Last Updated:  06/03/2020

FlyData Sync, LLC., its affiliates and subsidiaries (“FlyData”, “we’, “us”, “our”) respect individual privacy and values the confidence of its customers, employees, consumers, business partners and others. FlyData strives to collect, use and disclose Personal Information in a manner consistent with the laws of the countries in which it does business, and pride themselves on upholding the highest ethical standards in their business practices.

This Privacy Shield Policy (“Policy”) describes our standards and procedures for handling Personal Information in accordance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”).

FlyData has certified to and will adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks by adopting and implementing the Privacy Shield Principles (“Principles”). More information about the Privacy Shield can be found at Our Privacy Shield certification can be found at

This Policy supplements our Privacy Policy Unless specifically defined in this Policy, the terms in this Policy have the same meaning as in our Privacy Policy. For the purposes of this Policy, a “Data Controller” means the entity which determines the means and the purposes of the Processing of Personal Information; a “Data Processor” means the entity which Processes Personal Information on behalf of the Data Controller; “Processing/Process” means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

In case of conflict between the Privacy Policy and this Policy, this Policy prevails. In case of conflict between this Policy and the Principles, the Principles will govern.

How we obtain Personal Information

We obtain and Process Personal Information from the European Economic Area (“EEA”) or Switzerland in different capacities:

  • As a Data Controller, we collect and Process EEA and Swiss Personal Information directly from individuals, either via our publicly available websites, including, or in connection with our customer, reseller, partner, and vendor relationships.
  • In connection with our Services, we obtain and Process EEA and Swiss Personal Information on behalf of and at the instructions of our customers.  In that context, customers are the Data Controllers.

FlyData commits to subject to the Principles all Personal Information received from the EEA or Switzerland in reliance on the Privacy Shield (which includes both types of activities).

Privacy Shield Principles

  1. Notice. Our Privacy Policy in combination with this Policy describes our privacy practices.  When providing our Services as a Data Processor, our customers determine the categories of Personal Information we Process and the purposes of the Processing. Accordingly, our customers are responsible for providing notice to individuals.
  2. Data Integrity and Purpose Limitation. Any Personal Information we receive may be processed by FlyData for the purposes indicated in our Privacy Policy or as otherwise notified to you. We will not process Personal Information in a way that is incompatible with these purposes unless subsequently authorized by you.

We take reasonable steps to limit the collection and usage of Personal Information to that which is relevant for the purposes for which it was collected, and to ensure that such Personal Information is reliable, accurate, complete and current.  Individuals are encouraged to keep their Personal Information with FlyData up to date and may contact FlyData as indicated below or in the Privacy Policy to request that their Personal Information be updated or corrected.

We will adhere to the Principles for as long as we retain the Personal Information collected under the Privacy Shield.

When providing our Services as a Data Processor, we Process and retain Personal Information as necessary to provide our Services as permitted  in our agreements, or as required or permitted under applicable law. 

  1. Accountability for Onward Transfer of Personal Information.  FlyData may transfer Personal Information as described in the Privacy Policy.  When providing our Services as a Data Processor, we disclose Personal Information as provided in our agreements with customers.

We remain responsible for the Processing of Personal Information received under the Privacy Shield and subsequently transferred to a third party acting as an agent if the agent Processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage. Where FlyData becomes aware that an agent is using or disclosing Personal Information in a manner contrary to this Policy, FlyData will take reasonable steps to prevent or stop the use or disclosure.

  1. Security.  FlyData takes reasonable and appropriate precautions, taking into account the risks involved in the Processing and the nature of the Personal Information, to help protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
  2. Access and Choice. If we intend to use your Personal Information for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized, or if we intend to disclose it to a third party acting as a Data Controller not previously identified, we will offer you the opportunity to opt out of such uses and/or disclosures where it involves non-sensitive information or opt in where sensitive information is involved. To limit the use and disclosure of their Personal Information, an EEA or Swiss individual may submit a written request to

Where appropriate, you have the right to access to the Personal Information we maintain about you and to correct, amend or delete that information when it is demonstrated to be inaccurate or incomplete, or has been Processed in violation of the Principles, by sending a written request as indicated in “Contact Information” below.  We will review your request within a reasonable timeframe in accordance with the Principles, and may limit or deny access to Personal Information as permitted by the Principles.

When providing our Services as a Data Processor, we only Process and disclose the Personal Information as specified in our agreements.  Our customers control how Personal Information is disclosed to us and Processed, and how it can be modified.  Accordingly, if you want to request access, or to limit use or disclosure of your Personal Information, please contact the company to whom you submitted your Personal Information and that uses our Services.  If you provide us with the name of the company to whom you provided your Personal Information and who is our customer, we will refer your request to that customer and support them in responding to your request.

  1. Recourse, Enforcement and Liability. We conduct an annual self-assessment of our practices regarding Personal Information intended to verify that the assertions we make about our practices are true and that such practices have been implemented as represented.

If you have any questions or concerns, we encourage you to first write to us as indicated below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. 

If an issue cannot be resolved through FlyData’s internal dispute resolution mechanism, you may submit a complaint, at no cost, to BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus, which serves as FlyData’s alternative dispute resolution provider. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. This service is provided free of charge to you.

For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration as detailed in the Principles available here.

FlyData is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

How is this Policy Updated?  This Policy may be amended consistent with the requirements of the Privacy Shield. A notice will be posted on FlyData’s website whenever this Policy is changed in a material way. When we update this Policy, we will also revise the “Last Updated” date at the top of this document. Any changes to this Policy will become effective when we post the revised version on our website.

Contact information.  If you have any questions, concerns or complaints regarding our privacy practices, or if you’d like to exercise your choices or rights, you can contact us:

  • via email at; or
  • by mailing to FlyData Sync, LLC., 21750 Hardy Oak Blvd Ste 104 PMB 96350, San Antonio, Texas 78258-4946, United States.

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