Privacy Policy

Our privacy policy outlines what kind of information we collect from you and how we will use it.

Updated: 10 October 2018


LXNAV d.o.o. (“LXNAV”, “We”, “Us”, “Our Company”) is committed to protecting the privacy of our users.

This Privacy Policy provides our policies and procedures for collecting, using, and disclosing your information. Users can access the LXNAV Connect service (the “Service”, “LXNAV Connect”, "Services") through our websites (connect.lxnav.com, cs.lxnav.com, cs-dev.lxnav.com), applications on Devices, through APIs, and through third-parties. A “Device” is any embedded system or computer used to access the LXNAV Connect service, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device. This Privacy Policy governs your access of the LXNAV Connect, regardless of how you access it, and by using our Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. All of the different forms of data, content, and information described below are collectively referred to as “information.” Any transfer from the user's Device to our Service is referred to as “upload” and any transfer from our Service to the user's Device is referred to as “download”.


THE INFORMATION WE COLLECT AND STORE

We may collect and store the following information when you're using the LXNAV Connect service:


INFORMATION YOU PROVIDE

You may provide us with information in several ways, including by filling in forms on our website or by corresponding with us by phone, email, live chat, enter into a contract for the supply of services, enter a competition, promotion or survey or report problems with our services or devices.

When you register an account by filling out the form or by using a Google, Dropbox, SeeYou Cloud or other third-party platform to perform sign up, we may collect some personal information, such as your name, credit card or other billing information, email address, phone number and home or business postal addresses. You may also ask us to link external services to your account and give us access to your third party services. Some services support only logging in via identifiable information and we need to store this information for you to be able to use the external service via LXNAV Connect service. You may also provide us with your contacts' email addresses when sending files to them. We may also receive Personal Information (for example, your email address) through other users, for example if they have tried to connect with you via our Service.


  • FILES
  • We temporarily collect and store the files you upload, download, or access with the LXNAV Connect service (“Files”). Once we have finished moving or manipulating your Files we automatically and permanently delete them from our servers.

    We will ask you for your consent (the "Consent") to store and process flight logs (“IGC files”) that you upload via our Service. These flights will be used to further improve our Services, Devices and Software. We will remove any Personal Information from such flights.

    You may also give us consent to store additional files that you upload, including without limitation flight Logbook, Device profile, or other Device specific files. These files (depending on the type of consent) can be used to further improve your experience and interactivity with our or third-party services that you link with LXNAV Connect.


  • LOG DATA
  • When you use the Service, we automatically record information from your Device, its software, and your activity using the Service. This may include the Device's Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you search for on our website, locale preferences, identification numbers associated with your Devices, date and time stamps associated with transactions, system configuration information, metadata concerning your Files, and other interactions with the Service.

    Using the Service will generate an activity log listing metadata such as file name, file size, timestamps, user id, request contents and other debugging information. These are retained for quality assurance and troubleshooting purposes. Such logs are regularly purged from the system and retained no longer than a month.


  • COOKIES
  • We also use “cookies” to collect information and improve our Services. A cookie is a small data file that we transfer to your Device. We may use “persistent cookies” to save your registration ID and login password for future logins to the Service. We may use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage and web traffic routing on the Service. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Service.


HOW WE USE PERSONAL INFORMATION

  • PERSONAL INFORMATION
  • In the course of using the Service, we may collect personal information that can be used to contact or identify you (“Personal Information”).

    Personal Information is or may be used:

    (i) to provide and improve our Service,
    (ii) to administer your use of the Service,
    (iii) to better understand your needs and interests,
    (iv) to personalize and improve your experience,
    (v) to provide or offer software updates and product announcements,
    (vi) to communicate and interact with you,
    (vii) to fulfil an obligation under law or contract.

    If you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in any of those communications.


  • ANALYTICS
  • We also collect some information (ourselves or using third party services) using logging and cookies, such as IP address, which can sometimes be correlated with Personal Information. We use this information for the above purposes and to monitor and analyse use of the Service, for the Service's technical administration, to increase our Service's functionality and user-friendliness, and to verify users have the authorization needed for the Service to process their requests. As of the last modified date of this policy, we use Google Analytics using Personal Information anonymization.


DATA ACCESS SCOPES

  • GOOGLE SIGN-IN
  • profile - View your basic profile info
    email - View your email address
    openid - Authenticate using OpenID Connect

    LXNAV Connect uses these scopes to authenticate you on our website.


  • GOOGLE DRIVE
  • https://www.googleapis.com/auth/drive - View and manage the files in your Google Drive.

    LXNAV Connect uses this scope to list and create folders, download and upload files. Because Google Drive doesn't have the granular folder access control we get the access to all your files saved in your Google Drive. However, we simulate the granular scope by creating folder “LXNAV_Connect” and accessing and manipulating files only in “LXNAV_Connect” folder. We never access any files outside this scope.


  • DROPBOX SIGN-IN
  • profile - View your basic profile info
    email - View your email address
    openid - Authenticate using OpenID Connect

    LXNAV Connect uses these scopes to authenticate you on our website.


  • DROPBOX
  • When you link Dropbox service to LXNAV Connect a special “LXNAV_Connect” folder is created. We use this folder to list and create folders, and download and upload files. We don't get the means to access any files outside this scope.


  • SEEYOU CLOUD SIGN-IN
  • profile - View your basic profile info
    email - View your email address
    openid - Authenticate using OpenID Connect

    LXNAV Connect uses these scopes to authenticate you on our website.


  • SEEYOU CLOUD
  • When you link SeeYou Cloud service to LXNAV Connect we get access to all the files saved on your SeeYou Cloud. Currently we support only uploading flights to SeeYou Cloud.


  • OLC (onlinecontest.org)
  • When you link the OLC service to LXNAV Connect we have to save your OLC login info which we use to upload flights per your request.


  • GPSAeroData
  • To access the data from GPSAeroData we need to store your login info. This can be your email or 5-letter user ID.

  • TopMeteo
  • When you link the TopMeteo service to LXNAV Connect we have to save your TopMeteo username which we use for authentication. TopMeteo sends us the list of regions you are allowed to access.


INFORMATION SHARING AND DISCLOSURE

  • THIRD-PARTY APPLICATIONS AND SERVICES
  • We may share your information with a third party application for the purposes of linking your account with external service or security identification with external service, with your consent, for example when you choose to access the external services via our Service. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you.

    Currently we support the following external services:

    (i) SeeYou Cloud (privacy policy)
    (ii) Google Drive (privacy policy; terms of use)
    (iii) Dropbox (privacy policy; terms of service)
    (iv) SkySight (info)
    (v) OLC (privacy policy; terms of use)
    (vi) GPSAeroData (info)
    (vii) TopMeteo (privacy policy; terms of use)


    We have established that above services comply with EU GDPR directive at minimum in areas where information to them is provided by our Service.

    Before linking an external service to our Service the user has to create an account at such service and accept their terms of use and privacy policy. The same terms and privacy policy apply when user is using the external service via our Service. Our Service works only as a data mediator between the user and the external service.


  • OUTBOUND COMMUNICATION
  • As an information management service our Services may display or send personal information, under your control, through our applications or via email or text.


  • COUNTRIES OUTSIDE THE EEA
  • Information that you submit via the Services may be transferred to and processed in countries outside the European Economic Area ("EEA"). By way of example, this may happen if one or more of our servers are from time to time located in a country outside the EEA or one of our service providers is located in a country outside the EEA. We shall take reasonable steps to ensure that any transfer of your personal information to a country or territory outside the EEA, whose laws may provide for a lesser standard of protection for your personal information than that provided under European law, shall have adequate protection (such as model contractual arrangements as approved by the EU).


  • LEGAL OBLIGATIONS
  • We may share your information where we are legally obliged to do so. Please note we may not be able to provide you with notice prior to disclosure in such cases.


COMPLIANCE WITH LAWS AND LAW ENFORCEMENT REQUESTS; PROTECTION OF LXNAV'S RIGHTS

We may disclose to parties outside LXNAV d.o.o. files stored in LXNAV Connect (not any of external services) and information about you that we collect when we have a good faith belief that disclosure is reasonably necessary to:

(i) comply with a law, regulation or compulsory legal request;
(ii) protect the safety of any person from death or serious bodily injury;
(iii) prevent fraud or abuse of LXNAV Connect or its users;
(iv) to protect LXNAV's property rights.


BUSINESS TRANSFERS

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email and/or a prominent notice on our website) of any change in control or use of your Personal Information or Files, or if either become subject to a different Privacy Policy. We will also notify you of choices you may have regarding the information.


NON-PRIVATE OR NON-PERSONAL INFORMATION

We may disclose your non-private, aggregated, or otherwise non-personal information, such as usage statistics of our Service.


YOUR RIGHTS TO ACCESS, CORRECT AND DELETE YOUR INFORMATION

You have the right to review, correct, delete, or limit the use of your Personal Information. Whenever made possible, you can update your Personal Information directly through tools we provide within the Services or through a written or verbal request. You may contact us through online form https://gliding.lxnav.com/about/, via email info@lxnav.com or telephone.

If you are a registered user, you may review, update, correct or delete the Personal Information provided in your registration or account profile by changing your “account settings.” If your personally identifiable information changes, or if you no longer desire our service, you may update or delete it by making the change on your account settings. Removing personal information, such as part of your billing information or profile, could cause an interruption in service or account suspension. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 5 years. For questions about your Personal Information on our Service, please contact info@lxnav.com.

You can request to obtain a copy of your Personal Information in a commonly used electronic format so that you can manage, review or move it. Please note that we may ask you to verify your identity before responding to such requests.


DATA RETENTION

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact info@lxnav.com. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.


SECURITY

Your personal data safety is of utmost importance to us. We review and strive to improve our security measures on a regular basis.

We encrypt the transmission of all of information using secure socket layer technology (SSL). All data relayed to external services is always transferred using secure channels (SSL).

We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it. We protect your Personal Information by methods of encryption and information hashing (where possible). No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee its absolute security.

We have implemented appropriate measures in the form of various technical, physical and other means, including, but not limited to measures regarding the security of our electronic systems and databases, locks, racks, cases and other devices and access controlling systems, fire-notifying and fire extinguishing systems. These means aim at improving the integrity and security of the personal information that we collect and maintain. However, please be advised that even the best security measures cannot guarantee the full elimination of all risks.

If we learn of a personal data breach that affects our Services we will attempt to notify you electronically so that timely and appropriate protective steps can be taken. Apart from informing you via email, we may post a notice through the website if a security breach occurs.

If you have any additional questions about security of your Personal Information you can contact us at info@lxnav.com.


SECURITY - YOUR RESPONSIBILITIES

It is your responsibility to secure your login credentials to the Services, and keep your email address up to date.


TERMINATION

This Privacy Policy is effective until terminated by either party. If you no longer agree to be bound by this Privacy Policy, you must cease the use of our Services. If you are dissatisfied with LXNAV d.o.o., its content, or any of these terms, conditions, and policies, your sole legal remedy is to discontinue using the Services. LXNAV d.o.o., reserves the right to terminate or suspend your access to and use of the Services, or parts of them, without notice, if we believe, in our sole discretion that such use is in violation of any applicable law, or harmful to our interests or the interests of another person or entity, or where LXNAV d.o.o. has reasons to believe that their use is in violation of this Privacy Policy or the Terms of Use.


OUR POLICY TOWARD CHILDREN

Our Services are not directed to persons under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, they should contact us at info@lxnav.com. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information from our files.


CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may change from time to time. If we make a change to this privacy policy that we believe materially reduces your rights, we will provide you with notice (for example, by email) and we may provide notice of changes in other circumstances as well. By continuing to use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.


GOVERNING LAW

This Privacy Policy and the use of the LXNAV Connect services are governed by the laws of Slovenia. The parties undertake to first try to resolve the dispute with by negotiation. If the parties fail to reach an amicable resolution through negotiation, LXNAV d.o.o. agrees to submit the dispute to the competent Court of Slovenia.

If you are accessing the LXNAV Connect website or services (connect.lxnav.com) from another jurisdiction, please be advised that you are transferring your personal information to LXNAV d.o.o. in Slovenia and, by using the website or services, you consent to that transfer and to abide by the applicable laws concerning your use of the website and your agreement(s) with us.


CONTACTING US

If you have any questions about this Privacy Policy, please contact us at info@lxnav.com or at:
LXNAV d.o.o.
Kidriceva 24
3000 Celje
Slovenia

We hope that we will be able to resolve any questions or concerns you may have.

However, if LXNAV d.o.o. does not address your request, or fails to provide you with a valid reason why it is unable to do so, you have the right to contact the Slovenian Information Commissioner to make a complaint. The Information Commissioner can be reached at: Republic of Slovenia, Information Commissioner, Zaloška 59, 1000 Ljubljana, Slovenia.