SAFESKY Data Use Policy

Your use of any user data collected or processed through the SAFESKY Platform, whether directly or indirectly, is

subject to this SAFESKY Data Use Policy ("Policy").

"SAFESKY Platform" means the set of APIs, SDKs, tools, plug-ins, code, technology, content and services made available

by SAFESKY SRL, a registered company in Belgium under number 0761852549, that enables others, including app developers,

content providers and website operators, to develop software or other functionality.

This Policy explains your obligations with respect to the receipt, collection, use and processing of User Data (as

defined below) in connection with any Content you distribute via the SAFESKY Platform.

"Content" includes any application or other technical integration with the SAFESKY Platform you distribute.

To use the SAFESKY Platform, you must agree to this Policy, as well as our other applicable terms and policies made

available to you the “User”.

This Policy is effective as of the date you accept it or otherwise start accessing or using the SAFESKY Platform, and

will continue until you stop accessing and using the SAFESKY Platform, unless terminated earlier as described below.

If you fail to comply with this Policy or any other applicable terms or policies, we may suspend or remove your Content

and limit or terminate your developer access to the SAFESKY Platform, as described below.

1. LICENCE

Use of SafeSky Platform and Content is not allowed, except on the basis of a written Agreement by SafeSky.

Authorization can be granted for free for the purpose of non-profit research, non-profit education, or use in non-profit

private institutions aiming at enhancing airspace security.

Authorization includes reciprocal use of similar data from the User as agreed in the Agreement.

Authorization gives the applicant a limited, non-exclusive, non-transferable, non-assignable, and terminable license to

copy, modify, and use the data in accordance with this Agreement.

This Agreements concerns only data that are owned by SafeSky.

By requesting and receiving authorization you acknowledge that you understand and agree to be bound by the terms and

conditions of this Agreement.

There are no implied licenses in this Agreement. This Agreement shall become effective as of the date of approval by

SafeSky. This Agreement is subject to modification or revocation at any time at SafeSky sole discretion. SafeSky shall

have the right to use any of your feedback received during the license period for its non-profit educational and/or

research purposes.

2. DATA YOU COLLECT FROM END USERS

If you independently collect or process personal data from an end user (whether a person or an entity) through your

Content (including, without limitation, through web-based account creation or inputs from the end user through the

SAFESKY platform), then it is your responsibility, as required by applicable law, to obtain any permissions/consents

from the end user and/or rely on any appropriate legal basis for use or other processing of this personal data (the

"Developer User Data"). It is also your responsibility to obtain consent or clear direction from end users before you

give SAFESKY any Developer User Data.

You must clearly articulate your collection, use and processing of Developer User Data and User Data (defined below) in

a publicly available and easily accessible privacy policy and abide by this privacy policy as required by applicable

law. It is also your responsibility to comply with any and all privacy and data protection laws in all applicable

jurisdictions.

Your privacy policy may not supersede, modify, be less protective than or otherwise be inconsistent with this Policy or

our other applicable terms and policies with respect to User Data. This Policy applies to all User Data, regardless of

the disclosures you include in your privacy policy. For example, you may not sell User Data, even if you disclose your

intention to do so in your privacy policy.

You must retain your privacy policy in effect while using the SAFESKY Platform and maintain a publicly available privacy

policy with current and up-to-date links to your privacy policy in the privacy policy field in your app submission

documentation so that it can be provided to end users of your Content on the applicable product description page.

3. USER DATA YOU OBTAIN FROM SAFESKY

"SAFESKY User Data" is any data, information or content that is about or associated with a person, device or unique

identifier (including anonymised or hashed user IDs) that you obtain from SAFESKY.

4. PERMITTED USES OF USER DATA

You can use User Data solely for the following purposes:

• Running, supporting and maintaining your Content in order to provide the experience to the end user requesting the

Content and from whom the User Data was collected; and

• You must ensure that at all time your Content using User Data has been aggregated and de-identified or anonymised such

that it cannot be re-identified in any way.

5. USE OBLIGATIONS

If you use SAFESKY Platform for publication (including web pages, papers published by a third party, and publicly

available presentations), you must provide SafeSky with a copy of (or a link to) the publication and you must cite the

data as follows:

Use granted by www.SafeSky.app

You will notify SafeSky immediately of all relevant details if:

- confidentiality or privacy is compromised; or

- you receive any legal, investigatory, or other government demand to reverse engineer, decrypt, de-anonymize or

otherwise disclose anonymized or confidential data.

If requested, you will provide SafeSky evidence of compliance with this Agreement, such as a written description of your

data protection plan or a written affirmation that you have disposed of any and all copies of the received data set from

all systems reasonably known to you.

5. PROHIBITED USES OF USER DATA

You will not perform, or facilitate or support others in performing, any of the following prohibited practices

(collectively, "Prohibited Practices”):

• Retaining, using or disclosing User Data for any purposes other than those described in this Policy, the SDK Licence

Agreement and any other applicable agreements with SAFESKY;

• Using User Data for marketing or advertising purposes;

• Selling, licensing, purchasing, renting or lending User Data or similar actions, or permitting a third party to do so;

• Collecting and storing Data for a period that is longer than instant use

• Using User Data to profile, discriminate or encourage discrimination against people based on their race, ethnicity,

colour, national origin, religion, age, sex, sexual orientation, gender identity, family status, disability, medical or

genetic condition or any other categories protected by applicable law, regulation or other SAFESKY terms or policy;

• Using User Data to perform, facilitate or provide tools for surveillance. Surveillance includes the collection, use or

sharing of information about people, groups or events for law enforcement, national security, intelligence or

counter-intelligence purposes. The foregoing doesn't prevent you from responding to a valid court order, if you provide

SAFESKY with written notice and evidence of the court order, unless expressly prohibited by law from doing so;

• Using User Data to ascertain the identity of a natural person, including real name, or actual facial or body images,

to the extent not disclosed by the User Data (for example, through the use of AI, facial recognition or gait-identifying

technologies);

• Combining User Data with any other data, including with data separately collected by you or received from a third

party;

• Attempting to decode, circumvent, re-identify, de-anonymise, unscramble, unencrypt, reverse-hash or reverse-engineer

User Data that is provided to you;

• Using User Data in any manner or for any purpose that infringes, misappropriates or otherwise violates any

intellectual property rights or other rights of any person or that violates any applicable law or regulation; or

• Accessing or collecting User Data or allowing User Data to be collected using automated means such as harvesting bots,

robots, spiders or scrapers.

6. ENFORCEMENT

With or without advance notice to you, we may enforce against your Content if we conclude that you have violated this

Policy or are having a negative impact on the SAFESKY Platform and/or suspend your Content while we investigate

suspected violations of this Policy. We may or may not notify you in advance. You must keep your contact information up

to date and respond to our requests and requests from users to delete User Data.

7. SECURITY

You agree to use no less than industry-standard security measures to protect against unauthorised access, use or

disclosure of User Data and Developer User Data, and to respond to and comply with all end users requests under

applicable law. Without limiting the foregoing, you must delete User Data when a user requests their User Data to be

deleted or no longer has an account (unless the User Data has been obscured or de-identified so that it cannot be

associated with a particular user, browser or device).

8. GENERAL

In accordance with our policies, you will not transfer any of your rights or obligations under this Policy to anyone

else without our prior consent. Transfer can include assignment, acquisition, merger, change of control or other forms

of transfer. Any unpermitted transfer will be considered null and void. For any permitted transfer of Content, you will

obligate the transferee to comply with this Policy and other applicable terms and policies and to resubmit such App and

Content through our App Review process for our review and approval. After any such permitted transfer by you of Content,

you can only access, use, share and retain User Data to the extent permitted by and in compliance with this Policy and

applicable laws and regulations.

You also must comply with all applicable laws and regulations (including, without limitation, the European General Data

Protection Regulation, the ePrivacy Directive and any related EEA countries' requirements, the California Consumer

Privacy Act, the Children's Online Privacy Protection Act and the Video Privacy Protection Act). If there is any

conflict between this Policy and any other applicable online terms, the terms that are more restrictive on you and your

Content or more protective of us apply.

We reserve the right to amend this Policy at any time. Your continued use of or access to SAFESKY Platform or User Data

after any such amendment will constitute your binding agreement to this Policy as amended.

We may change, suspend or discontinue the availability of the SAFESKY Platform at any time. In addition, we may impose

limits on certain features and services or restrict your access to parts or all of the SAFESKY Platform or our other

APIs or websites without notice or liability.

When this Policy has ended, all rights granted to you under this Policy will immediately stop and you will immediately

stop using the User Data. The following Sections will remain in effect after this Policy has ended: Section 4

(Prohibited Uses of User Data), Section 5 (Sharing User Data), Section 7 (Security) and Section 8 (General).

9. APPLICABLE LAW

The Agreements and any dispute or claim arising therefrom or relating to them, their purpose or their formation

(including disputes or non-contractual claims) will be governed by and interpreted in accordance with Belgian law.

Nevertheless, SAFESKY reserves the right to initiate proceedings against any User for violation of these conditions in

the country of residence or any other relevant country.

The accessibility of the Website in any other country cannot have the effect of subjecting the information presented on

the Website to the specific legislation of each country.

Users accessing the Website from a country outside the European Union do so at their own risk and under their own

responsibility.

Version 1.0.0 - 10/04/2021