FLIGBY’s Data Policy

FLIGBY® Leadership Simulation and related online solutions are offered as a service of ALEAS Group and were created to assess and develop people management skills.

At ALEAS Group (represented by ALEAS Hungary Ltd.) (“Company,” “ALEAS,” “we,” “our,” and/or “us”), we value the protection and the privacy of individuals who use our platform and services through https://www.fligby.com and https://metrix.fligby.com (the “Site”), our software application (the “App”), and any related web-based, downloadable or other applications (collectively, the “Service”). This Data Policy describes the way we process and protect personal information and data that You provide, or we collect in connection with the Service.

This Data and Privacy Policy will explain how our Company uses the personal data we collect from You when You use our Service. Words and terms used in this Data Policy unless otherwise defined shall have the meanings given to them in the European Union’s General Data Protection Regulation (“GDPR”), the Brazil Lei Geral de Protecao de Dados (“LGPD”) and the California Consumer Privacy Act of 2018 (“CCPA”), all as amended from time to time. References to the GDPR shall be deemed to include the GDPR as incorporated into UK law under the Data Protection Act 2018 (DPA 2018).

1. What data do we collect?

ALEAS collects several different types of information for various purposes to provide and improve our learning and development services to our users and partners.

ALEAS collects several different types of information to provide and improve our smart learning and development services to our users. Offering the Service and experiences requires ALEAS to process personal information You provide. Personal information includes information that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular user or household. In some instances, information is collected in the aggregate that does not relate to any particular user or household, such as the number of App users per day. In other instances, personal information can be sufficiently anonymized that it cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular user.

Creating a “FLIGBY” account requires your basic contact information, including your email address. We may also require You to select a password for authentication and provide a username that will be visible to other users when You post to public portions of the Service. We receive and store this information and use it to create a user profile and provide You with access to the Service. We may use your email address to contact You with information relating to the Service or to provide support. We may also require your contact and payment information if You are entitled to receive payment based on your use of the Service or if You have accepted an obligation to provide payment. When You post or upload materials to the Service, including without limitation text, audio, images, or other media (collectively “User Content”), those materials are personal information.

If You make a purchase through our Service, your payment-related information, such as your credit and debit card or automated clearing house (ACH) information, is collected and stored by our third-party payment processor on our behalf.

When You use the Service, ALEAS may collect additional personal information, including more detailed contact information You provide, your location, demographics, and your use of the Service. We may also collect and record certain information such as your unique device ID, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends and for providing You with the correct version of the application.

If You contact us directly, we may receive additional information about You. For example, if You contact us for customer support, we may receive your name, email address, phone number, the contents of any message or attachments You may send to us, and any other information You choose to provide.

We automatically receive information about your interactions with our Service, such as your gaming results, the posts or other content You view, the searches You conduct, the people You follow, and the dates and times of your visits.

We may collect information using cookies, pixel tags, and similar technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after You close your browser. A persistent cookie remains after You close your browser and may be used by your browser on subsequent visits to our Service.

Our Company also collects the following data:

  • Information and content You provide. We collect the content, communications, and other information You provide when You use our Services, including when You sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content You provide.
  • Device Information. As described below, we collect information from and about the computers, phones, and other web-connected devices You use that integrate with our Services.
    • Device attributes: information such as the operating system, hardware and software versions, browser type, app, and file names and type.
    • Identifiers: unique identifiers, device IDs, and other identifiers.
    • Device signals: Bluetooth and Satellite signals and information about nearby Wi-Fi access points, beacons, and cell towers.
    • Network and connections: information such as the name of your satellite operator or ISP, language, satellite phone number, and IP address.
  • Cookie data: data from cookies stored on your device, including cookie IDs and settings.

2. How do we collect your data?

You directly provide our Company with most of the data we collect. We only collect such Personal Information on our Site or in our App when You voluntarily provide it to us. We collect data and process data when You:

  • Subscribe online or create an account to subscribe for our Services.
  • Provide your email address to sign up.
  • Voluntarily subscribe or contact us via email or other communications methods.
  • Use or view our website via your browser’s cookies.
  • Provide any other information voluntarily when using our Site or App.

Our Company may also receive your data indirectly from the following sources:

  • Information about your computer or device and internet or satellite connection, including operating system, device type, and browser type.
  • Details of your visits to our Site, including traffic logs and data.

Our Company uses cookies in a range of ways to improve your experience on our Site, including:

  • Keeping You signed in.
  • Understanding how You use our Site.

Our Company uses cookies to recognize You on our Site and remember your previously selected preferences. These could include what language You prefer and location You are in. A mix of first-party and third-party cookies is used.

You can set your browser not to accept cookies, and the website tells You how to remove cookies from your browser, however, some of our features may not function as a result.

3. How will we use your data and personal information?

Our Company collects your data and personal information so that we can:

  • Create your account to subscribe to our Services.
  • To personalize your experience.
  • Track audience size and usage patterns.
  • Recognize You as a returning user to our Site.
  • Provide, maintain, and improve our Services.
  • Communicate with You, provide You with updates and other information relating to our Service, provide information that You request, respond to comments and questions, and otherwise provide customer support.
  • Send You messages and notifications.
  • Facilitate transactions, redemptions, and payments.
  • Find and prevent fraud and respond to trust and safety issues.
  • Understand and analyze how You use our Service and develop new products, services, features, and/or functionality.

For data collected from the European Union, EFTA states, Brazil, and the United Kingdom, the primary legal bases/basis we rely on for such processing is a contractual necessity for fulfilling our Terms of Service and Terms of Use and to comply with our legal obligations.

4. How we share the information we collect

We do not and will never rent, sell, or share information about You with nonaffiliated third parties for their direct marketing purposes unless we have your affirmative express consent. We do not and will never rent, sell, or share information about You with nonaffiliated third parties for their direct marketing purposes unless we have your affirmative express consent. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if You post any objectionable content on or through our Service in violation of our Data and Privacy Policy. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Data and Privacy Policy in effect at the time of the acquisition or merger. We may also disclose your information with your permission.

5. How do we store your data?

Our Company securely stores your data. We secure your data through encryption in transit and at rest. your data will be stored in accordance with the applicable retention requirements of the Company, US laws, and any other applicable laws.

6. Does ALEAS process the personal information of children?

We do not knowingly collect, maintain, or use personal information from children under 18 years of age. If You have concerns, believe, or learn that a child has provided us with personal information violating this Privacy Policy, please alert us at info@fligby.com.

 7. Record keeping

Our Company keeps a record of when and how we received your consent for data collection and processing. Our Company keeps a record of exactly what and where You were told at the time of consent. We regularly review consents to check that their relationship, the processing, and their purpose have not changed.

8. What are your data protection rights?

Our Company would like to make sure You are fully aware of all your data protection rights. Every user is entitled to the following:

  • The right to access – You have the right to request Our Company for copies of your personal data. We may charge You a small fee for this service.
  • The right to rectification – You have the right to request that Our Company correct any information You believe is inaccurate. You also have the right to request Our Company to complete the information You believe is incomplete.
  • The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data under certain conditions.
  • The right to object to processing – You have the right to object to Our Company’s processing of your personal data under certain conditions.
  • The right to data portability – You have the right to request that Our Company transfer the data that we collected to another organization, or directly to You, under certain conditions.

If You make a request, we have one month to respond to You. If You would like to exercise any of these rights, please contact us.

9. Data security

To accomplish its mission of helping leaders and organizations develop people skills, ALEAS must collect and analyze vast amounts of data. As such, it is dedicated to putting the necessary safeguards in place to maximize the protection of these data.

ALEAS maintains a highly secure information technology environment to protect its client’s data’s confidentiality, integrity, availability, and privacy. It adheres to all Canada, U.S., European Union, and international data protection and security laws, and it routinely undergoes regular audits of its information technology to ensure its policies, procedures, and security controls meet or exceed the high standards of its clients.

In addition, ALEAS operates in a proactive security environment that uses a multitude of preventative, detective, and administrative systems and controls. We have chosen to ensure maximum coverage of client requirements by implementing rules for information security managed under the frameworks of ADGA Groups Converged security solutions.

ADGA Group, 110 Argyle Ave, Ottawa, Canada

10. How to contact us

If You have any questions about Our Company’s Data Policy or the data we have collected, or You would like to exercise one of your data protection rights, please do not hesitate to contact us.

            ALEAS Hungary Ltd., 1112 Budapest, Nevegy u. 28., Hungary

Should You wish to report a complaint or if You feel that our Company has not addressed your concern in a satisfactory manner, You may contact our Data Protection Officer for the contact information for the appropriate authority.

11. Changes to our privacy policy

Our company keeps its privacy policy under regular review and places updates on this web page.

Last updated: March 14, 2023