PanaSky™ Developer Beta Candidate Registration

PRIVACY POLICY

We respect the importance of your personal information. This privacy policy (“Privacy Policy”) applies to your personal information that we collect through or in connection with the operation of the the Site and the Beta Program Partner candidate selection process. We want you to understand our Privacy Policy and, specifically, what information we gather from the Site and otherwise in connection with the Beta Program Partner selection process, how that information is used, with whom we share that information and how we protect it. We’re accountable for the protection of your personal information under our control and are committed to following this Privacy Policy and complying with the law. This Privacy Policy supplements and is part of the Terms of Use (the “Terms”) for the Site and the Beta Program Partner candidate selection process.

In this Privacy Policy, “we,” “us” or “our” means Panasonic Avionics Corporation, a Delaware USA corporation based in California USA and “you” or “your” means a person who accesses or uses the Site or who registers to be considered as a potential Beta Program Partner candidate.

Capitalized terms that are not otherwise defined in this Privacy Policy have the meaning set forth in the Terms.

What Is the Site and Beta Program?

The Site is being used to create awareness of, and invite developers to express interest in being involved with, our planned Beta Program. The Site allows interested developers to register to be considered as a potential Beta Program Partner candidates.

Safe Harbor (for EU Residents).

Consistent with our commitment to protect personal privacy, we declare that we adhere to the Safe Harbor Principles embodied in the Safe Harbor Agreement concerning the transfer of personal data from the European Union (EU) to the United States of America effective November 1, 2000. If you are a EU resident, these Safe Harbor Principles apply.

What Categories Of Information Do We Collect?

The purpose of the Site is to collect certain information to be used in connection with our Beta Program Partner candidate selection process. Examples of the types of information we may collect includes:

  • Personal Information. Personal Information (or PII) is information that you provide to us that identifies you, for example, your name, address, email, telephone number, etc., or that can be used to identify you. In some jursidictions your IP address may be deemed to be PII. Personal Information does not include information that is about you but from which you could not reasonably be identified.
  • Portfolio Information. Portfolio Information is information you provide us with (directly or through a portfolio URL that you provide) regarding apps that you’ve previously developed or worked on or similar types of work experience.
  • Network and Device Information. We may collect information about your device and internet connection and information, such as a session ID token, source and destination addressing information, IP address, MAC address, software you are using and related device and network information.
  • Feedback Information. You may volunteer, or we may ask for, information on your experience using the Site or with the Beta Program Partner candidate selection process. At no time are you obliged to provide such information. Feedback Information includes comments, complaints, requests, suggestions or feedback sent by you to us regarding the Site or the Beta Program Partner candidate selection process.

Persons under 18 Years of Age.

The Site is not directed towards persons under 18 years of age and we do not intentionally or knowingly collect Personal Information from persons under 18 years of age.

How Do We Collect Information?

We may collect information about you in a number of different ways, including:

  • what you provide to us;
  • from communications between you and us;
  • from public sources; and
  • automatically in connection with your use of your device and the Site.

Collection of certain information is essential to the operation of the Site. Except where we are not required to do so under applicable law, we will obtain your consent before we collect other personal information.

How Do We Use This Information?

We may use the following information as described below:

  • Your Personal Information. Your Personal Information is only used to assess and select potential Beta Program Partners and inform you about Beta Program Partner selection, to contact you regarding the Beta Program Partner candidate selection process, to provide updates regarding the Site, the Beta Program, the PanaSky Developer toolkit and the Beta Program Partner candidate selection process, to seek feedback and to enforce the Terms. We may also use your Personal Information for internal purposes, such as auditing, data analysis and research to improve or modify the Site or the Beta Program Partner candidate selection process. You will have the option to unsubscribe from emails not related to the Beta Program Partner candidate selection process.We may disclose your Personal Information if we believe in good faith that we are required to do so by law, or that doing so is necessary to comply with legal process, respond to requests from law enforcement or governmental agencies, respond to claims or to protect our rights.Your Personal Information may be stored and processed in any country in which we or our affiliates, consultants or service providers maintain facilities. We reserve the right to transfer and store your Personal Information outside the country in which you reside. As we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions, as well as in the event we or substantially all of our assets are acquired by a third party, your Personal Information will generally be one of the transferred business assets. We reserve the right to include your Personal Information, collected as assets, in any such transfer to a third party. Additionally, your Personal Information could be disclosed as part of a bankruptcy involving us.When you use the Site, you give us your informed consent to collect, use and disclose your Personal Information in accordance with this Privacy Policy. Except where we are not required to do so under applicable law, we will notify you and obtain your consent before we disclose or use your Personal Information in any other way. EXCEPT AS DESCRIBED IN THIS POLICY, WE WILL NOT OTHERWISE DISCLOSE YOUR PERSONAL INFORMATION TO THIRD PARTIES FOR THEIR INDEPENDENT USE WITHOUT YOUR CONSENT. For EU residents: We don’t anticipate collecting any of your Sensitive Personal Information (Sensitive Personal Information is Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership or that concerns health or sexual activity), but for purposes of this Privacy Policy, we will treat any Sensitive Personal Information that we do collect as required by the Safe Harbor Principles.
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  • Portfolio Information. We use Portfolio Information to assess your work experience and suitability for being a Beta Program Partner candidate. We may share your Portfolio Information with our consultants under a confidentiality obligation. EXCEPT AS DESCRIBED IN THIS POLICY, WE WILL NOT OTHERWISE DISCLOSE YOUR PORTFOLIO INFORMATION TO THIRD PARTIES FOR THEIR INDEPENDENT USE WITHOUT YOUR CONSENT.
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  • Use and Network and Device Information. Use and Network and Device Information is used to provide you with access to the Site, to troubleshoot problems, to improve the Site and for usage, diagnostic and other purposes.
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  • Feedback Information. We may use Feedback Information in any manner and for any purpose without any obligation to account for such use or to compensate you for it. We will not disclose any personally identifiable feedback information to third parties (other than third parties who are involved in providing the Site or Beta Program Partner candidate selection process where such feedback relates to those providers) without your consent.
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  • De-Personalized Information. We may collect information of any type, including Personal Information, anonymize that information, and use it alone or with similar anonymized information obtained from other individuals (“De-Personalized Information”). No personally identifying information will be included in any De-Personalized Information. We may disclose De-Personalized Information to any third party and use it for any purpose we deem appropriate in our sole discretion.
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  • Other Parties’ Ability to Collect Personal Information. We do not authorize any third parties to collect PII about you or your activities over time or across different sites when you use the Site.

Can I obtain a copy of my Personal Information?

At your request, we will provide you with a list of all of your Personal Information that we have. Prior to releasing any such Personal Information, we may take such steps as we deem reasonably necessary to verify your identity. We are not required to release any records that are created and retained as part of the Site that are not Personal Information without a subpoena (unless otherwise required by law).

Can I correct my Personal Information?

If there is any Personal Information of yours that is inaccurate, incomplete or out-of-date that you cannot correct, please contact us at privacy@panasonic.aero with “PanaSky Developer Beta” in the Subject or Re line so that we can correct it.

Can I remove some or all of my Personal Information?

We will remove your Personal Information to the extent you request we do so. However, removal of such Personal Information will result in your removal from the consideration as a potential Beta Program Partner candidate (in effect, it will unregister you).

What Categories Of Third Parties Do We Share Your Personal Information?

The categories of third parties with whom we may share your Personal Information include service providers or consultants that we may use to operate the Site or assist us with Beta Program Partner candidate selection process.

Consent For Electronic Communications.

We use your Personal Information that is contact information to communicate with you regarding the Beta Program Partner candidate selection process, the Site, the Beta Program and the PanaSky Developer toolkit. By providing Personal Information that is contact information, such as name and email address, you consent to receive such communications using such contact information.

What Are Cookies And How Do We Use Them?

Cookies are pieces of information that we transfer to your computer or device through a browser to enable our systems to recognize the browser. Cookies also enable us to gain information about your use of the Site.

The Help option on the toolbar of most browsers will tell you how to prevent or limit the browser from accepting cookies, how to have the browser notify you when you receive a cookie, or how to disable cookies altogether. Cookies we use do not contain any personally identifying information. If you disable cookies, certain features may not operate.

How We Treat “Do Not Track” Or Similar Signals.

Some browsers provide you with “do not track” options. Because there is not yet a common understanding of how to interpret the “do not track” signal, we do not currently respond to the browser “do not track” signals when you use the Site.

How Your Personal Information Is Protected.

We take physical, organizational and technical measures to protect the Personal Information you provide to us. We cannot guarantee the absolute security of our database, nor can we guarantee that any information supplied will not be intercepted while being transmitted over the Internet.

How Long Is Personal Information Kept?

We will retain your Personal Information for as long as is necessary to: (1) to complete the Beta Program Partner candidate selection process; (2) maintain records until they cannot be lawfully challenged and legal proceedings may no longer be pursued or as needed to operate the business; (3) carry out marketing activities; (4) comply with applicable law, regulatory requests and relevant orders from government authorities; and (5) enforce, or fulfill any of the other purposes detailed in, the Terms.

For California residents: Your California Privacy Rights.

California Civil Code Section 1798 entitles California customers to request information concerning whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. As stated in this Privacy Policy, we will not sell or share your Personal Information with non-affiliated companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How Can We Be Contacted” section below.

Can This Privacy Policy Be Modified?

We reserve the right to modify this Privacy Policy at any time. Use of the Site after we have published a modified Privacy Policy on the Site constitutes acceptance of such modified Privacy Policy.

How We Notify You Of Modifications.

We will publish the modified Privacy Policy on the Site. The modified Privacy Policy becomes effective upon publishing. If the modifications are material, we will provide more prominent notice as appropriate under the circumstances (for example, for a period of time following publication the icon or link to the Privacy Policy may be highlighted or include the word such as “modified,” “revised,” “updated” or similar).

How Can We Be Contacted?

By mail at: Panasonic Avionics Corporation, Attn: Legal Department-Privacy (PanaSky Developer Beta), 26200 Enterprise Way, Lake Forest, CA 92630 USA; or by email at:privacy@panasonic.aero with “PanaSky Developer Beta” in the Subject or Re line.

Last revised: 29 August 2014. © 2014 Panasonic Avionics Corporation. All rights reserved.

Safe Harbor for EU Residents

Consistent with our commitment to protect personal privacy, we declare that we adhere to the Safe Harbor Principles embodied in the Safe Harbor Agreement concerning the transfer of personal data from the European Union (EU) to the United States of America effective November 1, 2000. The U.S. Department of Commerce and the European Commission have agreed on the Safe Harbor Principles and related materials to enable U.S. companies to satisfy EU legal requirements for adequate protection of Personal Information transferred from the EU to the United States (www.export.gov/safeharbor/). The provisions of this Safe Harbor section apply to EU residents. If there is a conflict between the other provisions of this Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles will govern.

SAFE HARBOR PRIVACY PRINCIPLES

The usage of Personal Information conforms to the following Safe Harbor Privacy Principles as stated below under the heading of each principle.

Notice and Choice

To the extent permitted by the Safe Harbor Principles, we reserve the right to process Personal Information in the course of providing the Site to you without the knowledge of the entities or individuals involved. If and when we collect Personal Information directly from individuals residing in the EU, we will inform them about the types of Personal Information we collect from them, the purposes for which we collect and use it and the types of non-agent third parties to which we disclose that information. We will also inform those individuals about the choices and means, if any, that we offer to limit the use or disclosure of their information.

Where we receive Personal Information from our subsidiaries, affiliates or other entities in the EU, we will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.

To the extent permitted by law, we will offer individuals the opportunity to choose (opt-out) whether their Personal Information is: (a) to be disclosed to a non-agent third party; or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For Sensitive Personal Information, we will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

We will provide individuals with reasonable mechanisms to exercise their choices.

Disclosures and Onward Transfers

We have identified a privacy administrator who is responsible for training employees regarding the appropriate use of Personal Information and conducting regular self-assessment reviews to ensure full compliance with the Safe Harbor Principles. We will not disclose an individual’s Personal Information to third parties, except when one or more of the following conditions is true:

  • we have the individual’s permission to make the disclosure;
  • he disclosure is required by statute, government regulation or case law that creates explicit authorizations, provided that, in exercising any such authorization, we can demonstrate that its non-compliance with the Principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization;
  • the disclosure is required to meet national security, public interest, or law enforcement requirements;
  • the disclosure is reasonably related to the sale or disposition of all or part of our business;
  • the information in question is publicly available;
  • the disclosure is reasonably necessary for the establishment or defense of legal claims; or
  • the disclosure is to one of our related entities or to persons or entities providing Sites on our or the individual’s behalf (each, a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
    • is subject to laws providing an adequate level of privacy protection;
    • has agreed in writing to provide an adequate level of privacy protection; or
    • subscribes to the Safe Harbor Principles.

Permitted transfers of information, whether to third parties or within our organization, include the transfer of data from one jurisdiction to another, including transfers to and from the United States.

Data Security

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use and confidentiality of information, either for our own purposes or on behalf of our clients, customers and business partners, we have put in place and enforce appropriate physical, electronic, and administrative procedures to safeguard and secure the information that we process. However, we cannot guarantee the security of information on, or transmitted via, the Internet.

Data Integrity

We process Personal Information only in ways that are compatible with the purpose(s) for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that Personal Information is accurate, complete, current and otherwise reliable for its intended use.

Access and Correction

Upon request, individuals will be permitted to access any Personal Information we receive within a reasonable time period except in the circumstances as described below. If an individual becomes aware that Personal Information we maintain about that individual is inaccurate, or if an individual would like to update or review that individual’s Personal Information, the individual may contact us using the contact information in the Privacy Policy. In every case, we will take reasonable steps to permit individuals to correct, amend, or delete Personal Information that is demonstrated to be inaccurate. The individual seeking to access or amend such Personal Information will need to provide sufficient identifying information, such as name, address, billing statement, account name, email address or other identifiers. We may request additional identifying information as a security precaution, including seeking assistance from a partner service provider to confirm an individual’s identity.

We may limit or deny access to Personal Information where the burden and expense of providing such access would be disproportionate to the risks to the individual’s privacy in the case in question, where the legitimate rights of persons other than the individual would be violated, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to Personal Information.

Enforcement and Dispute Resolution

We utilize a self-assessment approach to verify our compliance with this Privacy Policy. We periodically verify that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, accessible and in conformity with the Safe Harbor Principles. We retain a signed statement verifying our self-assessment and it will be made available upon request by individuals in the context of an investigation or complaint about non-compliance with this Privacy Policy.

We encourage interested persons to first raise any concerns about our implementation of this Privacy Policy using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.

Any claim arising out of or relating to our adherence to the Safe Harbor Principles, or the breach thereof, that cannot be resolved through our internal processes, will be settled by arbitration administered by the American Arbitration Association (“AAA”) in accordance with its applicable commercial rules. Any arbitrator will be either an attorney or retired judge having significant and recognized experience with, and knowledge of, privacy issues and information technology. The arbitration panel will apply California law, without regard to its conflict of laws principles, as well as the Safe Harbor Enforcement Principles issued by the U.S. Department of Commerce. In addition, the exclusive location for such arbitration will be Orange County, California. All decisions of the arbitration panel will be final and binding on the parties, which waive any right to appeal the arbitration award further, to the extent an appeal may be lawfully waived. We are also subject to the jurisdiction of the U.S. Federal Trade Commission and other U.S. and foreign government agencies.

Changes

We may change this Privacy Policy from time to time, consistent with the requirements of the Safe Harbor Principles or the United States Department of Commerce. We will post any revised privacy policy in our relevant work places, train relevant employees about such changes and how to comply with them, and will publish any amended privacy policy on the Site.

Information Subject To Other Policies Or Standards

We are committed to following the Safe Harbor Principles for all Personal Information within the scope of the Safe Harbor Agreement. Certain Personal Information, however, is subject to our policies that may differ in some respects from the provisions of this Privacy Policy. Personal Information subject to such additional policies includes Personal Information obtained from or relating to service provider, customer or business partner that is subject to the terms of any privacy notice or agreement with such customer or business partner, as well as any applicable laws.

Last revised: 29 August 2014. © 2016 Panasonic Avionics Corporation. All rights reserved.