Legal

This California Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to the Personal Information of certain California residents, who are Consumers receiving products or services for which we are a Business, as those terms are defined under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (the “CCPA”), .

Any capitalized terms herein are intended to have the same meaning as in the CCPA.

California Consumers’ Rights and Choices

If you are a Consumer, California law may permit you to request information regarding the:

• Categories of Personal Information (as defined by applicable California law) collected, Sold, Shared or disclosed by us;
• Purposes for which categories of Personal Information collected by us are used;
• Sources of information from which we collect Personal Information;
• The categories of third parties to whom we disclosed Personal Information; and
• Specific pieces of Personal Information we have collected about you.

In addition, if you are a Consumer you may

• Opt-out of Sale or Sharing of your Personal Information for cross-context behavioral advertising purposes. We do not sell or share your Personal Information as those terms are defined under California law;
• Opt-in to certain financial incentive programs we may offer related to the collection, Sale, Sharing or deletion of your Personal Information;
• Request deletion of your Personal Information by us and our Service Providers, in some circumstances;
• Correct inaccurate Personal Information that we maintain about you; and
• Limit the use of sensitive Personal Information. Under the California laws, you can limit the use and disclosure of your sensitive Personal Information to certain purposes specified by law. We only use or disclose sensitive Personal Information for such permitted purposes, so we do not provide an opt out.

Further, California law provides Consumers with the right not to receive discriminatory treatment by a Business for the exercise of these rights regarding Personal Information.

Personal Information, Collection, Disclosure, Sale and Sharing

In the past twelve months since this notice was last updated, we may have collected the following categories of information about you directly or indirectly from you or our affiliates through your use of the Elm Tree Limited Products and Services:

• Identifiers, such as your name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name. We collect such information (1) directly from you, e.g., forms you complete or products and services you purchase, (2) indirectly from you, e.g., from observing your actions on our website or from your devices, or (3) directly from our affiliates. We use such information for our business purposes, including specifically:

  (1) Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

  (2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  (3) Debugging to identify and repair errors that impair existing intended functionality.

  (4) Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

  (5) Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

  (6) Undertaking internal research for technological development and demonstration.

  (7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Data analytics providers.
  ▪️ Vendors and Service Providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Categories of Personal Information in Cal. Civ. Code Section 1798.80(e),
  such as your name, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. We collect such information (1) directly from you, e.g., forms you complete or products and services you purchase, or (2) directly from our affiliates. We use such information for our business purposes, including specifically:

  (1) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  (2) Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on behalf of the Business or Service Provider.
  (3) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.
  (4) If you are applying for a position at Elm Tree Limited, we may use your information for the purposes of recruiting talents for us or our affiliates.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Data analytics providers.
  ▪️ Vendors and Service Providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.

  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Characteristics of Protected Classifications under California or Federal Law, such as gender. We collect such information (1) directly from you, e.g., forms you complete, or (2) directly from our affiliates. We use such information for our business purposes, including specifically:

  (1) Showing your user profile with information you voluntarily provided to us by submitting online forms;
  (2) Recruiting talents for us or our affiliates.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Data analytics providers.
  ▪️ Vendors and Service Providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We collect such information (1) directly from you, e.g., forms you complete or products and services you purchase, (2) indirectly from you, e.g., from observing your actions on our website or from your devices, or (3) directly from our affiliates. We use such information for our business purposes, including specifically:

  (1) Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, verifying quality of customer services, and auditing compliance with product specifications and other standards.
  (2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  (3) Debugging to identify and repair errors that impair existing intended functionality.
  (4) Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, locating past service history.
  (5) Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.
  (6) Undertaking internal research for technological development and demonstration.
  (7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Data analytics providers.
  ▪️ Vendors and Service Providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Internet or Other Electronic Network Activity Information, such as browsing history, search history, and information regarding a Consumer’s interaction with an internet website, application or advertisement. We collect such information (1) directly from you, e.g., forms you complete or products and services you purchase, (2) indirectly from you, e.g., from observing your actions on our website or from your devices, or (3) directly from our affiliates. We use such information for our business purposes, including specifically:
  (1) Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  (2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  (3) Debugging to identify and repair errors that impair existing intended functionality.
  (4) Performing services on behalf of the Business or Service Provider, including verifying customer information, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.
  (5) Undertaking internal research for technological development and demonstration.
  (6) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Data analytics providers.
  ▪️ Vendors and Service Providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Geolocation Data, such as precise physical location and approximate location. We collect such information (1) directly from you, e.g., products and services you purchase, (2) indirectly from you, e.g., from observing your actions on our website or from your devices. We use such information for our business purposes, including specifically:

  (1) Performing services on behalf of the Business, including providing you with map services and UAS safety/regulatory notifications, finding your lost Elm Tree Limited Products, unlocking geofencing features in designated areas, and providing customer services.
  (2) Debugging to identify and repair errors that impair existing intended functionality.
  (3) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business, including retaining records relating to your geofencing unlock decisions.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Data analytics providers.
  ▪️ Vendors and Service Providers.
  ▪️ Social networks.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Affiliates.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.
  ▪️ Other third parties for whom we have obtained your permission to disclose your Personal Information.

• Sensory Information, such as audio, electronic, visual, thermal, or similar information. We collect such information directly from you, e.g., products and services you purchase. We use such information for our business purposes, including specifically, performing services on behalf of the Business or Service Provider, including providing customer service.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.

• Professional or employment-related information, such as job application or resume information, past and current job history, and job performance information, unless exempt. We collect such information directly from you, e.g., forms you complete or products and services you purchase. We use such information for our business purposes, including specifically, recruiting talents for us or our affiliates.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Affiliates.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.

• Inferences Drawn from Personal Information, such as Consumer profiles reflecting a Consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We collect such information indirectly from you, e.g., from observing your actions on our website or from your devices. We use such information for our business purposes, including specifically:

  (1) Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  (2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  (3) Debugging to identify and repair errors that impair existing intended functionality.
  (4) Undertaking internal research for technological development and demonstration.
  (5) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Data analytics providers.
  ▪️ Affiliates.
  ▪️ Third parties integrated into our services.
  ▪️ Third parties as required by law and similar disclosures.
  ▪️ Third parties in connection with a merger, sale, or asset transfer.

• Sensitive Personal Information: account log-in and precise geolocation data. We collect such information directly from you, e.g., from your account registration, or indirectly from you, e.g., from your device. We use such information for our business purposes, including specifically:
  ▪️ Performing services on behalf of the Business.
  ▪️ Helping to ensure security and integrity to the extent the use of the Consumer’s Personal Information is reasonably necessary and proportionate for these purposes.

  In the past twelve months, we may have disclosed such information to:
  ▪️ Vendors and Service Providers.

Such information may be used for the purposes for which it was collected or as otherwise permitted or required by applicable law.

We have not sold or shared your personal information in the preceding twelve months from the date of last review of this Privacy Policy, do not currently sell or share, and will not sell or share your personal information for twelve months from the date of the last review of this Privacy Policy.

Requests

You can make requests related to your California privacy rights at the attached link. You may also make those requests by email to support@dji.com or in writing to SZ Elm Tree Limited Co., Ltd., 14th Floor, West Wing, Skyworth Semiconductor Design Building, No.18 Gaoxin South 4th Ave, Nanshan District, Shenzhen, China, 518057. Please be aware that we do not accept or process requests through other means (e.g., via fax or social media).

We will review the information provided and may request additional information to ensure we are interacting with the correct individual. If you have an online account with us, you may be required to log-in to your account for identity verification. If you do not have an account with us, additional information to verify your identity may be required by law before we may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.

By law, we are not required to collect Personal Information that we otherwise would not collect in the ordinary course of our business, retain Personal Information for longer than we would otherwise retain such information in the ordinary course of our business, or re-identify or otherwise link information that is not maintained in a manner that would be considered Personal Information. If we have not requested specific additional information from you to verify your request, please do not send such information.

We generally will aim to avoid requesting additional information from you for the purposes of verification. However, if we cannot reasonably verify your identity or more information is needed for security or fraud-prevention purposes, we may consider any of the following factors, alone or in combination, in requesting additional information:

• The type, sensitivity, and value of the Personal Information collected and maintained about the Consumer, as applicable law requires a more stringent verification process for sensitive or valuable Personal Information;
• The risk of harm to the Consumer posed by any unauthorized access or deletion;
• The likelihood that fraudulent or malicious actors would seek the Personal Information;
• Whether the Personal Information to be provided by the Consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;
• The manner in which the Business interacts with the Consumer;
• Available technology for verification; and
• Other factors that may be reasonable in the circumstances, are consistent with industry practice, are recommended by California government officials, or which may be required by law or regulation following the effective date of this Privacy Policy.

If your request is regarding household information, the same verification steps above are required before we can provide you with aggregate household information. For us to process a request for access to or deletion of specific pieces of information regarding your household, all members of the household must make the request, and we must be able to verify each household member.

In some cases, we may not have sufficient information about you or your household to be able to verify your identity or sufficiently differentiate you from another Consumer or household to the degree of certainty required by law, in which case, we will not be able to act upon your request. In such cases, it may be unlikely that we would be able to identify you or your household in the future without collecting significantly more information or seeking to re-identify de-identified information. At this time, we do not intend to take such steps in response to a request made pursuant to this Privacy Policy and applicable law does not require that we do so. If, in the future, we determine a reasonable method to identify you or your household absent such steps, we will provide an update to you through this Privacy Policy and in response to any such request at that time.

Information that you submit for the purpose of allowing us to verify your identity in furtherance of a Consumer-related or household-related request pursuant to California law will only be used by us, and our Service Providers if any, for that purpose and no other. Except where we are required by law to maintain such information for record-keeping purposes, we will take steps to delete any new Personal Information collected for the purpose of verification as soon as practical after processing your request.

Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of Personal Information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request, including, for example, where fulfilling your request may infringe upon the rights and freedoms of other Consumers.

We reserve the right to charge a reasonable fee or take other appropriate action in response to requests from a Consumer or household that are manifestly unfounded or excessive, in particular because of their repetitive character.

You may designate an authorized agent to make a request on your behalf pursuant to applicable law. We accept documentation of your designation in the form of a valid power of attorney and/or a notarized statement. You must submit evidence of your designation of an authorized agent in writing to: SZ Elm Tree Limited Co., Ltd.14th Floor, West Wing, Skyworth Semiconductor Design Building, No.18 Gaoxin South 4th Ave, Nanshan District, Shenzhen, China, 518057. We may require verification of your authorized agent in addition to the information for verification above for Consumers and households.

Do Not Track

Elm Tree Limited does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

Deidentified Information

Where we maintain or use deidentified information, we will continue to maintain and use the deidentified information only in a deidentified fashion and will not attempt to re-identify the information.

Notice of Financial Incentive

With regard to our education discount program, we offer financial incentives to Consumers based upon the retention of sale of a Consumer’s Personal Information calculated based on a good-faith estimate of the value of the Consumer’s data, which forms the basis for offering such financial incentives. The financial incentive offered is a discount on the price of some Elm Tree Limited Products and Services, based on affiliation with an employer group or educational institution with which we partner. The categories of Personal Information that are implicated by the financial incentive or price or service difference include your place of employment or educational institution. You may choose to provide an email address associated with your employer or educational institution, which we will validate manually.

The method we use to calculate the value of a Consumer’s data is that our calculation used in good-faith of the likelihood of increased sales of Elm Tree Limited Products and Services to Consumers at your place of employment or educational institution.