Flycomm App Privacy Notice

Effective date: 20 October 2026

At a glance

1. Who we are and what this Notice covers

1.1 This App Privacy Notice (the "Notice") explains how Flycomm Networks Ltd., company no. 516202223, of 21 HaVa'ad HaLe'umi St., Jerusalem, Israel ("Flycomm", "we", "us") processes data collected through the Internet Speed Test by Flycomm mobile application for Android (the "App"). Flycomm is the controller of that data.

1.2 The same categories of data are collected by the Flycomm software development kit (the "SDK") when it is integrated into applications published by other companies. If you use such an application, the publisher's privacy policy applies to that application, and this Notice (together with the SDK Data Notice) applies to the data the SDK sends to Flycomm.

1.3 This Notice does not cover the Flycomm website or the Flycomm Platform used by our business customers, which have their own notices.

1.4 This Notice is written on the basis that the App is designed so that the data it collects does not identify you. Whether that data is nevertheless "personal data" under a particular law is a legal question that depends on the context; we therefore describe our processing in full and give you the information and the contact points that data-protection law requires, whatever the answer.

2. What the App collects

2.1 What we do not collect. The App does not collect or store your name, telephone number, email address, contacts, messages, the content of calls or communications, browsing or app-usage history, photos or files, your advertising identifier, IMEI, IMSI or MEID, Android ID, SIM serial number, the Wi-Fi hardware address of your own device, or any other identifier intended to identify you or your device persistently. The App does not ask you to create an account or to sign in.

2.2 No profiles. Our systems are designed not to link one session to another and not to build a profile of any user or device.

3. Why we use the data

3.1 We use the data collected by the App for the following purposes:

• Coverage intelligence. Building maps and statistics of mobile-network and Wi-Fi coverage, signal quality and network performance; identifying the location and configuration of network infrastructure; and powering planning, simulation and reporting tools that we provide to mobile operators, infrastructure and tower companies, system integrators, public bodies and other organisations through the Flycomm Platform.
• Operating and securing the service. Receiving, validating and storing measurements; detecting and discarding measurements that appear to be falsified, duplicated or generated by emulators or mock-location tools; protecting our servers against abuse; and diagnosing errors in the App.
• Research and improvement. Training, testing and improving the statistical and machine-learning models that turn measurements into coverage estimates, and improving the App itself.
• Legal purposes. Complying with legal obligations, responding to lawful requests, and establishing, exercising or defending legal claims.

3.2 We do not use the data to identify, track or profile you or any other individual, to show you advertising, or to make decisions about you. We do not sell personal data, and we do not use the data to locate any particular person.

4. Legal basis

4.1 Israel. We collect the data with your consent, which you give by enabling the App's location permission after reading the in-app disclosure and this Notice, and we process it for the purposes notified here, in accordance with Section 11 of the Protection of Privacy Law, 5741-1981 ("PPL"). See Section 15.1.

4.2 EEA and UK. Where the GDPR applies, our legal basis for collecting location and network data through the App is your consent (Art. 6(1)(a)), which is also the basis required by the rules on storing or accessing information on your device (Article 5(3) of Directive 2002/58/EC and its national implementations). You give consent through the Android permission prompts and the in-app disclosure, and you may withdraw it at any time by changing the App's permissions or uninstalling it. We rely on our legitimate interests (Art. 6(1)(f)) to secure the service, to detect falsified data and to improve our models using data already collected, and on legal obligations (Art. 6(1)(c)) where they apply.

4.3 Singapore. Where the PDPA applies, we collect, use and disclose the data with your consent, after notifying you of the purposes in Section 3, and we rely on the exceptions in the PDPA where they apply.

4.4 California. Where the CCPA applies, this Notice serves as our notice at collection; see Section 15.4.

4.5 Where the data collected through the App does not relate to an identifiable person and is therefore outside the scope of these laws, we nevertheless apply the safeguards described in this Notice.

5. How the App's design limits identification

5.1 No direct identifiers. As described in Section 2, the App does not collect names, contact details, account identifiers or persistent device identifiers, and it has no login.

5.2 Session-based identifiers. Measurements are grouped under a technical session identifier that is created when the App connects and is not reused. Our systems are designed not to link sessions to one another and not to maintain any user or device profile.

5.3 Further technical and organisational measures. We apply measures intended to reduce the risk that measurements could be attributed to an identified or identifiable person, including through combination with other information. The App collects no account, name, contact details or advertising identifier; all transfers are encrypted in transit (TLS); measurements are stored in access-controlled cloud databases with encryption at rest and role-based permissions; access is logged and monitored; customers and partners receive data under written contracts that prohibit attempts at re-identification.

5.4 Wi-Fi access points. Access-point identifiers are used only to associate Wi-Fi signal readings with a physical access point for coverage mapping. We do not use them to identify the owner of a network, and we exclude networks whose name ends in "_nomap", which is the widely recognised way for a network owner to opt out of location-mapping services.

5.5 Contractual safeguards. Our customers and partners who access measurement data through the Flycomm Platform are bound by terms that prohibit them from using the data to identify, locate, track or profile any individual or device, and from attempting to re-identify anyone.

5.6 What we do not claim. We do not claim that location-tagged measurement data can never be associated with a person under any circumstances. Our commitment is to collect no identifiers, to apply the safeguards above, to keep improving them, and to treat the data with the care that personal data would require.

6. Who we share the data with

6.1 Customers and partners, through the Flycomm Platform. Mobile operators, infrastructure and tower companies, system integrators, public bodies and other organisations that subscribe to the Flycomm Platform can view measurement data for the geographic areas they analyse. They see it as aggregated maps and statistics and, for radio-network analysis, as individual measurement records (location, time and signal readings) that contain no identifiers. They are bound by the restrictions described in Section 5.5. Partners may also receive the data to resell Flycomm services under their own brand, on the same terms.

6.2 Service providers. Companies that host our servers and databases, provide infrastructure and security services, and help us analyse data, acting on our instructions under written contracts: Amazon Web Services (hosting and storage, US East (Ohio) region); ClickHouse Cloud (analytics database); Cloudflare (network security, content delivery and speed-test servers); Google (Firebase Crashlytics and Analytics, Google Maps and Play services); Coralogix (logging and monitoring, EU); Base44 (hosting of the indoor-mapping service used in Pro mode, Google Cloud, US West).

6.3 Research collaborators. We may share measurement data, in aggregated form or under written agreements that include the restrictions in Section 5.5, with universities and research institutions studying wireless networks.

6.4 Authorities and legal process. Where required by law, regulation or legal process, or to protect the rights, property or safety of Flycomm, our users or others.

6.5 Corporate transactions. A buyer, investor or successor (and their advisers) in connection with a merger, financing, acquisition, reorganisation or sale of assets, subject to continued protection under this Notice.

6.6 We do not sell personal data and we do not share the data for advertising. Where the CCPA applies, see Section 15.4 on our public commitment regarding de-identified data.

7. International transfers

7.1 Flycomm is established in Israel and hosts the service in Amazon Web Services, US East (Ohio) region. Our customers and partners are located in Israel, Singapore, the United States, Japan, Europe and other countries, and they may access measurement data from those countries through the Platform.

7.2 Israel is recognised as providing adequate protection by the European Commission (Decision 2011/61/EU, confirmed in January 2024) and by the United Kingdom. Where personal data is transferred from the EEA or the UK to a country not recognised as adequate, we rely on the European Commission's Standard Contractual Clauses (with the UK Addendum or International Data Transfer Agreement where relevant). Transfers out of Israel comply with the Protection of Privacy (Transfer of Data to Databases Abroad) Regulations, 5761-2001, and transfers out of Singapore comply with the PDPA's transfer limitation obligation. Copies of the safeguards are available on request.

8. How long we keep the data

9. Your choices and rights

9.1 Your choices. You control collection through your device:

• Location permission. In Android settings you can allow precise location "all the time", "only while using the app", or not at all, and you can change this at any time. Without precise location the App cannot take measurements. You can stop all measurement at any time by choosing 'Exit' in the App's menu, which stops background monitoring. In Advanced Mapping you can lower the sampling rate and set background speed tests to 'None'.
• Wi-Fi measurement. Wi-Fi measurement runs only in Pro indoor-mapping mode and only after you accept the in-app prompt. You can decline the prompt, or revoke the 'Nearby devices' permission in Android settings.
• Uninstalling the App stops all collection immediately.

9.2 Your rights. Depending on where you live, data-protection law gives you rights of access, rectification, erasure, restriction, objection, portability and withdrawal of consent, and the right to complain to a supervisory authority (PPL Sections 13 and 14; GDPR Articles 15 to 21; PDPA Sections 21 and 22; CCPA rights to know, delete, correct, opt out and limit). Section 15 lists the rights available in each region.

9.3 Why we usually cannot find "your" data. The App collects no name, account or persistent device identifier, so we have no way of knowing which measurements came from you. In that situation the GDPR (Article 11) and similar laws do not require us to collect additional information in order to identify you, and the rights of access, rectification, erasure, restriction and portability apply only if you can provide information that enables us to identify the relevant records. If you can — for example the session identifier shown in the App on the Pro screen, together with the dates and places where you used it — we will search for the records concerned and act on your request. We will never ask you to provide identifiers that we would then have to store.

9.4 How to make a request. Email legal@flycomm.co or write to the address in Section 14. We respond within the period required by applicable law (in general within 30 days; one month under the GDPR, 30 days under the PDPA and 45 days under the CCPA, each extendable where the law allows). We will not discriminate against you for exercising your rights, and we will explain any refusal.

10. Children

The App is not directed to children, and we do not knowingly collect data from anyone under 18 years of age. If you believe that a child is using the App, please contact us; because of the App's design we may not be able to locate the child's data, but we will investigate and, where possible, delete it.

11. Google Play disclosures

11.1 Prominent disclosure. Before the App requests location permission, it shows you an in-app disclosure explaining that it collects location data to enable measurement of network coverage, including in the background when the App is closed or not in use (if you allow background access), and that the data is shared with Flycomm's customers and partners in a form designed not to identify you. The App requests the permission only after you accept that disclosure, in accordance with Google Play's User Data policy.

11.2 Data safety section. The information in the App's Google Play Data safety section is intended to be consistent with this Notice.

11.3 Google's own processing. Google Play, Google Play services and the Android operating system collect data about your device and App usage under Google's privacy policy, independently of Flycomm.

12. Security

12.1 Measurements are sent from the App to our servers over encrypted connections (TLS) and stored on infrastructure with access controls, logging, network separation and encryption at rest. Access to measurement records is limited to personnel and systems that need it, and customer access through the Platform is governed by role-based permissions and contractual restrictions. We maintain these measures in accordance with the Israeli Protection of Privacy (Data Security) Regulations, 5777-2017, and the security requirements of the GDPR and the PDPA.

12.2 Where we are required by law to notify a regulator or affected individuals of a security incident, we will do so without undue delay; because measurements carry no contact details, individual notification may not be possible, in which case we will publish a notice on our website at flycomm.co/app/privacy-policy and, where feasible, in the App.

13. Changes to this Notice

We may update this Notice from time to time, for example when the App collects a new category of data or when the law changes. The current version, with its effective date, is available in the App and on Google Play. Where a change materially expands what we collect or how we use it, we will show you the change in the App and, where the law requires, ask for your consent again before the change applies to you.

14. Contact and complaints

14.1 Controller: Flycomm Networks Ltd., 21 HaVa'ad HaLe'umi St., Jerusalem, Israel.

14.2 Privacy contact: legal@flycomm.co.

14.3 Supervisory authorities. You may complain to the Israeli Privacy Protection Authority; in the EEA, to the supervisory authority of your member state of residence, work or alleged infringement; in the UK, to the Information Commissioner's Office; in Singapore, to the Personal Data Protection Commission; and in California, to the California Privacy Protection Agency or the Attorney General. We would welcome the opportunity to address your concern first.

15. Regional annex

15.1 Israel — notice under Section 11 of the Protection of Privacy Law

In accordance with Section 11 of the PPL (as amended by Amendment No. 13), we inform you that: you are under no legal obligation to allow the App to collect data; collection depends on your free will and consent, given by enabling the location permission, and the only consequence of refusing is that the App will not take measurements; the data is collected for the purposes in Section 3 and held in Flycomm's databases; it may be transferred to the recipients in Section 6 for the purposes stated there, including customers and partners outside Israel; the controller of the database is Flycomm Networks Ltd., 21 HaVa'ad HaLe'umi St., Jerusalem, contact legal@flycomm.co; and, to the extent the data constitutes "information" about you under the PPL and can be located, you have the rights of access (Section 13), correction and deletion (Section 14) and the right to complain to the Privacy Protection Authority. The databases are maintained in accordance with the Protection of Privacy (Data Security) Regulations, 5777-2017.

15.2 European Economic Area and United Kingdom

• Controller: Flycomm Networks Ltd., Jerusalem, Israel.
• Legal bases: consent for the collection of location and network data through the App and for storing or accessing information on your device; legitimate interests for security, fraud detection and model improvement; legal obligation where applicable (Section 4.2).
• Withdrawal of consent: at any time, by changing the App's permissions or uninstalling it, without affecting processing before withdrawal.
• Rights: Articles 15 to 21 GDPR, subject to Article 11 as explained in Section 9.3; the right to lodge a complaint with your supervisory authority (Section 14.3).
• Transfers: Section 7. Israel benefits from an EU and a UK adequacy decision.
• Automated decision-making: none with legal or similarly significant effects.

15.3 Singapore

• Data Protection Officer: Legal and Privacy function, Flycomm Networks Ltd., 21 HaVa'ad HaLe'umi St., Jerusalem, Israel, reachable at the privacy contact in Section 14.
• We notify you of the purposes in Section 3 before collection, and collect, use and disclose the data with your consent, given by enabling the location permission. You may withdraw consent at any time by changing the App's permissions or uninstalling it.
• Access and correction requests are handled as described in Section 9.3; where we cannot locate records relating to you, we will tell you so.
• We retain the data only as long as necessary (Section 8) and transfer it outside Singapore only in accordance with Section 7.
• You may complain to the Personal Data Protection Commission.

15.4 California — notice at collection and CCPA disclosures

This Section applies to California residents to the extent Flycomm is a "business" under the CCPA and the data collected through the App is "personal information".

• Sources and purposes: Sections 2 and 3. Disclosed for business purposes to: the recipients in Section 6. Retention: Section 8.
• Sensitive personal information. We use precise geolocation only to perform the service you requested (measuring network coverage where you are) and for the other purposes permitted without the right to limit under the CCPA regulations. We do not use it to infer characteristics about you.
• No sale or sharing. We do not sell personal information and do not share it for cross-context behavioural advertising. Measurement data made available to customers is de-identified as described below.
• De-identified data commitment. To the extent the measurement data we provide to customers and partners is de-identified information under Cal. Civ. Code § 1798.140(m), Flycomm takes reasonable measures to ensure that it cannot be associated with a consumer or household, publicly commits to maintain and use it only in de-identified form and not to attempt to re-identify it (except to test the effectiveness of our de-identification), and contractually obliges recipients to comply with the same requirements.
• Your rights: to know, to delete, to correct, to opt out of sale or sharing (not applicable), to limit the use of sensitive personal information (not applicable to the uses described above) and not to be discriminated against. Because we hold no identifiers, we will ask you for information that enables us to locate records relating to you, as explained in Section 9.3. Submit requests to legal@flycomm.co; an authorised agent may act for you with your written permission.
• Under California's "Shine the Light" law we do not disclose personal information to third parties for their direct-marketing purposes.