Privacy & Data Policy

Effective: June 5, 2018

This privacy policy describes what data is collected and how it is collected; how the data collected is used; how data is stored and protected; when and with whom collected data is shared; and your choices regarding your data.

By using products or services provided by Grab Analytics LLC, including solutions branded as Flightly (“we”, “us”, “our”, “Flightly”, “Grab Analytics”), you agree to the collection, storage, transfer, disclosure, and use of your data as described in this privacy policy.

Information Collected

We collect some data to enable functionality in our products, provide personalized assistance, and improve our products & services. Your privacy is important to us, so we limit the amount of personally identifiable information collected or shared. We do not collect any sensitive information. We will never spam you or sell your information.

Data We Collect

1) Usernames, IDs, campaign information, and metrics

Why We Collect This Data - To provide the “Notifications” feature in the mobile app; to understand usage to improve our products and services; to provide personalized assistance to users when requested.

How We Collect & Store It - This information is collected from the Twitter Ads API for accounts that have Notifications enabled. The data is stored on a secure cloud based server on the Microsoft Azure platform.

Your Privacy Choices - You may opt out of this collection by disabling & deleting all notifications created for all your ad accounts. You can also choose to deauthorize the Flightly app from the Twitter App Settings. We may retain previously collected data even if you deauthorize or otherwise terminate your account. You can request previously collected information to be deleted by contacting us.

Data Collected through Third Party Services

We use third party services such as analytics providers to measure app & website usage, provide personalized assistance, and create targeted marketing campaigns. You may be additionally subject to the privacy policies of the third party providers.

We use the following third party services to collect and store data:

  • Localytics
  • Firebase Analytics / Crashlytics

1) Mobile Device Identifiers

  • Apple’s IDFA and Google’s Advertising ID

Why this Data is Collected - This information is used to attribute mobile installs & actions to targeted advertisements; to create retargeting & lookalike audiences; and to exclude existing users from new marketing campaigns.

How this Data is Collected and Stored - The device identifiers are collected through Localytics, a third party analytics & attribution company based in the United States, and stored for a maximum of 37 months. Grab Analytics does not have access to individual device identifiers.

Your Privacy Choices - You have the ability to limit ad tracking or to reset your device identifiers. On iOS, go to Settings > Privacy > Advertising. For Android, visit the Google Settings app > Google > Ads.

2) Basic App Usage & Device Data

  • Generic, events such as app install, app open, session length, and crash information
  • Device model, OS version, app version, country

Why this Data is Collected - We use this information to understand usage of our apps, including crashes, so that we can improve the reliability of our products and services

How this Data is Collected and Stored - This data is automatically collected upon any app usage. We use Localytics and Firebase Analytics / Crashlytics to track these basic events and usage.

3) App Specific Data

  • Actions taken within the app (logging in, modifying a campaign, composing a tweet, etc)
  • Basic Twitter information (ad account name, funding instrument type)

Why this Data is Collected - To understand and evaluate usage around specific features of our apps and to provide personalized assistance to our users upon request

How this Data and Stored - This data is collected and stored through Localytics, a third party analytics & attribution company based in the United States for a maximum of 37 months.

4) Website Visits

  • Cookies, Pixels

Why this Data is Collected - We use cookies and pixels from Google Analytics and Twitter in order to identify visits to our websites, and to create retargeting & lookalike audiences in campaigns.

How this Data is Collected and Stored - This data is collected and stored on Google Analytics and Twitter platforms. We do not have access to individual IP addresses.

Your Privacy Choices - You may limit or opt out of tracking and ads personalization by following the steps provided by the following third party platforms we use: Twitter and Google. Google separately offers a browser extension to opt out of Analytics tracking; learn more here. You can also use ‘incognito’ mode on many browsers to limit cookies or pixels.

Email Communication

We sometimes use email to communicate important information or updates around products & services.

1) Automatically Collected

Why this Data is Collected - We may choose to automatically collect the email address associated with your Twitter account for the purpose of sending product updates, including critical information, for the products/services you are using.

How this Data is Collected and Stored - This information is provided to us when you authorize with Twitter. We may collect and store this information on our database. Additionally we use a third party service, Mailchimp, to email multiple users at once; your email address will be sent to Mailchimp.

Your Privacy Choices - You can opt out of email updates and delete your email from Mailchimp by visiting the ‘Unsubscribe’ link at the bottom of a received email.

2) Opt In

Why this Data is Collected - We may offer services, such as a newsletter, which requires a user’s name and email address.

How this Data is Collected and Stored - This data will be opt-in only, meaning users must explicitly enter this information and give permission to sign up. Email addresses will be stored on Mailchimp.

Your Privacy Choices - You can opt out of email updates and delete your email from Mailchimp by visiting the ‘Unsubscribe’ link at the bottom of a received email.

Information Sharing and Disclosure

Grab Analytics, LLC does not disclose personal information except in the limited circumstances described here.

By User Consent or Direction

Flightly may share or disclose your information at your discretion, such as authorizing a third party application to access your account.

Law and Harm

Notwithstanding anything to the contrary in this privacy policy, Flightly may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Flightly and Grab Analytics, LLC’s rights or property. However, nothing in this privacy policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

Business Transfers and Affiliates

In the event that Flightly or Grab Analytics, LLC is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. We may also disclose information about you to our partners and affiliates in order to help provide, understand, and improve our services.

Non-Personal or Non-Private Information

Flightly reserves the right to share campaign data in an anonymized or aggregated way with its partners, clients, and potential clients. Users can choose to opt out of having their data shared in an anonymized or aggregated way by contacting us.

Security

Grab Analytics LLC, and the products & services it offers, including Flightly, use reasonable security measures to store and protect data collected that are under our control and appropriately limit access to it, and to the third party partners we use. However, no system can be completely secure. Therefore, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.

Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our system that materially affects you, we will notify you within 72 hours of discovery of the breach.

Information for Users Outside the United States

We are based in the United States and the information we collect is governed by US law. If you are accessing any of our products or services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using products or services offered by Grab Analytics, you understand that your information may be transferred to our servers and those third parties with whom we share it as described in this Privacy Policy.

Our Policy Towards Children

Our services are not directed to persons under 16. We do not knowingly collect personal information from users under 16. If we become aware that a person under 16 has provided us with personal information, we will take steps to remove such information.

Changes to this Policy

Grab Analytics, LLC may revise this privacy policy from time to time. The most current version of the policy will govern our use of your information and will be available from https://www.flightly.com. If we make a change to this policy that, in our sole discretion, is of material, we will notify you via an update on our social media account or email. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised privacy policy.