RebelRoam OÜ (“RebelRoam”) is committed to protecting the privacy of all individuals who register to use its mobile application enabling in-flight access to messaging services (“Flightful App”). This Privacy Notice describes RebelRoam’s privacy practices in relation to the use of the Flightful App.

The Flightful App may contain links to other websites. The information practices or the content of such other websites is governed by the privacy notices of such other websites.

Our contact details:

Company: RebelRoam OÜ, registry code 12933932, established in Republic of Estonia

Address: Erika 14, 10416, Tallinn, Estonia

 

  1. What personal data we collect

RebelRoam collects personal data from individuals who register to use the Flightful App. Depending on your use of the Flightful App, that may include:

  • email address, mobile phone number and password in course of registering to use the Flightful App;
  • content and details of your communication with RebelRoam in relation to using the Flightful App (for example, when you ask for support, send us questions or comments or report a problem);
  • Log of your DNS queries, including which messaging services you used and when such services were used;
  • your Flightful App settings;
  • Your flight number.

RebelRoam will not store and is not able to access any of your messages content and other communication transmitted via the messaging services. To clarify, these messages are encrypted and there are no technical means to access such content. We only process the DNS queries (which contain information about the service with which you request to connect with) in order to ensure that the Flightful App would only be used to access the permitted messaging services.

 

  1. For what purposes is your personal data processed

We will use the personal information you provide to:r

  • identify you when you sign into your account;
  • provide you with the Flightful App;
  • administer your account;
  • contact you regarding any questions you submit through the Flightful App;
  • analyse the use of the Flightful App and the people visiting to improve our content and Flightful App;
  • send you marketing communications we think you may find useful, if you have given us your prior consent;
  • use the information for other purposes that you explicitly consent to prior to using the information for such purposes.

 

  1. Legal basis

The lawful basis we rely on for processing your personal information are:

  • contractual obligation to process personal data on registration and using the Flightful App;
  • legal obligation to process personal data arising out of law;
  • your prior consent in order to provide you promotional material. You may revoke your consent at any time by contacting [Insert e-mail] or unsubscribing from our promotional e-mails.

 

  1. Recipients with whom personal data may be shared

Any data you provide will not be publicly displayed or revealed to other users. Certain RebelRoam employees may have limited access to personal data indicated in Section 1 to the extent necessary for the performance of their work duties.

We don’t provide your personal information to any third-parties, except when it’s necessary to provide our Flightful App or to fulfil our terms of service. When we share data with third-party service providers that support our delivery of the Flightful App, we require that they protect your personal information to the same standards as we do.

We use two-step SMS verification with Google Firebase to sign up for an account. User information (mobile number) is stored on Google servers.

We do reserve the right to disclose personal information when we believe that doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or other illegal behavior or to protect RebelRoam’s legal rights.

 

  1. Security and access to personal data

RebelRoam takes precautions, including administrative, technical, and physical measures to help safeguard personal data against loss, theft and misuse as well as against unauthorized access, disclosure, alteration, and destruction of personal data.

We use secure servers to protect your personal information and ensure that all data that is transmitted between you and the messaging service providers remains encrypted.

You are solely responsible for protecting your passwords, restricting access of your mobile device to other individuals and signing out of the Flightful App after sessions.

If a personal data breach occurs and such violation may pose a high risk to your privacy, RebelRoam will inform you and relevant authorities of the breach at the earliest opportunity.

 

  1. Data retention

The personal data is stored in servers in the European Union, except for the data that is stored by Google Firebase. You can get more information about the privacy practices of Google Firebase from https://firebase.google.com/support/privacy.

DNS query logs are retained for 6 months.

Other personal data shall be retained until you delete your Flightful account or until there is a valid legal basis for processing personal data. If there is no such legal basis, personal data will be deleted securely or will be anonymised so it will no longer constitute personal data. Anonymised data may be used for statistical and analytical purposes.

You can delete your account at any time. In such case, all data created within your account will be deleted.

In the event of a dispute, the personal data will be retained until an agreement is reached or until the due date for the claim expires.

 

  1. Your data protection rights

Your rights concerning your personal data we process include:

Right of access – you have the right to ask us access to or copies of your personal data.

Your right to rectification – you have the right to ask us to rectify data that is inaccurate. You also have the right to ask us to complete data that is incomplete.

Right to erasure – you have the right to ask us to erase your personal data, unless there is a need to retain certain data for a further period of time in accordance with applicable laws or this privacy policy.

Right to restriction of processing – you have the right to ask us to restrict the processing of your personal data in certain circumstances.

Right to data portability – you have the right to ask that we transfer the personal data you gave us to another organisation or to you in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. If the requests are unfounded or excessive, we may charge a reasonable fee or refuse to act.

Please contact us at [Insert e-mail], if you wish to make a request.

 

  1. Direct marketing

We shall ask for your prior consent in order to send you marketing emails. If, after providing the consent, you no longer want to receive such emails, you may revoke your consent at any time by contacting [Insert e-mail] or clicking “Unsubscribe” at the end of marketing e-mails. Even if you do not consent to marketing emails, we may still send you service-related emails which could include information about your account and technical matters.

 

  1. Miscellaneous

RebelRoam reserves the right to change this Privacy Notice. RebelRoam will provide notification of the material changes to this Privacy Notice through the Flightful App and/or by informing you via e-mail.

People under 14 are not permitted to use the Flightful App. People between ages 15-18 are only allowed to use the Flightful App with a prior consent of their parent or guardian.

If you have a complaint or concern about how we use your personal data, please contact us at [Insert e-mail] and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.