Effective: [], 2021; Updated January 1, 2023

This Airpeak privacy policy ("Privacy Policy") applies to information collected by Sony Electronics Inc. ("Sony", “we”, “us” or “our”), through Airpeak, including the Airpeak device ("Airpeak Product"), Airpeak Flight app and Airpeak Base app ("App(s)"), Airpeak Plus (“Cloud Service “)) , any Airpeak-specific registration pages, and any other Sony online or wireless service that posts a link to this Privacy Policy or otherwise expressly states that it is governed by this Privacy Policy, whether accessed via computer, mobile device or other technology (collectively, the "Services"). Please note that this policy does not apply to any other Sony website or online service, including any Sony Electronics pages, such as for newsletter sign-ups, unless expressly posted on such website or online service.

Please read this Privacy Policy carefully. In addition, please review our Airpeak EULA and User Agreement which governs your use of the Services.

Given the nature of the Airpeak Product, you may at times permit others to interact with or be in proximity to your Airpeak Product. You are solely responsible for informing any such person of the Airpeak Product's information collection capabilities and confirming his or her agreement to this Privacy Policy (or, if the person is a minor, the agreement of his/her parent or guardian).

TABLE OF CONTENTS

• Collection of Information
• Information You Provide to Sony
• Information Sony Collects Automatically
• Uses of the Information Sony Collects
• When and with Whom Sony May Share Information Collected
• Individuals Under 16
• Security and Retention
• Consent to Processing
• Policy Governs Use; Changes to Privacy Policy
• California Privacy Notice/Other State Rights
• Questions

Collection of Information

SONY collects and uses information or data as described below (collectively, the “Collected Data”). Some of this information may be considered personal information under applicable law in your jurisdiction, and it is collected when you choose to provide information to us or automatically when you use the Airpeak Product, App or Services.

Information You Provide to Sony

In General. We may collect information that could reasonably be used to contact you or to identify you personally (such as first and last name, email address, mailing address, telephone number, photographs or videos) when you register an Airpeak Product, create an Airpeak account, purchase a Cloud Service plan, and at other times during your use of the App(s) or our Services. We may also ask you to provide other information about yourself, such as demographic information (gender, geographic region, age, etc.) or certain information about your preferences and interests. If you choose not to provide certain information, you may not be able to register an Airpeak Product, utilize the Apps, purchase the Cloud Service, or use certain features on the Airpeak Product, or participate in other activities we offer. If we combine demographic or other information we collect about you with information that may identify you, we will treat the combined information as personal information.

Information Sony Collects Automatically

Through Your Interactions with our Services

Whenever you visit or interact with the Services, Sony and its third-party service providers automatically collect certain information regarding your use of the Services and your devices ("Usage Information"). Usage Information may include, in part, browser type, operating system, and the aspects of the Services you access, such as the Apps or Cloud Service (including the time at which a feature is used, the duration of the use, and the way you navigate within the Services). We also collect your IP address and other unique identifiers ("Device Identifier(s)") that identify the Airpeak Product, computer, mobile device, or other device you use to access the Services. We may also collect information regarding the physical location of the Airpeak Product, its flight path and the amount of time it is operated.

Through the Airpeak Product

We may collect Usage Information through the Airpeak Product, including information about the device itself and information the Airpeak Product collects through its sensors, such as air pressure, temperature, acceleration, geomagnetism, Inertial Measurement Unit (“IMU”), Infrared Range and GPS location. The sensor data is not associated with or linked to your Device ID. However, the following data may be collected and associated with your Device ID: device controls, settings (e.g., network settings, status information), activity logs and operational data, and flight plan information (including geolocation data, flight duration, positioning and movement data related to an Airpeak Product's mapping and movement), First Person View (“FPV”) camera data and data related to the Airpeak Product's behavior.

Airpeak Apps

In order to use certain services or features available through the Airpeak Apps and the Cloud Service, you will need to create and sign into an account. If you choose to create an account, SONY will assign identifiers (“Account IDs”) and collect your name, email address, age and password you input when creating the Account. We may collect additional information as follows:

• Information about the devices on which the Apps and Cloud Service are installed or used: Device ID and specifications/features; Operating System and Operating System version; Language code, country or region, time zone; Operational status; and IP address used by such device’s internet connection.
• nformation about the Apps and Cloud Service: Application ID and version, settings; account information, such as user name and profile information; purchase information and tokens; Information regarding the usage status and usage history of the Apps, including time stamp, flight plans, flight logs and fleet information.

Uses of the Information Sony Collects

Sony will use the Collected Data, including your personal information:

• to allow you participate in the Services, or features or activities we offer;
• to tailor your experience on or with the Services;
• to process a transaction or your account registration, verify your identity or eligibility, and send you confirmations and receipts;
• to provide you with information about products, services, promotions or other offerings that may be of interest to you;
• to provide you with support and answer questions or other requests;
• for legal, regulatory and compliance purposes, including security and fraud detection;
• to detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Services; and
• for other purposes disclosed to you at the time you provide the Collected Data or with your consent.

We may also use the Collected Data to monitor performance and for the design, development and improvement of the Services and other products and services, for other internal business purposes, and to contact you with regard to your use of the Services and, in our discretion, changes to any of our policies.

When and with Whom Sony May Share Information Collected

Non-Personal Information. We may share aggregate user statistics, demographic information, hashed or otherwise de-identified data, and other anonymous data with third parties for a variety of purposes, such as providing analytics, to the extent permitted by law.

Collected Data. We may also share Collected Data, as specifically disclosed at the time you provide the Collected Data or with your consent, as otherwise described in this Privacy Policy, and in the following circumstances:

To Affiliates and Other Sony Companies. Sony may share Collected Data with companies affiliated with Sony ("Affiliates"), so that those Affiliates can provide services to us, such as fulfilling your requests or purchases, or improving our products and services. We may also share Collected Data with Affiliates for other internal business and operational purposes, including any corporate reorganization, restructuring or other corporate change. For purposes of this Privacy Policy, Affiliates means (a) Sony Group Corporation, (b) any other company with respect to which Sony Group Corporation owns, directly or indirectly, 50% or more of its outstanding shares, that owns, directly or indirectly, 50% or more of Sony's outstanding shares, or that is under the control of a common party with Sony, and (c) any company with the name "Sony" as a part of its trade name.

To Third-Party Service Providers Providing Services on Sony's Behalf. We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share Collected Data with third-party service providers that assist us with providing content, fulfilling your requests, improving our products, content, or services, delivering advertising, or otherwise performing services for Sony. For example, third-party service providers may assist us with hosting or operating the Services, processing transactions and payments, fulfilling orders, providing analytics services, sending email, and administering promotions.

Business Transactions. Sony or any of its assets, including the Services, may be sold, or other transactions may occur in which the Collected Data is one of the key business assets in the transaction (such as a merger, acquisition, or bankruptcy, including, without limitation, during the course of any due diligence process related to such transaction). In such a case, the Collected Data may be one of the business assets we transfer and Sony reserves the right to disclose and transfer Collected Data, in connection with this type of business transaction.

Legal Protections and Law Enforcement. We may transfer and disclose information, including Collected Data, to third parties: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce our terms of use, license agreements, or other applicable agreements or policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of third parties, visitors to the Services or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, or law enforcement agencies in our discretion.

Individuals Under 16

Our Services are intended for a general audience and are not targeted to children younger than the age of 16. If you believe that we have collected information of a child under the age of 16 in contravention of any applicable laws and regulations, you may request that we delete that information by contacting us as stated in the Questions section below.

Security and Retention

Sony uses commercially reasonable safeguards to help protect and secure the Collected Data, and we use reasonable efforts to obtain the agreement of our Affiliates and third-party service providers to take steps to protect the confidentiality, security, and integrity of Collected Data we share with them. However, no electronic data transmission or storage of information can be guaranteed to be 100% private and secure. To help protect you and others, we may monitor use of the Services, and we use the Collected Data to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the Services; ensure compliance with the applicable terms of service and this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of Sony, its Affiliates, partners and customers. Sony does not ensure or warrant the security of any information you transmit to us, and you use the Services and provide us with your information at your own risk. Sony will retain the Collected Data under this Privacy Policy for as long as you use the Services and for a reasonable time thereafter. Sony will take steps to remove, delete or anonymize Collected Data when it is no longer needed. Please note that we may need to keep certain Collected Data to comply with applicable legal, regulatory, or other obligations, or the information is required for business reasons (such as to resolve disputes, provide service and enforce agreements), and we may be required to retain certain information by law.

Consent to Processing

This Privacy Policy is only intended for Airpeak Products purchased in the United States and users of the Services located in the United States. The Services are operated in the United States and Japan. Please be aware that the Collected Data will be transferred to and processed in the United States, Japan, and other jurisdictions. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of Collected Data in the United States, Japan, and other jurisdictions. If, notwithstanding the above, you are located in the European Union or elsewhere outside of the United States, you understand that your information may be transferred, processed, and stored in a jurisdiction where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

Policy Governs Use; Changes to Privacy Policy

The terms of this Privacy Policy will govern the use of any information collected while it is in place. Sony reserves the right to change this Privacy Policy at any time, without prior notice to you, and any changes will become effective immediately upon posting unless otherwise specified. Your continued use of the Services after the effective date of any changes to this Privacy Policy (or such other action as Sony may specify) will constitute acceptance of, and agreement to be bound by, those changes.

State Notices

Notice to Virginia Residents

We set forth above in our Privacy Policy the categories of personal information we process, the purpose for processing personal information, the categories of personal information shared, and the categories of third parties with whom personal information is shared.

Virginia consumers have the following rights with respect to their personal information pursuant to the Virginia Consumer Data Protection Act (VCDPA):

1. To confirm whether we are processing your personal information and request to access such data.
2. That we correct inaccurate personal information we hold about you.
3. That we delete the personal information provided by you or obtained about you.
4. To obtain a copy of the personal information previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability
5. To appeal a decision by us relating to a data request you have submitted to us.

If you are a Virginia consumer and would like to exercise any of these rights, please complete the form here: Data Requests

In addition, Virginia consumers have the right to opt-out out of the processing of your personal information for the purposes of targeted advertising. Sony engages in online advertising and analytics practices that may be considered “targeted advertising” under the VCDPA. To exercise your rights to opt-out of targeted advertising, you may submit a request here: Do Not Sell or Share My Personal Information

In addition, you may need to disable sharing through cookies set by 3rd parties on the Airpeak websites. To manage your cookie preferences, please refer to the “Manage Cookies” option for the Airpeak website and ensure that “Targeting” cookies are disabled.

CALIFORNIA PRIVACY NOTICE

This Airpeak California Privacy Notice is effective as of January 1, 2023.

Please note that this Airpeak California Privacy Notice applies to information collected under and controlled by this Privacy Policy and does not apply to other information that may be collected by or submitted to other Sony websites or online services, including any other Sony Electronics pages, such as for newsletter sign-ups or general product registration.

Our Practices Regarding Collection and Use of your CA Personal Information

If you reside in California, we are required to provide additional information to you about how we collect, use and disclose your personal information as defined under applicable law (“CA Personal Information”), and you may have additional rights with regard to how we use your CA Personal Information. We have included this California-specific information below

CA Personal Information. Consistent with the "Uses of the Information Sony Collects" section above, we may use CA Personal Information for the following business or commercial purposes:

California Consumer Rights. Subject to certain exceptions, as a California consumer, you may have the following rights regarding your CA Personal Information:

• Right to Know. Request information regarding what CA Personal Information we collect, use, disclose, and sell, including the right to request that we provide you with the categories and specific pieces of Personal Information we have collected about you;
• Right to Delete. Request deletion of the CA Personal Information we collect about you;
• Right to Correct. Request correction of inaccurate CA Personal Information that we maintain about you;
• “Do Not Sell or Share My Personal Information.” Request to opt-out of the “sale” of your CA Personal Information or the “sharing” of your CA Personal Information to a third party for cross-contextual behavioral advertising (i.e., targeted advertising). We do not knowingly sell or share for cross-contextual behavioral advertising the CA Personal Information of consumers younger than the age of 16.
• You may request us to limit the use or disclosure of your Sensitive Personal Information if we use or disclose such information for purposes other than certain excepted purposes set forth in the statute. Our use and disclosure of Sensitive Personal Information falls within this list of exceptions, and we therefore do not offer such opt-out right at this time.

Exercising Your Rights.

If you are a California consumer and would like to exercise your Right to Know, Right to Delete, or Right to Correct, please submit your request at: Data Requests;

or you may call us toll-free at 1-833-681-9900.

Please note that before we can provide specific pieces of information, we may require a signed declarationthat you are the consumer whose Personal Information is the subject of the request. We may also request confirmation of requests to delete information.

Do Not Sell or Share and Exercising your Rights

Right to Opt-Out of Sale or Sharing

California Consumers have the right to opt-out of the “sale” or sharing of CA Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising). If you are a California Consumer and would like exercise your Right to Opt-Out of Sale of Sharing, please submit your request at:

Do Not Sell or Share My Personal Information

Other Important Informationfor Do Not Sell or Share

Sony engages in online advertising and analytics practices which may be considered a “sale” or “share” for cross-context behavioral advertising as defined in the CPRA. In addition to submitting the form above, you may need to disable sharing through cookies set by 3rd parties on the Airpeak websites. To manage your cookie preferences, please refer to the “Manage Cookies” link for the Airpeak website and ensure that “Targeting” cookies are disabled.

Verifying Requests.When submitting your request, you must include your first and last name, email address, and zip code or mailing address. You may be asked to provide additional proof of identification so that we can verify your identity, and we may require that you validate your request. In response to a Request to Know, we may also require a signed declaration under penalty of perjury that you are the consumer whose CA Personal Information is the subject of the request before providing specific pieces of CA Personal Information. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, or in connection with promotions and other offerings, based upon you exercising your rights with respect to your CA Personal Information. Please note that you are limited by law in the number of requests you may submit per year.

Authorized Agents. If you are an agent making a request on a consumer’s behalf, you must provide appropriate documentation that includes your name, the name of the individual who is the subject of the request, and a clear description of the permission granted; alternatively, you may submit a valid, designated power of attorney as defined in the California Probate Code sections 4000-4465. The consumer’s identity, in addition to your own, will need to be verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that you were granted permission to submit the request. If we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.

Data Retention

We retain all categories of Personal Information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes outlined in this California Privacy Notice, considering the time period reasonably necessary to: provide the goods or services you request; exercise the choices and rights you have requested; comply with our contractual obligations; comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Except as noted differently specific pages or apps, we retain your personal information while you have an account with us, or while you are using our Services or continuing to interact with us.

Annual Metrics Reporting - Click here to access our data reporting metrics for the previous calendar year.

Additional Notice to California Residents:

If you are a California resident, under the California “Shine the Light” law, you have the right to receive: a) information identifying any third party company(ies) to which we may have disclosed, within the past year, personal information pertaining to you and your family for that company's direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to privacy@am.sony.com, and include your name, email address, and a reference to “Your California Privacy Rights.” We are not responsible for requests that are not labeled or sent properly, or do not have complete information.

Questions

If you have any questions or comments about our practices regarding the Collected Data or this Privacy Policy, you may:

• write to us: c/o Sony Electronics Inc., Personal Information Management Office, 115 West Century Road – Suite 250, Paramus, NJ 07652;
• send us an email at: privacy@am.sony.com; or
• call us at: 1-833-681-9900.

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