Effective Date: 23 Dec 2023
Version: 4.0

1. Introduction

In this policy, we explain how Flybits (Flybits Inc.) and its subsidiaries handle any personal data that we obtain through our website www.flybits.com or when you contact us by mail, phone or other electronic means. We will follow the law when you share personal data with us.

When you continue to browse our website, such as reading the content, clicking on a link or contact us by mail or phone, you consent to us using your personal data in the way that we describe here. This also includes our use of cookies as explained below.

Flybits offers a platform used by businesses to create personalized and relevant digital experiences for their consumers.

2. Information you provide to us

We collect the following information when you use our websites or contact us:

  • When you browse the website or contact us with commercial inquiries: we collect general analytics data and any contact and other information you provide to us.
  • When you contact us by mail, phone or through the contact form or chat on our websites: we collect your name, email address or phone number, and any other information you may provide to us.
  • When you contact us about a job opening: we collect any relevant information you provide to us.

We use this information:

  • For our own marketing communication correspondence, including to follow up on leads.
  • To reply to your information request when you contacted us with a question.
  • To keep you in our recruitment database if you contacted us about job openings.
  • To be able to provide our service to our customers, for onboarding, support and billing.

We store:

  • General contact information related to inquiries for up to two (2) years.
  • Recruitment information for up to five (5) years.
  • Marketing information for up to two (2) years.
  • Billing and other information for up to ten (10) years, to meet tax law requirements.

3. Information we obtain about you

Sometimes we obtain your personal data from other parties for general marketing purposes, such as companies that provide us with an overview of publicly available information on people that have submitted a job application. We will use this information in the same way as the information that you provided to us.

We also use HubSpot, Google Analytics, Facebook and Hotjar in the way described below.

4. Legal Basis

We process data from employees of customers on the basis of our and our customer’s legitimate interest to deliver our services in a regular manner.

We process data from visitors of our website and people that contact us, including for job openings, on the basis of our legitimate interest to provide information about our business.

5. Sharing information

We only share your personal data to outside service providers that we use for storing and processing your data. This includes outside service providers that we use for storing and processing your data, for example:

  • Companies that provide chat and other support functionality.
  • Companies that support our recruitment activities.
  • Companies that support us in sending emails and other messages related to our marketing. 

We require these companies to adequately safeguard your personal data and not use your data for any other purpose not authorized by us. 

In the event that (part of) our business is sold to another company, transfer of ownership could include the transfer of your personal data to the buyer if the data directly relates to that (part of the) business.

We will reveal personal data when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Flybits or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property.

Flybits also shall comply with any government or law enforcement entity investigation that provides proper law enforcement warrants and subpoenas. We will not sell or provide your personal data to other third parties allowing them to use your personal data for their own purposes. Flybits also shall comply with any government or law enforcement entity investigation that provides proper law enforcement warrants and subpoenas.

6. Transfer of your Personal Data

You should also be aware that your personal data may be transferred from your home country to other Flybits entities around the world or to our service providers. If you are an EU resident, this could imply that we also transfer data to countries or organizations that do not offer a so-called adequate level of protection for your personal data. When we transfer this data, we will do so only when we have put in place appropriate safeguards to protect your personal data. Please contact us to obtain a copy of the safeguards that we have put in place. Our contact details can be found at the bottom.

7. Security

We take all reasonably necessary steps to protect all information we hold from misuse, loss, unauthorized access, modification or disclosure. All information is kept secure, encrypted at rest and in transit where possible and protected using industry standard measures. No method of transmission over the Internet or method of electronic storage (including via 3rd parties) is 100% secure; therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

8. Information relating to children

Our website and service is aimed at and designed for those 18 years of age and older. We do not knowingly collect personal data from anyone under the age of 16. If the company is made aware that it has received personal data from someone under 16, it will use reasonable efforts to remove that information from its records.

9. Data integrity, purpose limitation

We process information in a way that is compatible with and relevant for the purpose for which it was collected as described above. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

10. Data Security Breach Notification

In the event of a data security breach that may affect the security of your personal data, we are committed to notifying you promptly in compliance with applicable laws and regulations. We will take all necessary steps to mitigate the breach and inform you of the steps you can take to protect your information.

11. Cookies Policy

11.1 Introduction

The Flybits website and online services use cookies to customize the online experience. This is done through small amounts of information being stored in regards to preferences, browsing behaviour and analytical data to ultimately provide a better service for our users. The Flybits website will ask users to consent to the use of non-strictly necessary cookies when one first visits the website.

11.2 About Cookies

Cookies are files made up of letters and numbers stored within the user’s browser in order to retain certain data about said user. The use of cookies allows Flybits to provide a website which is tailored to individual users.

Cookies can either be persistent or session cookies. A persistent cookie will be stored by a web browser and remains valid until the user deletes it, or it reaches its expiry date. A session cookie will expire at the end of the user session, upon the web browser being closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that is stored about the user may be linked to the information stored in and obtained from cookies.

11.3 Cookies Flybits Uses

Flybits could generate the following cookies:

  • Anonymous analytics cookies: We use these to analyze the use and performance of our website and services.
  • Geo-targeting cookies: This allows us to customize the content you see based on your location.
  • Registration cookies: These allow us to recognize users if they have previously filled out one of our forms, or signed in.
  • Third party advertising network cookies: We may use these to show ad banners including future updates or notifications

The main sources of cookies we use originate from Google Analytics, HubSpot, YouTube, LinkedIn (Insight Tag) and WordPress.

11.4 Disabling Cookies

Cookies allow for a more personalized user experience while on the Flybits website, however they are not necessary and can be disabled even after having accepted them. Acceptance can be revoked from the privacy section within the user’s browser preferences.

11.5 More Information

To view all cookies currently being used on our site, please refer to Cookie settings in the Manage consent tab on our website1

12. International Data Transfer

Your personal data may be transferred from your home country to other Flybits entities around the world or to our service providers. When we transfer this data, we will do so only when we have put in place appropriate safeguards to protect your personal data. Please contact us to obtain a copy of the safeguards that we have put in place.

13. Your rights

You have the right to request from us access to your personal data that we process. You also have the right to:

  • Rectify incorrect personal data or erase it in certain circumstances.
  • Restrict or object to the processing of your personal data.
  • Receive your data so that you can use it elsewhere (data portability).

You also have the right to withdraw your consent at any time, where our processing is based on your consent. Please be aware that a withdrawal of your consent does not affect the lawfulness of the processing of your data before the date on which you withdrew your consent.

Finally, you have the right to lodge a complaint with a supervisory authority. If you do not know who your supervisory authority is, please contact us and we will tell you.

14. Third-Party Services and Links

Our website and services may contain links to third-party websites or integrate with third-party services, such as social media platforms. Please note that this Privacy Policy applies solely to data collected by Flybits. We encourage you to review the privacy policies of any third-party services you interact with, as they may have different privacy practices and policies.

15. Flybits Data Protection Officer

Flybits has appointed a Data Protection Officer who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address, including with any questions you may have about the processing of your personal data or the use of cookies by us, or to exercise the above rights, at:

Flybits Inc
Attn: Data Protection Officer, 
175 Bloor St E North Tower, 14th Floor,
Toronto, ON M4W 3R8

Email for dataprotectionofficer@flybits.com

16. Changes to the Privacy Policy

We reserve the right to update and modify this Privacy Policy as needed to reflect changes in our practices and applicable laws. Any updates will be posted on our website, and we encourage you to periodically review this policy for any changes. Your continued use of our website and services after such changes constitutes your acceptance of the revised Privacy Policy.