FLYSPOT PRIVACY POLICY

Welcome!

We care about your privacy. In this policy, we explain simply and clearly how we process your personal data when you use our services – Flyspot wind tunnel flights, Deepspot diving and our online store.

Last updated: 2025.10.29

1. This Privacy Policy describes the rules regarding the processing of data, in particular personal data, by Aerotunel Sp. z o.o. with headquarters in Warsaw, 00-090, Al. Solidarności 75/26, entered in the National Court Register maintained by the District Court for the city of Warsaw. st. Warsaw, XII Commercial Department of the National Court Register under the KRS number 0000821632, NIP: 5252533508, share capital of PLN 19,000,000 (hereinafter: “Aerotunel” or “Administrator”).

2. The Privacy Policy describes the principles of data processing in connection with the offering of services by Aerotunnel, in particular those available in the wind tunnel facilities operated under the name FlySpot and the facility including the deep diving pool operated under the name DeepSpot. The rules described herein also apply to additional services or functionalities related to FlySpot and DeepSpot’s operations, such as, in particular, services and content made available through the Administrator’s websites, including www.flyspot.com i www.deepspot.com, and processes relating to the sale of products and services in stationary and online stores. (All of the above services and activities will be hereinafter collectively referred to as the “Services” and the persons using or wishing to purchase or use such Services as “Users.”)

3. The Administrator can be contacted on all issues related to data processing, including personal data, at the following email address: [email protected]

4. Aerotunel will process, including the collection and storage of personal data, in accordance with applicable laws, in particular the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (‘RODO‘), as well as in accordance with this Privacy Policy.

5. We collect only the data that is needed to provide services. Depending on what you use, we may ask you to:

c.Health Data (with your consent only):
Some of our services (such as diving) involve risks. For the sake of your safety, we may ask about your health status or contraindications. You provide this data voluntarily, having given your consent.

6. Image: When you fly in the tunnel or dive, we record your image so you can get a souvenir recording.

7. We use your data to:

• ✅ Complete the service – booking, flight, diving, shipping voucher
• ✅ Issue an invoice
• ✅ Ensure safety – check health contraindications
• ✅ Contact you – confirmation of the reservation, answer to questions
• ✅ Send marketing information – about our services (only if you agree)
• ✅ Improve our site – with traffic analysis (via cookies)

8 We process your data on the basis of:

• Contracts – to perform the service you ordered (Article 6(1)(b) RODO)
• Your consent – for marketing, cookies, health data (Article 6(1)(a) RODO)
• Legal obligation – e.g. issuance of an invoice (Article 6(1)(c) of the RODO)
• Legitimate legitimate interest – e.g. contact regarding complaints, marketing of own services (Article 6(1)(f) RODO)

9. How long do we store the data?

Data Type	Storage Period
Contract data	up to 5 years after issuing the invoice (accounting requirement)
Marketing	until you withdraw your consent
Complaints	until claims expire
Health data	until service completion + complaint period
Monitoring	up to 3 months
Flight/dive recordings	14-30 days (then deleted)

10. We share data only when necessary with the following entities:

• Shoper S.A. – our online voucher store platform https://www.shoper.pl/polityka-cookies
• Couriers – when we send vouchers by mail
• Instructors – providing training
• Google and Meta – analytical and advertising tools (only if you consent to cookies)
• SalesManago, the Customer Engagement platform used by Aerotunel https://www.salesmanago.pl/info/obowiazek-informacyjny.htm
• SalesMore – marketing agency supporting Aerotunel in the area of promotion and advertising https://salesmore.pl/polityka-prywatnosci
• State authorities – when required by law
• User’s personal data may be transferred to advertising or marketing service providers for the purpose of analyzing website traffic sources, settling advertising campaigns, and displaying personalized product and service offers to the user.

11. In connection with the processing of personal data by Aerotunel, Users have rights under GDPR.

12. You have the right to:

• ✅ Access your data – you can ask what information we have about you
• ✅ Correct data – if something has changed or is incorrect
• ✅ Delete data – in certain situations (“right to be forgotten”)
• ✅ Restrict processing – e.g., when you question the accuracy of the data
• ✅ Data portability – receive data in a format allowing transfer
• ✅ Object – to marketing or profiling
• ✅ Withdraw consent – at any time (does not affect previous processing)
• ✅ Complain to the supervisory authority (UODO) – if you believe we violate your rights

13. Cookies are small files saved in your browser. They help remember User preferences (e.g., language), conduct visit statistics, and show ads tailored to User interests.

14. Cookie Categories We Use

• a. Necessary (you cannot disable them) Required for store operation – login, cart, payments. This category also includes operational cookies. Operational cookies serve to analyze traffic sources on the site, maintain high quality and continuity of service operation, protect against abuse and fake traffic, settle advertising campaigns, and handle User requests.
  Legal basis: legitimate interest (website operation)
• Functional (you can disable) – They remember your settings – language, appearance. Legal basis: Your consent
• Analytical (you can disable) – Google Analytics – count visits, show how you navigate the site. Legal basis: Your consent
• Marketing (you can disable) – Facebook Pixel, Google Ads – help us show you ads that may interest you. Legal basis: Your consent

⚠️ Warning: Disabling necessary cookies may cause the store not to work properly.

15. Data Transfer to the USA – Google and Facebook have headquarters in the USA. Data transfer takes place based on:

• · Standard Contractual Clauses (SCC) approved by the European Commission
• · Additional safeguards provided by these providers

More information:

• Google: https://privacy.google.com/businesses/compliance/
• The finish: https://www.facebook.com/privacy/policies/cookies

16. Video surveillance operates at Flyspot and Deepspot facilities. Its purpose is the safety of people and property and protection against theft. We store recordings for a maximum of 3 months, then they are automatically deleted (unless they are evidence in proceedings).

17. Marketing and Profiling

a. Newsletter – You can subscribe to the newsletter – we will send information about promotions and news. You can unsubscribe at any time (link in the email footer).

b. Profiling – We analyze User behavior on the site (what you browse, how much time you spend) to show more interesting offers and tailor content to User interests. This does not affect User rights.

18. Is User Data Secure? Yes! We use appropriate technical and organizational safeguards:

• Connection encryption (SSL)
• Access to data only for authorized persons
• Regular backups
• Security procedures

19. We may update this policy. Changes will be visible on this page, and we will inform you about significant changes additionally (e.g., through a banner or email).

20. Governing Law – Matters not regulated in this Privacy Policy regarding personal data processing principles are governed by applicable law, in particular GDPR.

Thank you for your trust! ✈️🏊‍♂️