Navigraph menu Get Started Navigraph Privacy Policy Navigraph KB (”we”, ”us”, ”Navigraph”) is committed to protecting and respecting your privacy. This policy (the ”Privacy Policy”), together with our Terms of Service, sets out how we collect, store and process any personal data that we gather through our website, our software, or that you provide to us directly. Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. Should we ask you to provide certain information by which you can be identified when using this website, or our software, then you can be assured that it will only be used in accordance with this Privacy Policy. In accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679: We clearly state the categories of personal data we process about you, the purpose for processing the personal data and the legal basis for our processing. We do that via this Privacy Policy. We limit the amount of personal data we collect and process to only include information which is necessary for the purposes set out in the table below. We use sufficient security measures to protect your personal information, and we demand that partners processing information on our behalf also use sufficient security measures. We respect your rights regarding your personal data, including your right to access, object, edit or delete personal data. We may change this Privacy Policy from time to time by updating this page. You should check this page frequently to ensure that you are happy with any changes. In case of material updates or changes to the Privacy Policy, we will inform you by sending you an email. This version of the Privacy Policy is effective from 24 November 2021. 1. Personal data we may collect and process about you In providing our services, and when you use our software, register for an account or a subscription, or otherwise communicate with us, we may process different categories of personal data. Below you find a brief description of the different categories of personal data we may process: Personal details – includes your username, name, country of residence, avatar picture and the email address you have provided in connection with registering your account. Purchase history – all purchases (e.g. purchases for subscriptions) you have made, including historical payment information. User ID – a unique user identification number created when you register your account. Payment information – information on your chosen payment method (e.g. credit card or PayPal). We do not have access to or store specific details regarding your payment method (e.g. your credit card number or similar). User data – includes data processed as part of your usage of our services, including installed flight simulation related software, aircraft position and IP-address. Usage history – includes data on how you have historically used our website and services. Third-party cookies – means cookies of some of our business partners, gathering information on your interactions with our website. 2. Purpose of our processing and the legal basis According to the GDPR, processing of personal data may only take place in relation to specific and legitimate purposes, and is only lawful to the extent it is supported by one or more legal bases. The table below sets out for what purposes we process your personal data, our legal basis for such processing and the categories of personal data concerned. Purposes of processing Legal bases of processing Personal data processed To deliver data in and otherwise deliver our services in accordance with the Terms of Service, communicate with you to provide support, or otherwise administer and communicate with you regarding your account or subscription. Performance of contract Personal details Purchase history User ID User data For internal record keeping, primarily to comply with legal obligations (e.g. tax and accounting laws) Legal requirement Personal details Purchase history User ID To promote or market goods and services and improve our marketing practices, e.g. by sending you email marketing and sharing your personal details with our marketing partners Legitimate interest Personal details Purchase history User ID To improve our website, services and software Legitimate interest Usage history To provide aircraft position for moving maps and other context dependent software functions Legitimate interest User ID User data Tracking of website visitors and targeted advertising via Google Analytics and Facebook Pixel (see Section 6 below for more information) Consent Third-party cookies To investigate, detect and prohibit use of our services in violation of the Terms of Service or applicable legislation. Legitimate interest User data Usage history Personal details Payment information Purchase history User ID Process your payments Performance of contract Payment information Personal details Purchase history User ID In the table above, you can see that some of our processing is justified with reference to our “Legitimate interest”. This means that, in relation to the specific processing purpose, we consider that our interest in being able to process the personal data overrides your right to not have the personal data processed for these purposes. If you want more information on how we have made this assessment, feel free to contact us (see Section 9 below). 3. Where we store your personal information We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable safety procedures to safeguard and secure the personal data we process about you. The personal data that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. The laws in some countries may not provide as much legal protection for your personal data as in the EEA. If we transfer any personal data collected within the EEA to a country outside the EEA, we will take all reasonably necessary steps to ensure that such transfer is carried out securely and in accordance with the requirements of the GDPR, e.g. by implementing the so called standard contractual clauses approved by the EU Commission. 4. How long we store your personal information Generally, we do not store your personal data for any longer period than what is strictly necessary to fulfil the purposes for which the personal data was collected (see the table under Section 2 above). Most categories of personal data will be processed for as long as you have an active account with us, but in some cases we may need to store your personal data also after you have cancelled your account, in order to comply with mandatory Swedish legislation (for example, Swedish tax authorities require payment information to be stored for seven and a half years following the relevant transaction). 5. Sharing your personal data Generally, we do not sell, distribute or lease your personal information to third parties unless you have provided your explicit consent to do so. In certain situations we may, however, share your personal data with third parties and below you will find a brief summary of the recipients with which we may share your personal data, and why we share the personal data. Third-party suppliers, business partners and marketing partners Our services are to some extent dependent on third party suppliers, service providers or business partners. Therefore, we may need to provide such third parties with your personal data for the purposes of being able to provide you with the services in accordance with your subscription with us. If such third party processes your personal data on our behalf, we will always enter into a data processing agreement with such third party, ensuring that they process your personal data in a secure manner and in accordance with our instructions. Furthermore, in order to improve our marketing practices and ensure that the marketing we send you remains relevant, we may share limited personal data (namely your email address) with certain online marketing partners (such as Facebook and Google). Prior to sharing, we will ensure that the personal data is pseudonymised or ”hashed”. Law enforcement and authorities We may share your personal data with authorities, when we are obliged to do so in accordance with a legal obligation under applicable law, or to comply with any court order, subpoena or similar. Purchasers of our business In the event we are contemplating selling parts of, or our entire, business to a third party, we may share certain categories of your personal data if necessary for the consummation of such sale of our business. We will, in these cases, as far as possible anonymise or aggregate your personal data in a way making it impossible to trace the personal data back to you as an individual. 6. Google Analytics, Facebook Pixel and Cookies Google Analytics and Facebook Pixel As mentioned in the table under Section 2 above, on our website we use Google Analytics and Facebook Pixel, primarily for the purposes of gathering statistics regarding how our visitors interact with our website and to be able to target advertising to our website visitors through online ad networks (e.g. via Google, Facebook and Instagram). Other cookies On our website we also use “cookies”. A cookie is a small file which asks permission to be placed on your computer's hard drive. Cookies allow websites to respond to you as an individual and tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and to provide interest-based advertising. Your consent Any processing of personal data that we carry out by using Google Analytics, Facebook Pixel and other cookies is optional, and we rely on your consent to justify such processing. On our website we have included a “cookie consent-module”, available at all times, where you are able to freely choose to allow or restrict any cookies or processing through Google Analytics and Facebook Pixel. The “cookie consent-module” further includes links to relevant privacy documents of Google and Facebook. 7. Links to other websites Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. To clarify, this Privacy Policy does not cover any processing of your personal data on such other websites. Therefore, it is very important that you read through the privacy statement/policy of any such other website prior to sharing or disclosing any personal data with such website. 8. Your rights According to the GDPR, you are afforded several rights with respect to your personal data, and below we have summarized what rights you have and when and how you may exercise them. Right to access – meaning that you have a right to be informed of, and get access to, the personal data we process about you. Right to rectification – meaning that you have a right to request that we amend/update any personal data we process about you which is inaccurate or incomplete. Right to deletion/restriction – meaning that, under certain circumstances, you have a right to request that we delete, or limit our processing of, the personal data we process about you. Right to object – meaning that you have the right to object to any processing of your personal data carried out for marketing purposes or in other cases where we are justifying our processing of your personal data based on our “legitimate interests”. Right to data portability – meaning that you, under certain circumstances, have the right to request to receive the personal data we process about you in an electronic format for the purposes of using such personal data in relation to another party’s services. Some of the rights listed above can be exercised through the preferences settings in your account, for example if you want to object to our processing of your personal data for marketing purposes. Furthermore, some of the rights set out above are not unconditional. For example, we may be obligated to process some of your personal data to comply with our legal obligations (e.g. in relation to Swedish accounting and tax law), and under such circumstances we are not obligated to delete said personal data upon your request. Lastly, to avoid any misunderstanding, a majority of our services are dependent on our processing of certain categories of your personal data – and should you request deletion of such personal data, we will no longer be able to provide you with the relevant services. 9. Data controller and contact information Navigraph KB, (SE969697064001), Stora Nygatan 7, 111 27 Stockholm, Sweden, is the data controller in relation to the processing of personal data covered by this Privacy Policy. If you have any questions regarding the Privacy Policy, or if you want to exercise any of your rights, please contact us at account@navigraph.com. 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