Privacy Policy

This privacy policy (“Policy”) describes how Simple Flying Limited (“Simple Flying Limited”, “we”, “us” or “our”) collects, protects and uses the personally identifiable information (“Personal Information”) you (“User”, “you” or “your”) may provide on the simpleflying.com website and any of its products or services (collectively, “Website” or “Services”).

It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Automatic collection of information

Our top priority is customer data security and, as such, we exercise the no logs policy. We process only minimal user data, only as much as it is absolutely necessary to maintain the Website or Services. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding Website usage. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

Collection of personal information

You can visit the Website without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the Website’s features, you will be asked to provide certain Personal Information (for example, your name and e-mail address). We receive and store any information you knowingly provide to us when you publish content, or fill any online forms on the Website. When required, this information may include the following:

  • Personal details such as first names, last names
  • Contact information such as your email address

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the Website’s features. Users who are uncertain about what information is mandatory are welcome to contact us.

Storing personal information

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

Use and processing of collected information

In order to make our Website and Services available to you, or to meet a legal obligation, we need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Some of the information we collect is directly from you via our Website. However, we may also collect Personal Information about you from other sources. Any of the information we collect from you may be used for the following purposes:

  • Send marketing and promotional communications
  • Respond to inquiries and offer support
  • Request user feedback
  • Run and operate our Website and Services

Processing your Personal Information depends on how you interact with our Website, where you are located in the world and if one of the following applies: (i) You have given your consent for one or more specific purposes. This, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (ii) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) Processing is necessary for compliance with a legal obligation to which you are subject; (iv) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Information transfer and storage

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.

The rights of users

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

The right to object to processing

Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible.

California privacy rights

In addition to the rights as explained in this Privacy Policy, California residents who provide Personal Information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please contact us.

Privacy of children

We recognize the need to provide further privacy protections with respect to Personal Information we may collect from children and take many special precautions to protect the privacy of children. We do not require a child to disclose more information than is reasonably necessary to use the Website and Services. We encourage children to consult with their parents before submitting any information to any Website, including simpleflying.com. We believe parents should be involved in the online activities of their children and suggest that parents do their best to provide their children with a safe and friendly online environment.

Newsletters

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us.

Cookies

The Website uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services. To learn more about cookies and how to manage them, visit internetcookies.org

In addition to using cookies and related technologies as described above, we also may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These companies may deliver ads that might also place cookies and otherwise track user behavior.

Manage your cookie preferences:


Alexa metrics:

Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Our Website does not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

Advertisements

We may display online advertisements and we may share aggregated and non-identifying information about our customers that we collect through the registration process or through online surveys and promotions with certain advertisers. We do not share personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.

Affiliates

We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Privacy Policy.

Links to other websites

Our Website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third-parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information.


miniOrage two factor authentication

(applicable to Simple Flying journalists, editors and admin staff with site access):

miniOrange(“Us,” “We,” “Our,” “miniOrange,” or the “Company”) is committed to protecting the privacy of your information while you use our WordPress miniOrange Two Factor Plugin. We’ve crafted the policy below to help you understand how our plugin collects and uses personally identifiable information.

Definitions:

  • miniOrange Two Factor Plugin: This refers to Google Authenticator – Two Factor Authentication (2FA) WordPress plugin.Customer Support Services: It involves screen sharing sessions, meetings and support by mail.
    miniOrange Servers: This refers to miniOrange service which is stored on secure cloud service AWS. miniOrange Users data is also stored with AWS.
  • Third Party: This refers to customer using miniOrange services i.e. plugin to provide Two Factor verification to its users.
  • Personal data: This refers to information provided by you such as name, company name, address, phone number, email address, and any other information necessary.

Introduction:
We protect your personal information using industry ­standard safeguards. We may share your information only with your consent or as required by law as detailed in this policy, and we will always let you know when we make significant changes to this Privacy Policy. Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:

We protect your personal information and will only provide it to third parties: (1) with your consent; (2) where it is necessary to carry out your instructions; (3) as reasonably necessary in order to provide our features and functionality to you; (4) when we reasonably believe it is required by law, subpoena or other legal process; or (5) as necessary to enforce our User Agreement or protect the rights, property, or safety of miniOrange, its Customers and Users, and the public.

What Personal Data do we collect?
miniOrange collects data provided by you while registering with miniOrange or through any other service while contacting miniOrange. We also collect data needed to provide miniOrange services.

This data may contain different information as listed below:

  • When you register in the plugin, you provide us with information (including your name(optional), email address, phone number(optional), company name/website and password) that we use to offer you a personalized, relevant experience on miniOrange.
  • When User contacts our Customer Support, User’s personal data is shared which is necessary for us to provide support where we can assist you with the plugin configurations, setup or any other issues while using miniorange Two Factor Plugin.
  • The Personal Data you provided is used for purposes like answering questions, improving the content of the website, customizing the content, and communicating with the customers about miniOrange’s Services, including specials and new features.
  • While using miniOrange Risk Based Authentication (RBA) services, device information is collected. The information collected for RBA is mentioned below under data used by the plugin.
  • When you contact us using our support form, we collect information that helps us categorize your question, respond to it, and, if applicable, investigate any breach of our User Agreement or this Privacy Policy.
  • We also use this information to track potential problems and trends and customize our support responses to better serve you.
  • We do not collect email address from miniOrange production service for marketing use.
    In the miniOrange Two Factor plugin, we collect the following information from users :

Customer Details: First name, last name, username, email, Questions and Answers of Security Questions, Phone Number, Company Name.

Device Information: Location, Browser details, IP Address, Device Type, Time, Language, Useragent details, Device fingerprint.

miniOrange only uses your data in order to provide you with the service and keeps this data available only to the user that has provided the information or the third parties that the user has agreed to grant access to.The data is also provided to respective Authenticator Application owner which is required for verification during login.

How we use personal information?
miniOrange Two factor Plugin has various authentication methods and different methods require different information. Your Phone number and Email are used to send One Time Passcode. Your email is also used as a primary medium of contact only in case you need any help from us. Risk based Authentication uses information like device type, location, Ip address, time and other to identify the user and grant access based on the risk.

All data provided are stored with miniOrange which can be accessed through our site https://login.xecurify.com/moas/login where the user’s account is created while using the miniOrange Two Factor Plugin.

Personal Data Processing Duration:
Personal data will only be processed until we have a legitimate business. When we have no legitimate business, your data is stored securely until deletion. During this period, if you request for data stored with miniOrange, you would have to give sufficient evidence of identity before we can provide you with this information. You can request this by contacting us at info@xecurify.com. Same would apply if you request for deletion of the personal data.

User consent: End Users will be asked for consent if they agree to the terms and conditions of your website. If they deny consent, they will not be logged in and no data will be fetched.
Encryption: All data that is in transit because of miniOrange is encrypted in the miniOrange Two Factor plugin.

What are your rights:
Right to be forgotten: Information collected in stored in two places – WordPress Database and miniOrange Servers. Customer can delete end-user’s information if end-user requests.
Right to object: In certain situations, end user has the right to object to the data being processed in so far as such data have been collected for direct marketing purposes.
Right to rectification: You have a right for clarification of inaccurate personal data. And change the data by providing complete information.
Right of access: You have the right to obtain from us information concerning i.e. you have the right to request and get access to that personal data.


Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.

Data breach

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.

Legal disclosure

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Information will likely be among the assets transferred.

Changes and amendments

We may update this Privacy Policy from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When changes are made, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Website or Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different than what was stated at the time your Personal Data was collected.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Contacting us

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact form

This document was last updated on March 31, 2020