Privacy Policy
Welcome to our Privacy Policy page.
FLAPPER TECNOLOGIA S.A. (“Flapper” or “Us”), enrolled on CNPJ/MF (Corporate Taxpayer Identification Number) under no. 27.028.507/0001-00, as responsible for the processing of personal data, values privacy and is concerned about the rights of data holders, acting in compliance with the provisions of the Law No. 13.709/2018 (General Data Protection Law or “LGPD”) and other applicable law.
We value your trust and follow the best practices of the department in order to protect your personal information. Our Policy explains how we (1), collect, (2) use and (3) disclosure your personal data as a result of the access and use of services available by Flapper through an accessible website https://www.flyflapper.com/ and on the app “Flapper –Mobilidade Aérea” (Air Mobility), available on Google Play and App Store (“Platform”). The information you share with us help us to provide a personalized experience by using the Platform.
Flapper recommends the carefully reading of this Privacy Policy and its respective updates (“Policy”). In case of changing the Privacy Policy, the date of the last update, available at the top of this page, is also updated.
In this Policy, any individual that uses our Platform (“User” or “You”) may check how your personal data are processed when inserted on the Platform to (i) subscribe in our newsletter, (ii) send contact email, (iii) register in our Platform, (iv) use services available on the Platform, including the intermediation of aircraft charters, offers of flights and empty leg, (“Services”).
This Privacy Policy only contemplates the processing of personal data performed by Flapper resulting from the use of the Platform and it is incorporated in our Service Terms, available on https://www.flyflapper.com/termos-de-servico/.
The terms “Flapper”, “Service”, “us” include Flapper and our subsidiaries. All terms which are not defined on this document will have their meaning established on the Service Terms. “Personal Data” means any information used to identify, get in touch or locate you easily, and include some of the following items: name, address, email address or telephone number. We clarify that personal data which were anonymized are no longer considered personal data, under the applicable legislation.
See the content of our Policy below:
(1) CONSENT AND ACCEPTANCE ABOUT DATA PROCESSING
(2) INFORMATION THAT YOU SHARE WITH FLAPPER
(3) DOES FLAPPER USE COOKIES?
(4) HOW DO WE USE YOUR PERSONAL DATA?
(5) DISCLOSURE OF PERSONAL DATA
(6) SAFETY OF YOUR INFORMATION
(7) PRIVACY OF CHILDREN AND ADOLESCENTS
(8) INTERNATIONAL USERS
(9) INTERNATIONAL TRANSFER OF PERSONAL DATA
(10) RIGHTS OF DATA HOLDERS
(11) WHICH IS THE MAINTENANCE TERM OF PERSONAL DATA?
(12) INFORMATION UPDATE, ACCOUNT TERMINATION AND CONTACT WITH FLAPPER
(13) APPLICATION OF THE PRIVACY POLICY
(14) UPDATE OF THIS PRIVACY POLICY
(15) APPLICABLE LEGISLATION
If there is any doubt or if you need more information related to personal data processing or if you intend to exercise some of your rights as data holder, please contact us through the following channels:
(i) Email: support@flapper.aero
(ii) Written communication: Rua Sergipe, nº 1440, sala 700, Savassi, Belo Horizonte – MG, CEP 30130-174
(1) CONSENT AND ACCEPTANCE ABOUT DATA PROCESSING
By registering on the Platform and clicking on the link “I agree to Privacy Policy”, the User expressly and unrestrainedly states being in compliance with this Privacy Policy, stating, for all purposes, that he/she is over 18 (eighteen) years old, legally able and responsible for all acts he/she practices and the data provided on the Platform.
We clarify that LGPD states different legal foundations to process personal data. The so-called “legal foundations” provided by law would be the fundamentals, justifications, hypothesis in order to make the stated personal data processing legitimate, allowed.
The consent of the data holder is not the only legal foundation to process personal data. That means Flapper may only proceed to the personal data processing, even without the User’s consent, if there is a legal foundation provided by law that authorizes such processing, for instance, to comply with legal orders.
(2) INFORMATION THAT YOU SHARE WITH FLAPPER
A Personal Data is any information related to an identified or identifiable natural person. The natural persons whose data referred to are the Personal Data holders.
We collect your Personal Data when you: (a) create your account on Flapper; (b) use our Services; and (c) communicate with us. We also collect information, such as anonymous usage statistics, using cookies, server logs and other related technologies while you are using the Service.
Collecting your personal data. In order to use the Service or request a quote on the Platform, you must create an account with Flapper. In order to register, you may need to provide Personal Data, such as your name, CPF (Individual Taxpayer Identification Number) number, email address or telephone number. In order to book a flight, you must also provide the following information, yours and from other passengers: full name, email address, personal identification number, cell phone number and credit card details (for online payments). If you register by our app, the Firebase Cloud Messaging (FCM) Token will also be collected to send notifications, for authentication purposes in our system.
Making payments. By paying for the Service, you provide information to our third-party service providers. That includes the number of your credit card, expiration date and security number, besides the address, full name and personal identity number. The collected data may be stored to make future transactions.
Client support. We may collect personal data through your communication with our client support team.
Access to the Platform. By accessing the Platform, the following data may be collected: (i) date and time of access; IP (Internet Protocol) address; (iii) origin of access; (iv) browser data (name and version of the browser, manufacturer and language); (v) data from the access device (type of device – desktop, cell phone, tablet -, operational system and version, display resolution and language); and (vi) geolocation data (latitude, longitude, City, State). Such data will be stored by Flapper for a period not less than 6 (six) months.
It is a User’s responsibility to keep his/her personal information updated. Every time there is a change on your data, such fact must be immediately changed by the User through the Platform. Flapper is not responsible for the veracity of data provided by the User, who is the only responsible for the information accuracy.
Flapper provides a contact channel in its Platform, allowing the User to get in touch in order to send or ask for information through texts, upon information of name, email address and telephone.
The User agrees he/she is the only person responsible for all messages transmitted by this means. Flapper will not consider such messages as confidential or secretive, but, in any case, this Privacy Policy is also applicable to them.
By using the Service, you are authorized to collect, analyze and contain the data related to the Service provision.
(3) DOES FLAPPER USE COOKIES?
“Cookies” are small files put on the visitors’ browsers in order to store their preferences. Cookies itself do not identify the individual User, only the device used, and they are not used to collect personal data.
Flapper collects and stores information automatically generated as you use the Service, including your preferences and anonymous usage statistics. When you visit the website or an app, along with our third-party service providers, we receive and register information on our records from the server, including your IP address, cookies, location and related items.
By accessing the Platform, the User authorizes the usage of cookies and similar technologies, as pixels and tags, in accordance with this Policy. If he/she does not agree with this type of usage, he/she must adjust the settings of his/her browser in order to not authorize its use. Disable the cookies used can make the Platform less functional, but cannot block its browsing.
Type of cookies used:
The type of cookies Flapper uses are Session Cookies, which are temporary cookies and will remain on the cookies file in the browser until the User leaves the website. The information obtained by these cookies are used to analyse traffic standards on the web, allowing the identification of problems and the provision of a better browsing experience.
Flapper still uses Google Analytics and Google Tag Manager in order to measure the interaction of the users with the Platform content, and the Firebase Crashlytics, in order to monitor, prioritize and correct possible problems of the Platform.
(4) HOW DO WE USE YOUR PERSONAL DATA?
Data processing is an operation or a set of operations made with personal data through manual or automated means, including the collection, storage, usage, copy and transference, among others.
The person in charge for the personal data collection and processing for the purposes below is Flapper. If there is any doubt about how is the procedure of personal data processing, if you want some clarification about this document or if you want to exercise some of the rights mentioned on this document, you must get in touch by email or physical notification to our address, both informed on item 12 below.
The User accepts, in an express and unequivocal way, that the data provided by him/her may be processed by Flapper whose main purpose by collecting personal information is providing the User a safe, peaceful and efficient experience. In order to do that, personal data may be processed for the following purposes:
We use your personal data in order to improve our services and to communicate with you. We may also use this information (i) to remarketing purposes, (ii) to comply with legal obligations, including court orders, (iii) to process orders, requests or any requirements that may be made by the User through any means of contact available by Flapper; (iv) to help you with information on the newsletter, disclosed services as well as the provision on services provided by Flapper.
Internal use and related to the service. We use information, including Personal Data, for internal purposes related to the Service, and we may provide them to third-parties in order to allow us to provide the Service (chat, payments, etc.). We may use and retain data we collected in order to provide and improve our services.
Communications. We may send emails to the email address that you provided us for transactional informative and operational purposes. We may also send personalized notifications to your phone app, provided that you have activated the notification by push resource in your smartphone. Your communication channels will also be used so we can warn you about maintenances or updates on the Platform or on the Privacy Policy.
Remarketing. We may use information, including your Personal Data, to share offers we perceive as relevant to you. Currently, we use Facebook Ads, Google Ads and LinkedIn Ads as redirection tools.
Integrated Data. We can anonymize and integrate all data collected by the Service and analyse them in group level. These data may be used to analyse trends, researches or to create demographic profiles, as well as to analyse users’ behavior in general and other important measures to make Flapper able to provide a quality service.
(5) DISCLOSURE OF PERSONAL DATA
We may share your information with the following entities: (a) Outsourced service providers; (b) Regulatory entities; (c) Courts and other public agencies.
We use Suppliers and Service Providers. We can share any information we receive with suppliers and service providers retained in connection with the Service provision. We will share Personal Data, including your name and ID, with air carriers and national aviation authorities.
The access to collected information is restricted to employees and persons authorized and involved on the service provision. Employees and/or persons authorized that use this information improperly will violate our Privacy Policy and will be subject to the penalties provided in our disciplinary process, without excluding other applicable legal measures.
Marketing. We do not rent, sell or share your Personal Data to other persons or not affiliated companies for direct marketing purposes, except if we have your permission. We can allow the access to other data collected by the Service to facilitate the transference of information that may be useful, relevant, valuable or interesting to you in other way.
As Required by Law. We can share your Personal Data with agencies, authorities and other entities from the public power in order to comply with the applicable legislation and regulation to the services offered by Flapper.
Compliance with legal obligation. We can share your Personal Data with agencies, authorities and other entities from the public power, as well as with natural persons and private legal entities, in compliance with legal obligation or court order.
Defense of interests. We can share your Personal Data for defense of interests and rights of Flapper or third-parties, including in legal and administrative proceedings, as well as with police authority or members of the Public Prosecutor’s Office, even if there is not a specific legal obligation or court order, in order to protect rights, properties or safety of Flapper, its clients, employees, other Users or third-parties.
Consolidations, Sales or other Transfer of Assets. If we are involved on a consolidation, acquisition, financial audit, reorganization, bankruptcy, judicial liquidation, sales of assets of the company or service transition to other provider, your information may be shared as a part of a transition, as required by law and/or contract. We cannot control how these entities may use or disclosure this information.
(6) SAFETY OF YOUR INFORMATION
We adopt the best technical and organizational practices and measures in order to protect your personal data against destruction, loss, change, disclosure, non-authorized access and any type of unappropriated or illicit processing, as well as to ensure that your information is safely stored, in accordance with privacy laws.
As any company acting on the internet, we are prone to cyber attacks and we cannot ensure the safety of any information that you gave us. We do not assume responsibility by unintentional disclosure.
If you have any concern or suspicion that your personal data are in risk, please contact us immediately.
Flapper advises that the User, when accessing the Internet, should always look for the privacy policy of the website he/she is browsing. Check if the page is safe and do not pass your data to third parties.
When using the service or providing us information and Personal Data, you agree that we can communicate electronically with you regarding safety, privacy and administrative matters related to your use of the Service. If we know about the violation on a safety system, we can try to notify you electronically, publishing a warning on the Service or sending an email to you. You can have the legal right to receive this warning by writing. To receive a free written warning of a safety violation (or remove your consent to receive an electronic warning), please contact us through the following channels:
(i) Email: support@flapper.aero
(ii) Written communication: Rua Sergipe, nº 1440, sala 700, Savassi, Belo Horizonte – MG, CEP 30130-174
(7) PRIVACY OF CHILDREN AND ADOLESCENTS
Flapper Platform is not destined to use to persons under 18 (eighteen) years. We do not intentionally collect, keep or use Personal Data from persons under 18 (eighteen) years and there is no part of the Service or Marketing directed to persons under 18 (eighteen) years. We will take measures to exclude them if we find out we have that information. If you found out that your son or daughter has provided Personal Data without your consent, you can warn us by getting in touch through the following channels:
(i) Email: support@flapper.aero
(ii) Written communication: Rua Sergipe, nº 1440, sala 700, Savassi, Belo Horizonte – MG, CEP 30130-174
(8) INTERNATIONAL USERS
Your data are managed by the company based in the Federative Republic of Brazil. By choosing to use the Service or provide information to us, you agree that any dispute on privacy or terms contained in this Privacy Policy is regulated by the Federative Republic of Brazil laws and the adjudication of any disputes arising from Flapper or Service will be in compliance with the Service Terms.
If you come from other countries than the Federative Republic of Brazil or regions with different laws that regulate the collection and use of data, observe that, when you use our Services, you agree with transferring your information to the Federative Republic of Brazil.
(9) INTERNATIONAL TRANSFER OF PERSONAL DATA
Flapper is not directly involved on international transfer of information and Personal Data between different subsidiaries. However, personal data may be transferred abroad when stored by Flapper in cloud computing servers located outside Brazil. For such purpose, Flapper observes and adopts the best safety and privacy practices to ensure the protection of personal data, as well as it is attentive to the current local legislation about the subject.
In order to ensure the protection of data holders, if the international transfer occurs, Flapper is compromised to guarantee it will observe the applicable legal provisions, namely regarding the determination of suitability of such country in relation to the data protection and applicable requirements to such transfers.
(10) RIGHTS OF DATA HOLDERS
Under applicable legislation on personal data protection, Flapper ensures to the data holder the right over access, rectification, termination, portability and objection on your personal data, upon written request addressed to Flapper. The request may be done through an email or physical notification to our address, informed on the item 12 below.
When the access right of the data holder harms fundamental rights and legitimate interests of natural persons, it will be limited.
The provision of copies requested by the data holder may cause administrative expenses.
(11) WHICH IS THE MAINTENANCE TERM OF PERSONAL DATA?
Flapper stores and preserves personal data during the necessary period to fulfill with the purposes provided on this Privacy Policy or during the period required by legal standards and applicable legislation.
If you want, you may require to Flapper, via email or physical notification to our address, informed on the item 12 below, that information collected is excluded from your database.
In compliance with the applicable legislation or court order, Flapper may keep determined data stored for a period not less than 06 (six) months after its exclusion period. Referred data will not be anonymized or destroyed by Flapper before the conclusion of this term.
Flapper is reserved to the right of analysing the requirement and, observing the legal term of mandatory custody, will provide the elimination or anonymization of data, in its sole discretion.
(12) INFORMATION UPDATE, ACCOUNT TERMINATION AND CONTACT WITH FLAPPER
If you want to update or correct the information provided by you through the use of the Service or other way, or if you have any doubt or suggestion to improve our Privacy Policy, or even if you need some extra information regarding personal data processing, if you want to cancel your account registered on the Platform or if you intend to exercise your rights as data holder, including termination and objection, please contact us through the following channels:
(i) Email: support@flapper.aero
(ii) Written communication: Rua Sergipe, nº 1440, sala 700, Savassi, Belo Horizonte – MG, CEP 30130-174
The answers to the requests will be provided, as a rule, in a maximum period of 15 (fifteen) days, except if it is a especially complex request or multiple requests. We kindly request that, when you write to us, please put on the subject field “Notification about the use of personal data.”
We clarify that, eventually, before we answer to a request, we may ask you some information, in order to confirm your identity.
(13) APPLICATION OF THE PRIVACY POLICY
This Privacy Policy is applicable to all means of access to the Platform, whether by computers or mobile devices.
The terms of this Privacy Policy are not applicable to the services provided by other platforms or third-party websites even if, eventually, a link to access other platforms or websites is available on the Platform.
However, Flapper recommends a careful analysis, by the User, of the privacy policy from other websites, since the content of this Privacy Policy is not applicable to them. The access to platforms or websites which are not owned by Flapper will be done voluntarily and at the User’s sole risk.
(14) UPDATE OF THIS PRIVACY POLICY
In order to always improve our services and our relationship with third-parties, this Policy may be updated by Flapper, at any time, aiming its refinement. The amended Privacy Policy shall come into force as of its publishing on the Platform.
Flapper will notify the User on potential material updates on this Privacy Policy through electronic address provided by the User and will make available the last version of the Privacy Policy on the Platform, with the date of its last update.
The User will stay associated to any amendment to the Privacy Policy, after its publishing, if he/she keeps using the Platform, the Services provided by Flapper through the Platform and does not show interest in disassociate himself/herself.
The User is compromised to often consult the Privacy Policy available on the Platform in order to be updated about the terms and conditions.
In case of conflict between this Privacy Policy and occasional adjustments, the last ones must prevail.
(15) APPLICABLE LEGISLATION
This Privacy Policy shall be governed and construed in compliance with the laws of the Federative Republic of Brazil and any dispute arising out of this Policy shall be submitted to the jurisdiction of the Judicial District of Belo Horizonte, State of Minas Gerais.