Flight Club Privacy Policy

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use the Service and explains your privacy rights and how the law protects you. We use your Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliatemeans an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company(referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to SMRT TEC CORP.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Nova Scotia, Canada.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• Website refers to Flight Club, accessible from https://flightclub.life
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Information We Collect

We may collect the following categories of Personal Data:

• Identity and contact information (e.g., name, email, phone number).
• Government identification or licenses (if required for verification).
• Payment information (processed securely by third-party payment providers).
• Profile information, photos, listings, and reviews.
• Communications sent through our platform.
• Geolocation and device information.
• Background check or verification data from service providers (where permitted by law).
• Information from third-party integrations (e.g., Google APIs).
• Usage and analytics data.

How We Use Personal Data

We use Personal Data to:

• Operate, maintain, and improve the Service.
• Facilitate transactions and payments.
• Verify identity, prevent fraud, and promote safety.
• Enable communications between users.
• Provide customer support.
• Send transactional notices and, where permitted, promotional messages.
• Comply with legal obligations and enforce our agreements.

Sharing and Disclosure of Personal Data

We may share your Personal Data:

• With other users to facilitate bookings and transactions (e.g., name, profile photo, listing details).
• With Service Providers including payments, hosting, analytics, verification, and insurance partners.
• With a not-for-profit general aviation industry trade association, for the purpose to verify the User's membership status with such not-for-profit industry trade association, and User's eligibility for additional entitlements or benefits as a result of such membership.
• With authorities where required by law, regulation, or to protect safety.
• Across borders: Personal Data may be stored or processed in the U.S., Canada, or other countries where we or our vendors operate. We use contractual, technical, and organizational measures to safeguard such transfers.

Use of Artificial Intelligence and Automated Systems

We use artificial intelligence (AI), machine learning, and other automated tools to help operate and improve our Services. These tools may be used for purposes such as:

• Fraud detection and prevention.
• Risk assessment and account security.
• Personalizing and improving search results, recommendations, and user experience.
• Content moderation (e.g., detecting prohibited content or unsafe behavior).
• Customer support, including automated responses or suggested replies.

Human Oversight

AI outputs are regularly reviewed and monitored by Flight Club staff. Decisions that may significantly affect your rights (such as account suspension, denial of access, or eligibility restrictions) involve human review.

Data Used by AI

AI systems are trained and operate on data we already collect as described in this Privacy Policy, including profile information, communications, transaction history, and usage data. We do not sell your data for AI model training by third parties.

Your Choices

Where required by law, you may have the right to:

• Request information about the use of automated decision-making in relation to your account.
• Opt out of certain types of automated processing that produce legal or similarly significant effects, subject to limitations under applicable law.
• To exercise these rights, contact us at Privacy@flightclub.life.

Tracking Technologies and Cookies

We use cookies, pixels, and similar technologies to enable functionality, analyze usage, and provide personalized content and advertising. You can manage cookies through your browser settings. For California and certain other U.S. residents, you may opt out of targeted advertising or the sale/share of your Personal Data. Flight Club honors Global Privacy Control (GPC) and other recognized universal opt-out signals.

Data Retention

We retain Personal Data for as long as necessary to provide the Service, resolve disputes, comply with legal obligations, and enforce agreements. Typical retention periods include:

• Transactional and tax records: at least 7 years.
• Verification documents: shortest period required for compliance.
• Messaging data: until disputes or claims are resolved.

Security and Breach Notification

We implement technical and organizational safeguards to protect Personal Data. If a breach of security safeguards creates a real risk of significant harm, we will notify affected individuals and, where required, regulators such as the Office of the Privacy Commissioner of Canada (OPC), the Alberta OIPC, or applicable U.S. authorities. We maintain breach records for at least 24 months, as required by Canadian law.

Children's Privacy

The Service is not directed to individuals under 16. We do not knowingly collect Personal Data from children under 13. If we become aware that such information has been collected, we will delete it.

Your Rights

U.S. Residents

Depending on your state of residence (e.g., California, Virginia, Colorado), you may have rights to:

• Access, correct, or delete your Personal Data.
• Appeal decisions regarding your requests.
• Opt out of the sale or sharing of your Personal Data and of targeted advertising.
• Limit the use and disclosure of sensitive Personal Data (where applicable).
• We honor browser- and device-based opt-out signals such as Global Privacy Control (GPC).

Canadian Residents

Under PIPEDA and Ontario law, you may:

• Request access to your Personal Data.
• Request correction of inaccurate or incomplete information.
• Withdraw consent, subject to legal or contractual restrictions.

To exercise your rights, please contact us at Privacy@flightclub.life.

U.S. State Privacy Notice

This U.S. State Privacy Notice supplements the Flight Club Privacy Policy and applies to residents of California, Colorado, Connecticut, Delaware, Montana, New Jersey, Oregon, Texas, Utah, Virginia, and any other U.S. state that has enacted similar privacy laws.

Categories of Personal Data Collected

We collect the categories of Personal Data described in our Privacy Policy, including identifiers, contact details, payment information, commercial information related to your transactions, internet or device activity, geolocation data, and profile content you provide.

Purposes of Use

We use this information for the business purposes described in the Privacy Policy, including providing our services, processing transactions, verifying identity, ensuring safety, personalizing content, marketing, and complying with law.

Disclosures of Personal Data

We disclose Personal Data to:

• Other users of the marketplace (only what is necessary for a transaction).
• Service providers such as payment processors, hosting providers, analytics vendors, and verification/insurance partners.
• Regulators and law enforcement, where required.

We do not sell Personal Data in the traditional sense. However, some of our sharing practices may be considered a “sale” or “share” of Personal Data or “targeted advertising” under state privacy laws.

Your Rights

Subject to applicable law, you may have the right to:

• Access and obtain a copy of your Personal Data.
• Request correction of inaccurate information.
• Request deletion of your Personal Data.
• Opt out of the sale or sharing of your Personal Data and of targeted advertising.
• Limit the use and disclosure of sensitive Personal Data (where applicable).
• Appeal decisions we make regarding your rights requests.

We honor browser and device-based opt-out signals, including Global Privacy Control (GPC).

How to Exercise Your Rights

You can exercise your rights by:

• Emailing us at Privacy@flightclub.life
• Using the “Do Not Sell/Share My Personal Information” link in the footer of our Website

You may designate an authorized agent to make a request on your behalf, subject to verification. We will not discriminate against you for exercising your rights.

Contact Us

If you have questions, concerns, or requests about this Privacy Policy or your Personal Data, please contact our Privacy Officer:

Email: Privacy@flightclub.life

Mailing Addresses:

• Canada (Ontario corporation): SMRT TEC CORP., 101-5101-50th Avenue, Suite 910, Leduc, AB T9E 0B9, Canada
• United States (Delaware corporation): SMRT TEC CORP., 3500 S Dupont Hwy, Dover, DE 19901, USA

If you are in Canada, you may also contact:

• Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca
• Office of the Information and Privacy Commissioner of Alberta: https://oipc.ab.ca