Privacy Policy
TOPFLIGHT TECHNOLOGY SDN. BHD. (referred to hereafter as “Top Flight” or “we”) prioritizes the protection and security of users' personal data at all times. To support this commitment, we have formulated this Privacy Policy to ensure that your personal information is handled securely and responsibly throughout your use of our services and its associated services. Before accessing or using our services and any services offered by Top Flight, we kindly ask that you read and understand the terms outlined in this Privacy Policy. This Policy constitutes an integral component of our Terms of Service and carries equal legal weight, remaining subject to the provisions contained therein. By proceeding to use our services and its features, you acknowledge and accept the practices of data collection, usage, storage, and disclosure as described within this Policy. At Top Flight, we recognize the value and sensitivity of your personal information and are dedicated to safeguarding its integrity and confidentiality. In line with established industry standards, we pledge to implement appropriate technical and organizational measures to secure your personal data. Our sincere goal is to provide a reliable and worry-free experience while you use our services. Should you have any inquiries or suggestions, you are encouraged to contact us at any time.
1.Personal Information Collection

1.1 When you register for our services or create an account, you need to provide relevant personal information, including mobile phone number, email address, custom username and password. This information will be used to verify your identity, ensure account security and provide you with services.

1.2 When purchasing products or services from Top Flight, you may need to provide transaction information such as name, contact information, address, tax identification number (TIN), business registration certificate, bank card number, etc. This information will be used for order generation, payment processing, logistics distribution and other processes to ensure the smooth completion of transactions.

1.3 The backup service function of this product is turned off by default, and user and flight information will not be uploaded or disseminated through mobile devices. Unless the user explicitly grants permission through our services, the Top Flight Customer Service team has no right to access flight log data. After granting this permission, only the flight logs within the selected date range can be accessed. When you use our platforms or systems to connect with the aircraft and perform related operations, Top Flight may collect information or data such as your device location, flight path, flight altitude, speed, and related device status to optimize your flight experience, ensure flight safety, and provide you with more accurate services.

1.4 Various still and moving images and data from aircraft sensors will be stored on the internal drive of the aircraft. If your aircraft needs to be repaired, you can authorize Top Flight to use the information on the internal storage unit of the aircraft for diagnosis; Top Flight ensures that the data is only used for maintenance purposes and will not be abused or leaked. If it is not necessary to process services or repairs, this information will not be retained by Top Flight.

1.5 In order to improve your service experience, we may collect information such as communication records, questionnaire responses, and service usage habits between you and the customer service team.

1.6 We may invite you to participate in product improvement plans to help us optimize existing products or design new products. During this process, we may collect diagnostic data and dosage data, but you have the right to choose whether to participate.

1.7 We may process your personal data without your prior consent in the following limited circumstances, as permitted by applicable laws:

1.7.1 When required to comply with a legal obligation;

1.7.2 When necessary to protect vital interests (e.g., life or physical safety);

1.7.3 When processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority;

1.7.4 When the data has been made publicly available by you;

1.7.5 When necessary for the performance of a contract to which you are a party;

1.7.6 When otherwise permitted or required by applicable laws and regulations.

Note: Your personal information may contain sensitive personal information. Please handle such information carefully when using our products or services. The above information you provide will continue to authorize us to use it during your use of Top Flight products and services. When you cancel your account, we will stop using and deleting this information, except for special requirements for information retention time by laws and regulations.

When we use information for other purposes not specified in this policy, or use information collected for specific purposes for other purposes, we will seek your consent in advance.

2.Information Usage and Disclosure

2.1 Top Flight strictly follows the principle of data minimization and will not share your personal information with any company, organization or individual other than Top Flight, except in the following circumstances:

2.1.1 With your affirmative consent: After obtaining your affirmative consent, Top Flight will share your personal information with other parties.

2.1.2 Complying with laws and regulations or government requirements: Top Flight may share your personal information externally in accordance with the provisions of laws and regulations or mandatory requirements of government authorities.

2.1.3 Sharing with Affiliates: Your personal information may be shared with Top Flight's affiliates, but only to the extent necessary to achieve the purposes described in this Privacy Policy. If the affiliates need to change the purpose of processing personal information, Top Flight will seek your authorization again.

2.1.4 Sharing with authorized partners: In order to provide better services and user experience, Top Flight may share your necessary personal information with authorized partners. For example, logistics information when purchasing products will be shared with logistics service providers. Top Flight ensures that partners only process your information for legal, legitimate, necessary, specific, and clear purposes, and strictly limits its scope of use. Top Flight's authorized partners include but are not limited to suppliers, service providers, and other business partners who assist Top Flight in providing technical infrastructure, transaction and communication services, and customer support. Top Flight has signed strict Non-Disclosure Agreements with all partners who share personal information, requiring them to handle personal information in accordance with Top Flight's instructions, this Privacy Policy, and other relevant confidentiality and security measures.

2.1.5 Cross-border transfer: We may transfer your personal data to our affiliates or service providers located in other countries or regions as necessary to deliver our services. In such cases, we implement appropriate safeguards to ensure your data is protected in accordance with applicable data protection laws, such as the use of Standard Contractual Clauses under the GDPR.

2.2 Top Flight will not transfer your personal information to any company, organization or individual at will, except for the following circumstances:

2.2.1 With your affirmative consent: After obtaining your affirmative consent, Top Flight will transfer your personal information to other parties.

2.2.2 In the event of a merger, acquisition or bankruptcy liquidation, such as the transfer of personal information, Top Flight will ensure that the new information holder continues to be bound by this Privacy Policy, or seek your authorization and consent again.

2.3 Top Flight will publicly disclose your personal information only in the following circumstances:

2.3.1 With your affirmative consent: After obtaining your affirmative consent, Top Flight may publicly disclose your personal information.

2.3.2 Based on legal requirements: Under the explicit requirements of law, legal procedures, litigation or government authorities, Top Flight may publicly disclose your personal information. Top Flight will ensure that this process complies with legal requirements and protects your legitimate rights and interests as much as possible.

3.Information Protection

3.1 We use industry-leading security technologies and standards to ensure that the personal information you provide is fully protected. We have implemented a series of security measures, including but not limited to:

3.1.1 Data Encryption: We use advanced encryption technology to protect the confidentiality of data and prevent unauthorized access to data.

3.1.2 Access Control: We have established strict access control mechanisms to ensure that only authorized personnel can access your personal information and data.

3.1.3 Security Training: We regularly conduct security and privacy training for employees to raise their awareness of the importance of protecting personal information.

3.2 We only collect personal information that is necessary to achieve the purposes described in this clause and retain this information for a reasonable period of time after the purpose is achieved. Unless required by law or necessary to extend the retention period, we will promptly delete or anonymize your personal information.

3.3 We understand the security challenges of the Internet environment and therefore strongly recommend that you:

3.3.1 do not send sensitive data via email, instant messages, or other unencrypted means.

3.3.2 use complex and unique passwords to protect your account.

3.4 We are committed to protecting the security of your personal information, but please understand that the Internet environment is not absolutely secure. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or damage to your personal information, we will try our best to take remedial measures to reduce your losses.

3.5 If a personal information security incident occurs, we will promptly notify you of the relevant situation in accordance with the requirements of laws and regulations, including the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and suggestions for you to independently prevent and reduce risks. At the same time, we will proactively report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities.

3.6 Information sharing of third-party websites and services

3.6.1 Through our services, you may choose to share information with downloaded third-party websites or services. Please note that any information you provide on third-party websites or services will be received and processed directly by the operator of that service. Even if you access or link through our services, the personal information and data you provide are still subject to the Privacy Policy and Terms of Service of that third-party service operator.

3.6.2 we are not responsible for the privacy and security practices and content of third-party websites or services linked to or accessed through our services. We strongly recommend that you carefully read and understand the Privacy Policy, Terms of Service, and other relevant information of the third-party website or service before sharing information to ensure that you understand how their data is collected, used, stored, and shared.

3.6.3 Before deciding to share information with third-party websites or services, please evaluate the risks yourself and ensure that your choice meets your privacy and security needs. Top Flight is not responsible for any consequences that may arise from sharing information with third-party websites or services.

4.Children's Privacy
Our services are not intended for children under the age of 18 (or 16 in certain jurisdictions). We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information promptly in accordance with applicable laws.
5.User Rights

In accordance with relevant laws, regulations, standards, and national and regional practices, we fully respect and ensure that you exercise the following rights to your personal information:

5.1 You have the right to access your personal information in accordance with laws and regulations. You can access and manage your account info in the following ways:

5.1.1 Account information: You can view and edit your personal profile information, payment information, change passwords, add security information, etc. Please note that due to security and identity recognition considerations or mandatory provisions of laws and regulations, some initial registration information may not be able to be modified.

5.1.2 If you cannot access it through the above methods or need to access other personal information, you can contact us by sending an email to the topflight@topflightuav.com or other contact methods provided on the website/application.

5.2 When you find errors in the personal information we process about you, you have the right to ask us to correct it. You can request a correction by sending an email to the topflight@topflightuav.com or by contacting us according to the instructions on the website/application.

5.3 In the following situations, you can request us to delete your personal information in the following cases:

5.3.1 Our collection and use of personal information violates laws and regulations;

5.3.2 Our handling of personal information violates our agreement with you. If we decide to respond to your deletion request, we will notify all entities that have obtained your personal information from us and require them to delete it in a timely manner, unless otherwise provided by laws and regulations or these entities have obtained your independent authorization. Please note that even if you request deletion, due to technical limitations and backup needs, we may not be able to immediately delete relevant information from all backup systems. We will ensure that this information is properly stored, isolated, and cleared or anonymized as soon as technical conditions permit.

5.4 You have the right to cancel your account with us at any time. After account cancellation, we will stop providing you with relevant products or services and delete your personal information at your request (except as otherwise provided by laws and regulations).

5.5 To ensure the security of your information, we may require you to provide a written request or other means to prove your identity. Before processing your request, we may require you to verify your identity. We generally do not charge any fees for your reasonable requests. However, for requests that are repeated multiple times and exceed reasonable limits, we may charge a certain cost fee depending on the situation. For requests that are unreasonably repetitive, technically difficult, high-risk, or do not meet the actual situation, we may refuse to process them.

5.6 Please note that in the following circumstances, we may not be able to respond to your request as required by laws and regulations:

5.6.1 Directly related to national security and national defense security.

5.6.2 Directly related to public safety, public health, and major public interests.

5.6.3 Directly related to criminal investigation, prosecution, trial, and judgment execution.

5.6.4 There is sufficient evidence to show that you have subjective malice or abuse of rights.

5.6.5 Responding to your request will seriously harm your or other individuals' or organizations' legitimate rights and interests.

5.6.6 Involving trade secrets;

5.6.7 Related to our fulfillment of obligations stipulated by laws and regulations.

6.Third-party Technology and Services
To ensure the stable operation of the functions, we may access the software development kit (SDK) provided by third party to achieve the aforementioned purposes. We will strictly review the SDK from which our partners obtain personal information to protect your personal information security. Please note that in third-party SDKs personal information processing types may change due to version upgrades, policy adjustments and other reasons. Please refer to official instructions.
7.International Transfers of Personal Data
Your information collected by our services may be transferred to and accessed by Top Flight entities and business partners globally to provide Top Flight Products and Services to you. We will provide the same level of protection as set forth in this policy regardless of the location of processing.
8.Policy Update
Top Flight's privacy policy may be updated in response to business needs, changes in laws and regulations, or technological development. Please regularly review this privacy policy to understand the latest privacy policy of Top Flight. If you continue to use Top Flight's products or services after the update of this policy takes effect, it means that you have fully read, understood, and accepted the updated terms, and are willing to be bound by the updated terms. If we make significant changes to this Privacy Policy in accordance with applicable laws and regulations, we will notify you through other appropriate channels (such as pop-ups) and obtain your consent again.
9.Miscellaneous
This policy will be implemented according to relevant laws and regulations.
No matter any clause of this policy becomes valid or cannot be executed, other clauses still take effect.
10.Contact Us

If you have any questions, complaints or suggestions about this Privacy Policy or personal information protection, you can contact us through any of the following ways:

a) Contact us through +60 17-358 8197 or topflight01@topflightuav.com.

b) Send mail to: 2518, Lorong Perusahaan Baru 2, Kawasan Perusahaan Perai 3, 13600 Perai, Penang, Malaysia