Thank you for your interest in Shenzhen HEISHA Technology Co., Ltd. and its affiliated companies (“HEISHA”, “we,” or “us”) and in the various hardware, firmware, software, websites, applications, and services provided by us and on which a link to this Privacy Policy (this “Policy”) is displayed (each, a “Product” or “Service” and, collectively, the “HEISHA Products and Services”).

Shenzhen HEISHA Technology Co., Ltd. is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information in connection with the HEISHA Services, as defined herein. This Privacy Policy describes our practices in connection with information that we collect through the HEISHA website (currently available at www.heishatech.com) and any successor website, on both desktop and mobile web browsers (the “Website”); through the software applications made available by us for use on or through computers and mobile devices (the “Apps”); through any drone that you own or operate and that is used in connection with any of our services (each, a “Drone”); and through HTMLformatted email messages that we send to you (collectively, including the Websites, the Apps and Drones, the “Services”). By providing Personal Information to us or using our Services, you agree to the terms and conditions of this Privacy Policy.

Personal Information

Personal Information We May Collect “Personal Information” is information that identifies you as an individual or relates to an identifiable person, such as:

Name

Postal address

Telephone number

Email address

Credit and debit card number

Social media account ID

We may use a third-party payment service to process payments made through the Services.

If you wish to make a payment through the Services, your Personal Information may be collected by such third party, and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We May Collect Personal Information

We and our service providers may collect Personal Information in a variety of ways, including:

Through the Services: We may collect Personal Information through the Services, such as when you sign up for an account, operate a Drone, or ask us to contact you.

From Other Sources: We may receive your Personal Information from other sources, such as drone manufacturers; public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms; and from other third parties. For example, if you elect to connect your social media account to your Website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your social media profile or your friends’ profiles.

How We May Use Personal Information

We may use Personal Information:

To verify your identity in connection with your use of a Drone.

To respond to your inquiries and fulfill your requests, such as to send you emails or newsletters.

To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.

To provide you with information about your Drone or its intended flight path.

To complete and fulfill your purchase.

To provide you with customer service.

To send you marketing communications that we believe may be of interest to you.

To personalize your experience on the Services by presenting content, products and offers tailored to you.

To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these may have rules that contain additional information about how we use and disclose your Personal Information, so we suggest that you read the rules carefully.

To facilitate social sharing functionality.

To allow you to send messages to a friend through the Services.

For our business purposes, such as data analysis, audits, identity verification, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

To our affiliates, for the purposes described in this Privacy Policy.

To drone manufacturers, in connection with your operation of a Drone manufactured by that manufacturer.

To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

To third parties, to permit them to send you marketing communications, consistent with your choices.

To third parties, such as airports, with your consent.To third-party sponsors of sweepstakes, contests and similar promotions.

To identify you to anyone to whom you send messages through the Services.

By you, on message boards, chat, profile pages, blogs and other services to which you are able to post information and materials or communicate with other users of the Services.

Please note that any information you post or disclose through these services will become public and may be available to users of the Services and to the general public. We urge you to be very careful when deciding to disclose any information on the Services.

To your friends associated with your social media account, to other website users and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account. By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your Personal Information shared with other users or with your social media account provider, please do not connect your social media account with your Services account, and do not participate in social sharing on the Services.

To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Other Information

Other Information We May Collect “Other Information” is information that does not reveal your specific identity or does not directly relate to an individual, such as:

Drone information

Browser and device information

App usage data

Information collected through cookies, pixel tags and other technologies

Demographic information and other information provided by you

Aggregated information

How We May Collect Other Information

We and our third-party service providers may collect a variety of Other Information, including:

Drone information: When you use a Drone, we may collect its physical location, including its flight path, by, for example, using satellite, cell phone tower of WiFi signals. We may also collect a serial number or other information that identifies the Drone. We may use this information to provide you with personalized location-based services and content, including information regarding geofences and flight data. We may share the information we collect about a Drone, combined with your Personal Information, with our partners, including Drone manufacturers.

Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.

Through your use of the App: When you download and use the App, we may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences and other anonymous traffic data. We use the information for security purposes; to facilitate navigation; to display information more effectively; to personalize your experience; and to continually improve the design and functionality of the Services, understand how they are used and to assist us with resolving questions about them.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept these cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.

We may use third-party services, such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and to report on activities and trends. Such services may also collect information regarding the use of other websites, apps and online services. You can learn about Google’s practices by going to www.google.com/policies/privacy/?partners/ and opt out of them by downloading the browser add-on available at https://tools.google.com/dlpage/gaoptout.

We do not respond to browser do-not-track signals.

Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.

IP address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.

Physical location: We may collect the physical location of your mobile device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. You may be able to allow or deny such uses of your device’s location, but, if you do, we may not be able to provide you with the applicable personalized services and content.

From you: Information such as your preferred means of communication is collected when you voluntarily provide it.

By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular postal code.

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including your drone manufacturer or any other third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

Choices and Access

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

Receiving electronic communications from us: If you no longer want to receive marketingrelated emails from us on a going-forward basis, you may opt out by following the instructions contained in each such email. Please note that if you opt out, we may still send you important administrative messages, from which you cannot opt out.

Our sharing of your Personal Information with affiliates and unaffiliated third parties for their own direct marketing purposes: If you prefer that we not share your Personal Information on a going-forward basis with our affiliates or unaffiliated third parties for their own direct marketing purposes, you may opt out of this sharing by writing to us at: Shenzhen HEISHA Technology Co., Ltd., A1001, Huayi building, No. 7, Yongxiang road, Wuhe Community, Bantian street, Longgang District, Shenzhen, China.

We will try to comply with your request(s) as soon as reasonably practicable.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress, or delete Personal Information that you have provided us, you may contact us at sales@heishatech.com or: Shenzhen HEISHA Technology Co., Ltd. A1001, Huayi building, No. 7, Yongxiang road, Wuhe Community, Bantian street, Longgang District, Shenzhen, China

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have the Personal Information you have provided us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of Personal Information you have provided us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

Retention Period

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Use of Services by Minors

The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals not provide Personal Information through the Services.

Cross-Border Transfer

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us.

Updates to this Privacy Policy

Contacting Us

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Any questions about this Privacy Policy should be addressed to sales@heishatech.com.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.