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Gaggle Privacy Policy

Effective Date: 15 June 2023

Your privacy is very important to us. Before we get to the details, check out our Privacy Label to see a summary of our privacy practices. Click on the links to learn and read the full policy below.

Privacy Label

The following chart details these activities:

Collection and Sale of Data
Do we sell your personal information for monetary value?No
Do we share or sell aggregate information?Yes
Do we share your data with third party API partners?Yes, with your consent
Do we use sensitive categories of data, like health information?Yes, with your consent
Do we use your contact if you allow us access?No
Do we delete your data when you request account deletion?Yes
Do we retain your data for as long as we need it unless you request deletion?Yes
Privacy Tools and Controls
Can you control who sees your activity and content?Yes
Can you control who sees your location-based activity?Yes
Are you activity and profile privacy controls set to "Everyone" by default?Yes
Can you download and delete your data?Yes
Do all members worldwide have the same suite of tools and controls?Yes
Tracking
Do we track your device location to provide Gaggle to you?Yes
Do we track your device location while you are not using the app?No
Do we use cookies?Yes
Do we track your browsing activities on other sites?No
Do we listen to you on your device microphone?No
Communication
Do we give you advance notice when we make important changes to our Privacy Policy?Yes
Do we send you marketing communications with opt out?Yes
Do we send you push notifications with opt out?Yes

Privacy Policy

Gaggle is a product of Viszen (Pty) Ltd.

Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our websites and the related mobile applications and services (collectively, the “Services”). Please also read our Terms of Service which sets out the terms governing the Services.

Gaggle is headquartered in Centurion, South Africa, and our Services are provided to you by Viszen (Pty) Ltd. If you are a resident of the European Economic Area (“EEA”), Viszen (Pty) Ltd is the controller of your personal data for the purposes of EEA data protection law.

This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

Questions or comments about this Privacy Policy may be submitted by mail to the address below:

Viszen (Pty) Ltd
1 Logan Park
3 Melbroek Street
Centurion, 0157
Attn: Legal
[email protected]

Information Gaggle Collects

Gaggle collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with Gaggle. We receive information in a few different ways, including when you track, complete or upload flights (hereafter called activities) using the Services. Gaggle also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your friends, and your activities with Gaggle. For example:

Account, Profile, Activity, and Use Information

We collect basic account information such as your name, email address, username and password that helps secure and provide you with access to our Services.

Profile, activity and use information is collected about you when you choose to upload a picture, activity (including date, time and geo-location information as well as your speed, altitude, and other sensor information) or post, join a challenge, add your equipment usage, view others’ activities, or otherwise use the Services.

We use your contact information so we can respond to your support requests and comments.

Location Information

We collect and process location information when you sign up for and use the Services. We do not track your device location while you are not using Gaggle, but in order to provide Gaggle's core Services, it is necessary for us to track your device location while you use Gaggle. If you would like to stop the device location tracking, you may do so at any time by adjusting your device settings.

Content You Share

We gather information from the photos, posts, comments, likes, ratings, reviews, messages, and other content you share on the Services, including when you participate in partner events or create routes.

Connected Devices and Apps

Gaggle collects information from devices and apps you connect to Gaggle. For example, you may connect your Garmin watch or Variometer to Gaggle and information from these devices and apps will be passed along to Gaggle.

Health Information

Gaggle may collect or infer health information. Certain health information may be inferred from sources such as heart rate or other measurements. Before you can upload health information to Gaggle, you must give your explicit consent to the processing of that health information by Gaggle. You can withdraw your consent to Gaggle processing your health information at any time.

Payment Information

When you make a payment on Gaggle, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry compliant third-party payment services and we do not store your credit card information.

Third-Party Accounts

Gaggle allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook, Google, or Apple (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences. This information is collected by the Third-Party Account provider and is provided to Gaggle under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account.

Technical Information and Log Files

We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information. Learn more about how we use cookies and manage your preferences by visiting our Cookies Policy.

The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to session IDs, athlete IDs and device identifiers.

Other Information

We may collect information from you through third parties, such as when we collect your feedback through surveys.

We may also collect information about you from other members such as when they give you likes, view your activities, comment on your activities.

How Gaggle Uses Information

Gaggle uses the information we collect and receive as described below.

To provide the Services

We use the information we collect and receive to provide the Services, including providing you with the ability to:

  • Record your activities and analyze your performance. For example, to compare your past efforts, analyze your training, and (with your consent) use your heart rate information to provide you with interesting and useful performance analysis.
  • Interact with other pilots. For example, to compete on routes, participate in groups, challenges, or events, follow other pilots, and use features that help pilots interact with one another, such as group activities or nearby pilot suggestions.
  • Manage your training and skill progression. For example, to set goals and use your training dashboard.
  • Explore new places to go. For example, to discover routes or flying sites where you can go flying.
  • To visualise your activities in new ways. For example, by showing your flights in 3d replays.

Subject to your privacy controls, your information, including parts of your profile, username, photos, members you follow and who follow you, groups you belong to, your activities, the devices you use, and lieks and comments you give and receive will be shared on Gaggle so that you may be able to participate in the Services, for example to show your place on a leaderboard. Certain information (e.g., your name, and some profile information) is also available to non-members on the web. Your precise location information, such as where you fly, may also be shared on Gaggle or to non-members, in accordance with your privacy controls.

To customise your experience

We use the information we collect about you, your followers, and your activities to customise your experience. For example, we may suggest flying sites, routes, challenges, or groups that may interest you, pilots that you may want to follow, or new features that you may want to try. If we know that you like to fly paramotor, we may tell you about new paramotor activities or show you sponsored content related to paramotoring. If we see that you fly in a certain area, we may suggest a fly-in in that area.

To protect you and the Services

We use the information we collect to protect members, enforce our Terms of Service and Community Standards, and promote safety. For example, we find and remove content that violates our terms, such as hate speech or spam, as well as suspend or terminate accounts that share such content.

To improve our Services

We also use the information we collect to analyse, develop and improve the Services. To do this, Gaggle may use third-party analytics providers to gain insights into how our Services are used and to help us improve the Services.

To communicate with you

We use the information we collect to provide support in response to your requests and comments.

We may also use the information we collect to market and promote the Services, activities and events on Gaggle, and other commercial products or services. This includes marketing and push communications, where you have not opted out of receiving such messages and notifications.

To process your subscription

We use the information we collect to process your subscription.

Aggregate Information

We do not sell your personal information. Gaggle may aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties. Examples of the type of information we may aggregate include information about equipment, usage, routes, popular flying sites, and performance. Gaggle may use, sell, license, and share this aggregated information with third parties for research, business or other purposes such as to improve flying in some areas by working with associations and clubs or to help our partners understand more about pilots, including the people who use their products and services. Gaggle also uses aggregated data to generate global insights of pilot activity across the world.

How Information is Shared

In addition to sharing aggregated data about our members as described above, we also share personal information in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below.

Service Providers

We may share your information with third parties who provide services to Gaggle such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf, so that we or they may promote Gaggle or display information that may be relevant to your interests on the Services or other websites or services.

Publicly Available Information

When you join the Gaggle community, your profile and your activities are set to be viewable by everyone by default. Your name and other profile information is viewable by other Gaggle members and the public and, subject to your privacy controls, additional information and content you share may also be viewable. For example, your photos, routes, and public groups may be accessed by other Gaggle members and non-members or viewable on publicly accessible Gaggle pages or in search engine results. We provide a variety of tools to control the sharing of your information and encourage our members to adjust their controls to align with their desired experience.

Sharing Information and Activities

As a social network, we share your information with other Gaggle members and the public in accordance with your privacy controls. You can change the visibility of the activities you upload to Gaggle. Also, you can tell us about important locations, such as private flying sites, by enabling privacy mode in the settings for each flying site. We will make private any activity that starts or ends in your sites privacy zone. You can also choose to share your live location while you fly with other members, which can be controlled in the same manner as activities. You can also share your activities with your contacts via text, email, or on social media applications like Facebook, Instagram, and Twitter. If you link your Gaggle account to other social networks and share your activities, they will be viewable on such third-party platforms, including your location information. You should use caution when sharing information via third parties and you should carefully review the privacy practices of such third parties.

Third Party Business via the Gaggle Business Portal, API ,or Other Integrations

We enable you to share your information and content with third party apps, plugins, or websites that integrate with the Services, as well as with third parties who work with Gaggle to offer an integrated feature, such as a challenge sponsor or tracking watch. You can choose to share your profile data and activity data (including private activities). Information collected by these third parties is subject to their terms and policies. Gaggle is not responsible for the terms or policies of third parties.

Affiliates and Acquirors of our Business or Assets

We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If Gaggle becomes involved in a business combination, securities offering, bankruptcy, reorganisation, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction.

Legal Requirements

We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that this is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of Gaggle or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

DMCA Notices

We may share your information with third parties when we forward Digital Millennium Copyright Act (DMCA) notifications, which will be forwarded as submitted to us without any deletions.

How We Protect Information

We take several measures to safeguard the collection, transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. Gaggle engages providers that are industry leaders in online security, including Services verification, to strengthen the security of our Services. The Services are registered with site identification authorities so that your browser can confirm Gaggle's identity before any personal information is sent. In addition, Gaggle’s secure servers protect this information using advanced firewall technology.

Managing Your Settings

Privacy Controls

Gaggle offers several features and settings to help you manage your privacy and share your activities. Most privacy controls are located in your account settings, but some are specific to individual activities, pilots, routes, flying sites, or groups. Gaggle provides you the option to make your activities private.

Adjust Notification and Email Preferences

Gaggle offers various ways to manage the notifications you receive. You can choose to stop receiving certain notifications by indicating your preference in specific section for notifications, like groups or followers. You may also unsubscribe by following the instructions contained at the bottom of marketing or promotional emails. Any administrative or service-related emails (to confirm a purchase, or an update to this Privacy Policy or our Terms of Service, etc.) generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested.

Updating Account Information

You may correct, amend or update profile or account information at any time by adjusting that information in your account settings. If you need further assistance correcting inaccurate information, please contact Gaggle at [email protected]

Deleting Information and Accounts and Downloading Your Data

You can delete your account or download your data using our self-service tools. You can download some data like your flight recordings and flights. To request that your account is deleted, you can initiate the process from your account settings page.

After you make a deletion request, we permanently and irreversibly delete your personal data from our systems, excluding backups. Once deleted, your data, including your account, activities and place on leaderboards cannot be reinstated. Following your deletion of your account, it may take up to 90 days to delete your personal information and system logs from our systems. Additionally, we may retain information where deletion requests are made to comply with the law and take other actions permitted by law.

Note that content you have shared with others, such as photos or shared routes, or that others have copied may also remain visible after you have deleted your account or deleted specific information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

Gaggle also provides you the option to remove individual activities you have posted without deleting your account. Once removed, the activities may remain on Gaggle's systems until you delete your account.

Your Rights and Our Legal Base

We provide the same suite of privacy tools and controls to all of our members worldwide. Particular rights may be available to you if you reside in certain locations, such as the EEA, Brazil or California.

Your Legal Rights in the EEA

If you are habitually located in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. Gaggle’s lead supervisory authority in the EEA is the Data Protection Commission of Ireland.

Our Legal Bases

Gaggle relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • as necessary to provide the Services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide the Services unless we collect and use your location information;
  • where you have consented to the processing;
  • where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  • to protect your vital interests, or those of others, such as in the case of emergencies; and
  • where necessary for the purposes of Gaggle’s or a third party’s legitimate interests, such as our interests in protecting our members, our partners’ interests in collaborating with our members, and our commercial interests in ensuring the sustainability of the Services.

Transfers

The Services are operated from South Africa, with data being stored and process in Germany. If you are located outside of Germany and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in Germany, as it is necessary to provide the Services and perform the Terms of Service. South African privacy laws may not be as protective as those in your jurisdiction.

Retention of Information

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account. For example, after you withdraw your consent to Gaggle processing your health-related information, Gaggle will delete all health-related information you upload. Following your deletion of your account, it may take up to 90 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Gaggle, such as statistics of the use of the Services. For example, we may retain publicly available flights or routes and other depersonalised geolocation information to continue to improve the Services. This information will be de-associated with your name and other identifiers.

Other Gaggle Sites

Gaggle maintains certain websites that can be accessed outside of https://flygaggle.com (the “Other Sites”). The Other Sites maintain the look and feel of the Services, but are hosted by outside service providers with their own terms and privacy policies. If you interact with the Other Sites, your information may be stored, processed, or shared outside of the Services. If you interact with the Other Sites, you acknowledge that you may be subject to the terms and conditions and policies applicable to such Other Site. Please be aware that any personal information youå submit to the Other Sites may be read, collected, or used by other users of these forums indefinitely, and could be used to send you unsolicited messages. Gaggle is not responsible for the personal information you choose to submit via the Other Sites.

Privacy Policy Information

Gaggle reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Gaggle makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.

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