information about you when you log in to your Kespry account via third party services (such as Box, Dropbox, and Google). This information may include names and email addresses or login ids.
• Information from Other Sources: We may also obtain information, including Personal Information, from other third parties and sources other than the above.

How Kespry Uses Information about You

Kespry may use Personal Information about you:

• To provide our business customers the Kespry services, including to operate, maintain, enhance, and provide the Kespry Drone System, to operate the Equipment during flight, to help maintain and support the Equipment between flights, and to create the Visual Information delivered via the Online Services. In this context, we may process Personal Information about other individuals as a data processor acting on behalf of our business customers. To learn more about the processing of your Personal Information in this context, please refer to their respective privacy policies.
• To operate, maintain, enhance and provide the Kespry website and communicate with you via the Kespry chatbot.
• To manage the relationship with our business customers, partners and vendors, including contacting their employees for administrative purposes, for customer service purposes, or regarding any submissions we may receive (such as registration).
• To develop, enhance, improve and create new features, products, and services by analyzing Personal Information we collect about you, such as Flight Data.
• To understand and analyze the usage trends and preferences of our business customers and website users, to improve the way the Kespry Drone System and website work and look, and to create new features and functionality.
• To personalize customer experience of the Online Services. For example, when you log back in, we may welcome you back to the Online Services by name, present you with a customized user interface.
• Kespry may use information collected via automated means to (a) provide customized third-party content and information; (b) monitor and analyze the effectiveness of Kespry and third-party marketing activities; and (c) monitor aggregate usage metrics such as total number of visitors, pages viewed, etc.
• To send promotional email related to products or services that we think may interest you.
• To process your job application and any information you provide to us in this context, whether you submit it via our online career page or by sending us an email.
• For our business purposes, such as audits, security, compliance with applicable laws and regulations, to enforce the relevant End User License Agreement or Customer Agreement or other legal rights.

When Kespry May Use Information about You

If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when:

• You have consented to the use of your Personal Information;
• We need your Personal Information to provide you with the Kespry’s products and services, including for account registration or to respond to your inquiries;
• We have a legal obligation to use your Personal Information;
• We or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our products and services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

How Kespry Shares and Discloses Information about You

We are not in the business of selling your information. We do, however, need to disclose your Personal Information in a variety of circumstances in the ordinary course of operating our business. For example:

• When we process Personal Information on behalf of our business customers, we share that information with them (e.g., Visual Information provided via the Online Services).
• When you log in to your Kespry account via third party services (such as Box, Dropbox, and Google), we share Personal Information about you with these third parties.
• Kespry may work with third party service providers that provide web service hosting and maintenance as well as other services to us. In the course of performing services for Kespry, these providers may have access to or process your Personal Information on our behalf.
• Kespry may also disclose your information in the good-faith belief that we are required to do so by state or federal law, or in response to a court order, judicial or administrative subpoena or warrant, or to otherwise cooperate with law enforcement investigations. Kespry also reserves the right to disclose information as is necessary to protect Kespry or others from fraudulent, abusive, unlawful, or otherwise inappropriate uses of the Online Services or the website; to investigate and defend ourselves against third-party claims or allegations; to protect the security or integrity of the Online Services; or to protect the rights, property, security, and/or safety of Kespry, our business customers and website users, or third-parties.
• In the event that Kespry or its assets are acquired by or merged with a third party entity, Kespry reserves the right, in any of these circumstances, to transfer or assign the information that we have collected from users in connection with such merger, acquisition, sale, or other change of control.

Your Choices and Rights

You have certain choices with respect to your Personal Information:

• You may, of course, decline to share certain Personal Information with Kespry, in which case Kespry may not be able to provide some of the features and functionality found on the Online Services or our website to you.
• You may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page through the Online Services. Please note that while your changes may be reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.
• You may have the ability to opt-out of receiving marketing communications from us by updating your account settings through the Online Services or clicking on links embedded in such messages.

If you are located in the European Economic Area, you may have additional rights described below. These rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us as indicated at the bottom of this Policy.

• You have the right to request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• You have the right to withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

International Data Transfers

The Online Services are hosted in the United States. If you are visiting from the European Economic Area or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your Personal Information to the United States, which does not have the same data protection laws as your jurisdiction, and by providing your Personal Information you consent to the transfer of your Personal Information to the United States as indicated above.

Confidentiality and Security

Kespry employs appropriate physical, administrative, and technical safeguards to help protect Personal Information, data uploaded by the Kespry Drone System, and Visual Information stored on behalf of our business customers.

To protect your privacy and security, we take steps to verify your identity before granting account access to you or making corrections to your information. Please note, you are responsible for maintaining the secrecy of your unique password and account information at all times.

If Kespry learns of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps, by posting a notice on our website i or sending you an email. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. We may not be able to notify you of a security breach if we do not have your contact details. To receive mandatory security notifications, please sign up at: <a href=”mailto:privacy@kespry.com”>privacy@kespry.com</a>.

The following is a summary of the measures Kespry takes to protect your information and descriptions of ways we implement these measures for different types of information you may provide to us:

• Secure Socket Layer (SSL). Kespry uses SSL (Secure Socket Layer) encryption when transmitting certain kinds of information. An icon resembling a padlock is displayed on the bottom of most browser windows during SSL transactions.
• Vendors and Partners. Kespry works with vendors and partners to protect the security and privacy of information.
• Employee and Contractor Access to Information. Kespry limits access to Personal Information about you to those employees who we reasonably believe need to come into contact with that information to provide products or services to us or in order to do their jobs.

Please note, however, that this is not a guarantee that Personal Information may not be accessed, disclosed, altered, or destroyed by breach of any of our systems or safeguards. We cannot guarantee or warrant the security of any information you transmit to Kespry, and you transfer such information to us at your own risk.

Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrolment with our services, the impact on the services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

Contact Information

Please contact Kespry with any questions or comments about this Policy, your Personal Information, our third party disclosure practices, or your consent choices by email to <a href=”mailto:care@kespry.com”>care@kespry.com</a> or by writing to us at: