Privacy Policy

This Privacy Policy is incorporated by reference into the CartoLake End User License Agreement (“EULA”). The terms “CartoLake,” “we,” and “us” include CartoLake LLC and our affiliates and subsidiaries. The Privacy Policy explains how CartoLake may collect, use, and disclose information we obtain through the “Service.” Any capitalized terms used and not defined in this Privacy Policy shall have the meaning given to them in the EULA.

IMPORTANT NOTE: By accessing or using the Service, you expressly consent to CartoLake’s collection, use, and disclosure of your Personal Information in accordance with the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the EULA.

Categories of Personal Data Processed by CartoLake

PERSONAL DATA THAT IS PROCESSED WHEN YOU CREATE A FLIGHTBAGX ACCOUNT:

When you create a FlightBagX account, we ask you to provide your email address and name.

PURPOSES AND LEGAL GROUNDS:

(a) CartoLake processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on CartoLake’s legitimate interest in protecting the security of your account.

(b) CartoLake also processes your email address for the purpose of sending you important information about your FlightBagX products, apps or account, such as important safety information or material changes to this Privacy Policy. The name you provide is associated with your account profile. The legal ground for processing your email address and name for these purposes is CartoLake’s legitimate interest in providing you important safety or other information about your FlightBagX products, apps or account or material changes to this Privacy Policy.

(c) By giving CartoLake your email address, you consent to receiving marketing information from CartoLake, and CartoLake will process your email address for the purpose of sending you marketing information about FlightBagX products and apps, newsletters, and other occasional emails. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your FlightBagX account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from CartoLake are based on the preferences you provide in your FlightBagX account, the locale indicated by your Internet Protocol (IP) address, the types of FlightBagX devices you have added to your FlightBagX account, and any subscriptions included in your FlightBagX account. The legal ground for processing this data for this purpose is CartoLake’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.

(d) CartoLake also processes your email address to associate it with your FlightBagX account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.

PERSONAL DATA THAT IS PROCESSED WHEN YOU MAKE A PAYMENT:

When you make payments through the Service, you may need to provide financial account information, such as your credit card number or bank account information, to our third-party payment processors. This information is provided directly to such payment processors, and we do not collect or store such information, though we may receive summary information about transactions that does not include credit card or bank account numbers.

PURPOSES AND LEGAL GROUNDS:

The legal ground for processing this data for these purposes is performance of a contract. We also process your personal data as part of our fraud detection processes. The legal ground for processing your personal data for that purpose is our legitimate interest in protecting CartoLake and our customers from attempts to engage in fraudulent transactions.

Your financial account information, such as your credit card, is required to make a payment for a product. The legal ground for processing your email address for this purpose is based on CartoLake’s legitimate interest in collecting payment for its services.

PERSONAL DATA THAT IS PROCESSED WHEN YOU ADD AN AIRCRAFT TO YOUR FLIGHTBAGX PROFILE:

When you add an aircraft to your FlightBagX account, we may ask for additional information, such as the make, model, series name, tail number, year and serial number of the aircraft.

PURPOSES AND LEGAL GROUNDS:

This information is processed to help CartoLake function better by understanding the performance of your aircraft and allowing CartoLake to make better calculations about your flight. The legal ground for processing this information is our legitimate interest in providing a better product that incorporates the performance of your aircraft in making calculations.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE FLIGHTBAGX TO CREATE AND FILE FLIGHT PLANS:

You can use FlightBagX to create flight plans and file those flight plans with applicable aviation authorities. When you do this, we process your name, phone number, address, aircraft details, date and time of the flight, and associated flight details.

PURPOSES AND LEGAL GROUNDS:

This information is processed to help you create flight plans and file them with applicable aviation authorities. The legal ground for processing this information is our legitimate interest in providing a tool to our customers to create and file flight plans.

PERSONAL DATA THAT IS PROCESSED USING THE LOCATION INFORMATION FROM YOUR MOBILE DEVICE:

When you use FlightBagX, we process the aircraft’s tail number, latitude, longitude, heading, barometric altitude, destination, estimated time enroute, and associated flight details. Without location information, FlightBagX navigational features will not function properly. This data is uploaded to your FlightBagX account.

PURPOSES AND LEGAL GROUNDS:

This information is processed to help you keep track of important details regarding your flights. The legal ground for processing this information is our legitimate interest in providing a tool to our customers to keep track of important flight details. In addition, CartoLake’s navigational features help provide you with a safer flight.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE THE LOGBOOK FEATURE:

When you use the logbook feature on FlightBagX, we process information about your flights, such as the take-off and landing airports, dates and times, and notes you choose to submit.

PURPOSES AND LEGAL GROUNDS:

We process this data to provide our customers an automated tool for them to maintain these regulatorily required records in their pilot logs. The legal ground for processing this information is our legitimate interest in providing our customers an automated tool for them to maintain these regulatorily required records in their pilot logs.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE THE APPLICATION:

When you use the FlightBagX app, we process information about you and your device including a device ID, IP address, mobile software and hardware information, pages or areas visited within the Service, what time said pages and areas are visited, and web browser information, so that we can provide and customize functionality, such as push notifications. You may also permit the Service to access your device’s contact list and photo storage.

PURPOSES AND LEGAL GROUNDS:

We process this data to provide our customers with a better user experience. The legal ground for processing this information is our legitimate interest in providing a better product that provides the user with a better experience.

PERSONAL DATA THAT IS PROCESSED WHEN YOU COMMUNICATE WITH CARTOLAKE:

When you interact with our customer support representatives via email, telephone, or online, we collect personal data, such as your name, mailing address, phone number, email address, and contact preferences; and information about the FlightBagX products you own. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys.

When you contact CartoLake for technical support, diagnostic data, including logs from the device on which you use our application, may be automatically uploaded to CartoLake to help the technical support team resolve your concerns.

PURPOSES AND LEGAL GROUNDS:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is CartoLake’s legitimate interests in providing quality product support.

Categories of Recipients of Personal Data

AVIATION AUTHORITIES:

When you use FlightBagX to create and file flight plans, your flight plans and associated information are submitted to the applicable aviation authorities.

OTHER SERVICE PROVIDERS:

CartoLake uses a custom service to assist in sending emails and to analyze the use and performance of FlightBagX products. This service tracks the activities associated with emails, such as whether they were opened, whether links in the emails were clicked on, and whether purchases were made following clicks on those links. That data is stored solely within the FlightBagX servers. CartoLake uses this data to analyze the level of engagement with its emails. CartoLake uses third-party service providers such as Segment to help us better understand usage of the FlightBagX website and app.

OTHER DISCLOSURES:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of CartoLake assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information, and we disclaim any liability arising out of such entity’s failure to comply with the terms of the EULA or this Privacy Policy.

Cookies and Similar Technologies

WEBSITE:

To help analyze how you and other visitors navigate the CartoLake websites, we compile aggregate statistics about site usage and response rates to help diagnose any problems with CartoLake’s servers, administer the CartoLake websites, and maintain user experience continuity across website pages and site visits, we, with assistance from third-party analytics service providers, collect certain information when you visit our site. This information includes IP address, geographic location of the device, browser type, browser language, date and time of your request, time(s) of your visit(s), page views and page elements (e.g., links) that you click. We may use cookies, pixel tags, web beacons, clear GIFs or other similar tools on our sites or in our email messages to assist us in collecting and analyzing such information. We use this information to provide better, more relevant content on our sites, to identify and fix problems, and to improve your overall experience on our sites.

If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.

FLIGHTBAGX APP:

We also collect data from users about their usage of the FlightBagX app. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. CartoLake uses this data to improve the quality and functionality of the FlightBagX app; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.

The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products, apps, and websites so we can enhance the user experience and functionality of our products, apps, and websites.

Here are examples of third-party providers of analytics and similar services we currently use:

ANALYTICS SERVICES:

Segment: This site uses Segment web analytics. Segment helps us measure and evaluate site usage behavior, such as mouse clicks, mouse movements, keystrokes (excluding personally identifiable information), scrolling activity, and pages visited and actions taken on the site and app. For more information, see the Segment privacy policy.

Information Security

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Neither CartoLake, nor its affiliates, nor any of their respective employees, officers or agents or the provider of the internet services on behalf of CartoLake (nor any other person involved in the management or establishment of the Service) can give any representation or warranty as to the absolute security of the data transmitted using the Service, and cannot give any guarantee that such data will not be compromised by bad actors. If you choose to provide data to or allow collection of data by CartoLake, then you do so understanding the aforementioned risk.

By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice by mail.

Children’s Privacy

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at crew@flightbagx.com. If we learn that we have collected any Personal Information from children under 13 in a manner that is inconsistent with the U.S. Children’s Online Privacy Protection Act, we will promptly take steps to delete such information and terminate the child’s account as soon as practicable.

Marketing

We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. We may allow access to other data collected by the Service to send information we think may be useful or relevant to you. Note that we may use your name, usage history and email address without further consent for non-marketing or administrative purposes (such as notifying you of major updates, customer service needs, tips on using the Service, notifications of unused features of the Service, or items for which you have requested communication).

Legal and Similar Disclosures

We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) comply with the law; (iv) investigate, prevent, take action, or enforce compliance with regard to a violation of the EULA or this Privacy Policy; (v) investigate, prevent or take action regarding illegal activities or suspected fraud; or (vi) protect your, our, or others’ rights, property, or safety.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the bottom of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the CartoLake website and through the FlightBagX app.

Retention of Personal Data

We will retain your personal data as long as your FlightBagX account is active. You may request deletion of your account and associated personal data at any time by emailing crew@flightbagx.com.

Data Controller

The personal data collected by CartoLake is controlled by CartoLake LLC at 121 Cassidy Point Drive, Suite LL2, Portland, ME 04102, which you can also contact by email at crew@flightbagx.com.

Your Rights in California

This section applies solely to the personal data of users who reside in the State of California ("consumers" or "you") and supplements the information contained in CartoLake's Privacy Policy. We have included this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights and Choices: The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights. You have the right to request that CartoLake disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information, if any; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Deletion Request Rights. You have the right to request that CartoLake delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (vi) engage in public or peer-reviewed research in accordance with Section 1798.105 (d)(6) of the CCPA; (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (viii) comply with a legal obligation; or (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it. Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: E-mail: crew@flightbagx.com or write to us at the address listed above. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you goods or services; (ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. Contact Information: If you have any questions or comments about this notice, the ways in which CartoLake collects and uses your information described in this section, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: crew@flightbagx.com or write to us at the address listed above.

Last updated: September 2026