INTRODUCTION

At Airobot, we attach great importance to the protection of your personal data. This Privacy Policy explains how we protect your personal data, whom you can contact for more information, and how you can exercise your legal rights. If you provide us with personal data of other persons, such as users of the Airobot software (hereinafter the “Tool”), please inform these persons of our Privacy Policy before entrusting us with their personal data.

We reserve the right to amend this Privacy Policy in response to changes in legislation or internal working methods. You can consult the most recent version of our Privacy Policy at any time on our website.

PART I: AIROBOT AS DATA CONTROLLER

CONTROLLER OF THE PROCESSING OF PERSONAL DATA

The controller of the processing of your personal data is Airobot NV. Airobot NV is a public limited liability company governed by Belgian law, with its registered office at Lichtenberglaan 1090, 3800 Sint-Truiden, Belgium, and registered with the Crossroads Bank for Enterprises under company number 0603.992.571.

Hereinafter, Airobot NV is referred to as “we” or “Airobot”.

LEGAL BASIS AND PURPOSES OF THE PROCESSING OF PERSONAL DATA

Purposes of the processing

We process the personal data of (prospective) customers, their contact persons, and users of the Tool for the purposes of:

(1) entering into or performing our agreement (Service Provision), as well as complying with related legal obligations (e.g. accounting or tax obligations); and

(2) direct marketing purposes.

We process the personal data of visitors to our website who complete the contact form solely for the purpose of:

(3) responding to the visitor’s request submitted via the contact form.

We process the personal data of (prospective) suppliers and their contact persons for the purposes of:

(4) purchasing and supplier management, as well as compliance with related legal obligations (accounting, taxation, after-sales services).

In addition, we use cookies on our website for the purpose of:

(5) optimising our website.

Use of analytical cookies

Our website uses analytical cookies, including Google Analytics, to gain insight into the use of our website and to improve its operation. Google Analytics collects, among other things, information about your visit to our website, such as IP address, visited pages, time and duration of the visit, and the browser and device used.

We have configured Google Analytics in a privacy-friendly manner, including:

• activation of IP anonymisation;
• exclusion of data sharing with Google for its own purposes;
• conclusion of a data processing agreement with Google.

Analytical cookies are only placed after your consent via our cookie banner. More information about the use of cookies can be found in our Cookie Policy.

Although Google is a company established outside the European Economic Area (“EEA”), the data processed via Google Analytics is processed as much as possible within the EEA. To the extent that personal data is nevertheless transferred outside the EEA, this is done on the basis of appropriate safeguards in accordance with the GDPR, such as standard contractual clauses approved by the European Commission.

User data may also be processed, in accordance with the Terms of Use of the Tool, for the purpose of:

(6) optimising the Tool and/or the Service Provision.

Legal basis of the processing

Service Provision

If you are a customer yourself, the processing of your personal data is solely intended to enable us to provide our services and to perform our agreement with you. Without this processing, our services cannot be provided. The legal basis for this processing is the conclusion or performance of our agreement.

If you are a contact person or a user of the Tool on behalf of our (prospective) customer and your data has been provided by the customer, we process your data on the basis of the legitimate interest of Airobot and the customer to organise the services and perform the agreement. Given the limited use of your data, we believe that your interests or fundamental rights and freedoms do not outweigh these interests. If you disagree, please consult the section “Your rights regarding the processing of personal data” below.

Direct marketing

Where we have already obtained your data in connection with the sale of our own services, we further process these personal data for direct marketing purposes on the basis of our legitimate interest in offering similar Airobot products.

If this is not the case, we request your explicit consent to process your personal data for sending direct marketing communications containing information about our services. Your consent is requested at the time we receive your personal data. You may withdraw your consent at any time by email at contact@airobot.eu.

Responding to your contact request

If you contact us via a contact form on our website, this also results in processing. This processing is based on our (and your) legitimate interest, solely for the purpose of handling and following up on your request for information.

Given your initiative to submit the request via the contact form (from which we assume you expect a response) and the limited use of your contact details to respond, we believe that your interests or fundamental rights and freedoms do not outweigh these interests. If you disagree, please consult the section “Your rights regarding the processing of personal data” below.

Purchasing and supplier management

If you are a supplier, we process your personal data solely to enable our cooperation, manage our supplier relationship, and enter into and perform the agreement with you. Without this processing, we cannot make use of your goods or services. The legal basis for this processing is the conclusion or performance of our agreement.

If you are a contact person of a (prospective) supplier and your data has been provided by your organisation, we process your personal data on the basis of the legitimate interest of Airobot and the supplier to manage the cooperation. Given the limited use of your data, we believe that your interests or fundamental rights and freedoms do not outweigh these interests. If you disagree, please consult the section “Your rights regarding the processing of personal data” below.

Legal obligations

We also process your personal data where necessary to comply with legal obligations related to the performance of our agreement (accounting, tax, or after-sales obligations).

Optimisation of the Tool and/or the Service Provision

This processing of user data is based on our (and your) legitimate interest in continuously improving our products and services. Given the limited use of user data, we believe that your interests or fundamental rights and freedoms do not outweigh these interests. If you disagree, please consult the section “Your rights regarding the processing of personal data” below.

PERSONAL DATA PROCESSED AND THE NECESSITY OF PROVIDING SUCH DATA

For (prospective) customers and their contact persons

• Name of contact person * (1)(2)
• Position * (1)(2)
• Telephone and/or mobile number * (1)(2)
• Business address * (1)
• Company contact details * (1)(2)
• Company entity and legal form * (1)(2)
• VAT number * (1)
• Financial data * (1)
• Username/password (1)
• Contract-related information (1)
• Where applicable: customer complaints and complaint details (1)

Personal data marked (1) are processed for sales purposes. Personal data marked (2) are processed for direct marketing purposes. The personal data marked with an * must be provided if the customer wishes to enter into a sales relationship. The provision of other personal data is entirely voluntary.

Categories of recipients and tools used

In the context of our activities, Airobot may rely on the following categories of service providers and tools, acting as processors within the meaning of the GDPR and acting solely on our instructions:

IT and cloud infrastructure

• Hosting and cloud platforms (for storage, processing, and backups of data)

• Data centres within the European Economic Area

  (e.g. cloud hosting providers and managed infrastructure providers)

Software and SaaS providers

• CRM and customer management tools

• Project and ticketing systems

• Internal communication and collaboration software

• Analysis and monitoring tools for performance and error detection

  These tools are used to efficiently organise and improve our services.

Website and marketing tools

• Website hosting
• Email and marketing automation tools
• Analytics and statistics tools (e.g. visitor statistics and usage analysis)
• Cookie and consent management tools

Financial and administrative service providers

• Accountants
• Payment service providers
• Invoicing and subscription management systems

Professional advisers

• Legal advisers
• Accountants
• Auditors

These parties only receive access to personal data insofar as this is necessary for the performance of their tasks. We conclude data processing agreements with all processors in accordance with the GDPR. These personal data are processed for the purposes of performing the agreement with the customer and optimising the Tool and the Service Provision.

Processing of personal data in the context of service provision

In the context of the delivery and optimisation of the Tool, personal data of users may be processed by external service providers who provide technical support for:

• hosting and making the Tool available;
• processing and storing maps, point clouds, and other user content;
• securing, monitoring, and maintaining the infrastructure;
• analysing usage and performance to improve the Tool.

These processing activities are necessary for the proper functioning of the Tool and for delivering the agreed services to our customers.

For website visitors who complete the contact form

• Contact details (name, email address, phone number) *
• Position *
• Company name
• Data entered on the contact page *
• Response to the request

The provision of these data is entirely voluntary. The personal data marked with an * must be provided to submit a contact form. The data are processed solely to correctly handle your request.

For (prospective) suppliers and their contact persons

• Name of contact person * (1)
• Position * (1)
• Telephone and/or mobile number * (1)
• Business address * (1)
• Company contact details * (1)
• Company entity and legal form * (1)
• Company number * (1)
• VAT number * (1)
• Financial data * (1)
• Contract-related information (1)
• Where applicable: supplier complaints and complaint details (1)

Personal data marked (1) are processed for purchasing purposes. The personal data marked with an * must be provided if the supplier wishes to enter into a business relationship. The provision of other personal data is entirely voluntary.

DURATION OF PROCESSING AND RETENTION PERIOD

For (prospective) customers, (prospective) suppliers, and their contact persons

We retain your personal data for as long as necessary for active case management or, after the cooperation ends, for one year or as long as legally required.

Personal data processed on the basis of your consent or our legitimate interest are processed until you withdraw your consent or object to the processing.

For users of the Tool

We may, but are not obliged to, process your data in accordance with the Terms of Use for the improvement of our Tool and Service Provision. Airobot may (without being obliged to do so) retain processed maps and point clouds created in the Tool with the associated user account for two years after creation (“cold storage”), even if the additional storage period described in Part II below has expired, for the purpose of increasing the attractiveness of its services for returning customers and improving the Tool and Service Provision. Two years after creation, and provided that the additional storage period described in Part II has expired, the relevant data will be automatically deleted.

For website visitors who complete the contact form

We process your personal data for as long as necessary to handle and follow up on your request. The data are not retained thereafter, unless they are processed in the context of another processing purpose as described in this Privacy Policy.

RECIPIENTS AND TRANSFER OF PERSONAL DATA

Except as described below, Airobot will in principle not disclose or transfer your personal data to third parties, third countries, or international organisations, unless you have given prior and explicit consent.

It is possible that our processors may have access to your personal data, including but not limited to: IT and hosting service providers, accountants, marketing agencies, HR services, sales and marketing tools, and software providers that assist Airobot in managing our website, the Tool, our information systems, and our business in general. Such transfers are subject to confidentiality obligations and processing in accordance with our instructions and applicable legislation. Airobot will not transfer personal data to processors outside the EEA unless appropriate safeguards are in place in accordance with the GDPR.

We may also disclose personal data if we believe in good faith that such disclosure is necessary to comply with applicable legislation or to defend or protect our rights and/or those of our customers, whether or not in legal proceedings.

YOUR RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA

With regard to the personal data processed by Airobot, you have the following legal rights:

• right to information and access;
• right to rectification;
• right to erasure and/or restriction of processing;
• right to data portability;
• right to object where processing is based on Airobot’s legitimate interest;
• right to withdraw your consent, without affecting the lawfulness of processing prior to withdrawal.

You can exercise these rights by contacting us at contact@airobot.eu. We will handle your request within one month. If we cannot comply with your request, we will inform you of the reason. If we are unable to properly identify you, we may request proof of identity.

For any questions or comments regarding this Privacy Policy or the processing of your personal data, you can contact us at contact@airobot.eu.

You also have the right to lodge a complaint with the Data Protection Authority:

Data Protection Authority

Drukpersstraat 35, 1000 Brussels

Tel: +32 (0)2 274 48 00

Email: contact@apd-gba.be

URL: https://www.gegevensbeschermingsautoriteit.be/burger

PART II: AIROBOT AS PROCESSOR (PROCESSING POLICY)

INTRODUCTION

The processing activities described below concern cases where Airobot acts as a processor. When using the Tool, the customer initiates the processing and determines the purposes and means of processing their personal data.

As controller, the customer is responsible for complying with all legal obligations associated with that role, in particular the obligation to inform data subjects about the purposes of processing.

LEGAL BASIS AND PURPOSES FOR PROCESSING CUSTOMER PERSONAL DATA

Purposes of the processing

Airobot processes personal data on behalf of its customer in accordance with the purposes determined by the customer. These purposes relate to the processing, analysis, and sharing of data collected by drones for the customer’s commercial activities.

In this context, Airobot performs the following processing activities:

• authentication to (parts of) the Tool;
• technical processing necessary for service provision;
• incident support;
• improvement of security.

Legal basis of the processing

Airobot processes personal data solely in accordance with the customer’s instructions and agreed purposes.

CUSTOMER PERSONAL DATA EXPECTED TO BE PROCESSED

• Name
• Email address
• Username/password
• Log data
• Customer-specific data: all personal data managed by the customer in the Tool
• User content including messages, reviews, videos, maps, models, folders, data, text, photos, images, and data collected by a drone or device, including maps and point clouds
• location and geospatial data (e.g. GPS coordinates);
• image and video material;
• technical metadata related to datasets (e.g. capture time, altitude, sensor data);
• identifying object information insofar as it can be traced back to natural persons;
• log and audit data related to use of the Tool.

These personal data may relate to the following categories of data subjects:

• the customer and its employees;
• users of the Tool on behalf of the customer;
• customers of the customer;
• third parties appearing in data collected by the customer (e.g. persons visible in images, maps, or models);
• visitors or users of locations where data are collected;
• natural persons indirectly identifiable via location or contextual data.

DURATION OF PROCESSING AND RETENTION PERIOD

We retain customer personal data in accordance with the customer’s subscription to our Service Provision. After the end of a one-month free trial (“Basic Service”) or after expiry or termination of a paid subscription, customer data, including all processed maps and point clouds created in the Tool with the associated user account, may be deleted:

• 30 days after the end of the Basic Service or a monthly paid subscription; or
• one year after the end of an annual paid subscription.

If the customer renews the subscription within this additional storage period, the data will not be deleted and the user will retain access.

As explained in Part I, Airobot may also process data as controller for the purpose of improving the Tool and Service Provision, including retaining processed maps and point clouds for up to two years after creation (“cold storage”), even after expiry of the additional storage period. After two years and provided that the additional storage period has expired, the data will be automatically deleted.

SUB-PROCESSORS

The customer authorises Airobot to engage sub-processors for the purposes described in this policy. The customer approves the following sub-processors:

These sub-processors are bound by obligations at least equivalent to those of Airobot. Airobot will inform the customer of any intended changes regarding sub-processors, allowing the customer to object.

RECIPIENTS AND TRANSFER OF PERSONAL DATA

Airobot will not transfer customer personal data to sub-processors outside the EEA unless appropriate safeguards are in place in accordance with the GDPR and subject to the provisions on changes to sub-processors described above.

RIGHTS REGARDING THE PROCESSING OF CUSTOMER PERSONAL DATA

Airobot undertakes to assist the customer, taking into account the nature of the processing, with:

• complying with GDPR obligations, such as responding to data subject requests under Chapter III GDPR;
• carrying out a data protection impact assessment where required.

If the customer requires assistance, they must inform Airobot immediately by email and telephone.

TECHNICAL AND ORGANISATIONAL SECURITY MEASURES

Airobot undertakes to implement appropriate technical and organisational security measures to protect customer personal data and to update them regularly, including:

• role-based access control;
• encryption of data in transit and, where appropriate, at rest;
• system logging and monitoring;
• regular backups;
• secure authentication (e.g. strong passwords, MFA where possible);
• periodic security evaluations;
• staff awareness and confidentiality obligations.

DATA BREACH NOTIFICATION

Airobot will:

• monitor security incidents involving customer personal data;
• detect data breaches;
• report security breaches without undue delay.

In the event of a data breach, Airobot will promptly inform the customer and provide relevant information for notification to authorities where possible. Incident logs will be retained for six (6) months.

CONFIDENTIALITY CLAUSE

Airobot will treat personal data processed for customer purposes confidentially and will not disclose such data to third parties without the customer’s prior written consent. Airobot ensures that employees and sub-processors involved are bound by confidentiality obligations.

AUDITS

The customer has the right to audit Airobot’s compliance with this Processing Policy during normal business hours, provided Airobot is notified at least one month in advance. Audit costs are borne by the customer unless serious deficiencies are identified.

DATA PROTECTION CONTACT

Name: Cedric Cops

Tel: +32 471 42 8889

Email: cedric@airobot.eu