Acceptable Use Policy

Purpose

Virtower provides airport operations intelligence, aircraft activity monitoring, airspace awareness, operational analytics, reporting, and related services designed to support airport management, planning, safety, infrastructure development, and operational decision-making.

The Virtower platform enables airport operators to better understand aircraft activity and airspace utilization, support data-driven planning initiatives, enhance situational awareness, improve operational efficiency, and provide objective information for operational and capital investment decisions.

This Acceptable Use Policy (“Policy”) establishes the requirements for authorized users accessing Virtower services, systems, reports, analytics, sensor networks, and related information.

Authorized Use

Virtower services may be used only by individuals authorized by the Airport Sponsor. Authorized users may include:

• Airport management personnel
• Airport operations personnel
• Airport planners
• Airport consultants
• Airport engineers
• Authorized contractors
• Governing board members
• Government agencies funding or sponsoring the service
• Other individuals approved by the Airport Sponsor

Users shall access Virtower information solely for legitimate airport operational, planning, safety, infrastructure, security, regulatory, and administrative purposes.

Appropriate Uses of Virtower Information

Virtower information may be used to support:

• Airport operational awareness
• Airfield and terminal planning
• Airport Master Plans
• Airport Layout Plans (ALP)
• Capital Improvement Programs (CIP)
• FAA grant applications
• Project justification and funding support
• Airport Safety Management Systems (SMS)
• Aircraft activity analysis
• Airspace utilization studies
• Remote ID-equipped UAS monitoring
• Environmental and noise studies
• Airport operational reporting
• Emergency preparedness and response
• Airport Security Plan implementation
• Airport infrastructure planning and development

Restrictions on Revenue Collection and Fee Enforcement

Virtower services are intended to support airport operational awareness, planning, safety, infrastructure development, airspace awareness, and related airport management activities.

Unless expressly authorized by applicable law, regulation, ordinance, airport rule, lease agreement, operating agreement, or other legally enforceable authority within the Airport Sponsor's jurisdiction, information generated by the Virtower platform shall not be used by the Airport Sponsor, airport tenant, consultant, contractor, governmental entity, or any other third party as the sole basis for assessing, invoicing, collecting, enforcing, or attempting to collect landing fees, access fees, operational fees, penalties, fines, charges, or similar assessments against aircraft owners, operators, pilots, passengers, tenants, or other parties.

Virtower does not determine the legality, validity, or enforceability of any airport fee, charge, assessment, or revenue collection program. Responsibility for compliance with applicable federal, state, and local laws governing airport fees, airport revenue, and revenue collection practices rests solely with the Airport Sponsor.

Virtower information may be used to support airport planning, operational analysis, infrastructure development, grant applications, project justification, traffic studies, airspace utilization assessments, safety initiatives, and other legitimate airport purposes. However, Virtower information shall not be represented as an official FAA record, regulatory determination, or legal basis for fee collection where such use is prohibited by law.

Nothing in this Policy prohibits the use of Virtower information to support lawful airport business activities where expressly authorized under applicable law, airport policy, lease agreement, operating agreement, or other legally enforceable authority.

Virtower reserves the right to suspend access to reports, data products, or platform features if Virtower reasonably believes that the information is being used in a manner inconsistent with this Policy or applicable law.

Operational Decision Support

Virtower provides situational awareness, operational intelligence, reporting, and analytical tools intended to support airport operations, planning, safety, and security activities. Information provided through the platform is intended to supplement, not replace:

• FAA systems and information services
• Air traffic control communications
• Pilot communications
• Airport Security Plans
• Safety Management Systems
• Airport emergency procedures
• Airport operational procedures
• Regulatory requirements

Users remain responsible for operational, planning, safety, regulatory, and business decisions made using information provided through the platform.

Data Sources and System Information

Virtower aggregates and analyzes information from Virtower-owned sensor networks, Federal Aviation Administration (FAA) data sources, Remote ID broadcasts, and other authorized aviation information sources. While Virtower employs commercially reasonable efforts to maintain reliable information, users acknowledge that data may be affected by:

• Equipment outages
• Communication interruptions
• Signal limitations
• Environmental conditions
• Third-party data source availability
• Aircraft equipment performance
• Network connectivity issues

Service interruptions resulting from loss of power, internet connectivity, facility access restrictions, environmental conditions, airport infrastructure failures, or other factors outside Virtower's control may temporarily reduce the availability, accuracy, or functionality of Virtower services. Virtower information should be considered a decision-support resource and not a guaranteed source of complete or uninterrupted operational information.

Airport Data Rights

The Airport Sponsor retains perpetual rights to use, reproduce, distribute, and rely upon airport-specific reports, dashboards, summaries, analytics, and other work products generated through the Virtower platform for airport operational, planning, safety, infrastructure development, grant administration, regulatory compliance, project justification, and other legitimate airport purposes. Airport-specific reports may be shared with:

• Airport employees
• Airport consultants
• Airport engineers
• Airport planners
• Airport governing boards
• Regulatory agencies
• Government agencies funding or sponsoring the service
• Other parties authorized by the Airport Sponsor

Virtower retains ownership of its software, databases, sensor networks, methodologies, algorithms, proprietary systems, and underlying intellectual property.

Confidentiality and Sensitive Information

Users acknowledge that Virtower may provide access to information relating to airport operations, aircraft activity, airspace monitoring, airport infrastructure, operational trends, security-related observations, and critical infrastructure. Such information should be treated as sensitive operational information and shared only with individuals who have a legitimate operational, planning, safety, security, or regulatory need to know. Users shall not disclose airport-specific information to unauthorized third parties.

Airport Security Plan Integration

Virtower's airspace awareness, monitoring, alerting, reporting, and analytical capabilities support airport operational awareness and security objectives. Airport Sponsors are encouraged to incorporate Virtower services, sensor systems, monitoring capabilities, operational procedures, response procedures, and alerting protocols into their Airport Security Plan (ASP) and related airport security documentation.

The parties acknowledge that information generated through Virtower services may contain sensitive airport operational information, security-related information, airspace monitoring information, and critical infrastructure information that could adversely affect airport operations, public safety, or airport security if improperly disclosed. Users should handle such information in accordance with applicable airport security policies, procedures, and legal requirements.

Public Records and Information Requests

Virtower provides continuous 24-hour situational awareness and operational monitoring capabilities. Certain information available through the platform may not otherwise be publicly available and may include sensitive operational, security-related, or infrastructure information.

Virtower shall not release, disclose, sell, distribute, or provide airport-specific operational data to any third party except:

• With authorization from the Airport Sponsor;
• As required by law, court order, subpoena, or lawful governmental request;
• When reasonably necessary to preserve life, protect public safety, or respond to an emergency;
• To authorized consultants, engineers, planners, contractors, or professional service providers acting on behalf of the Airport Sponsor; or
• To governmental agencies funding, sponsoring, administering, or paying for the service on behalf of the Airport Sponsor.

Users should coordinate any public records request, Freedom of Information Act (FOIA) request, sunshine law request, or similar disclosure request with the Airport Sponsor and appropriate legal counsel before releasing Virtower-generated information.

To the fullest extent permitted by applicable law, information generated through the Virtower platform and incorporated into an Airport Security Plan or supporting security documentation should be treated as sensitive operational and security information and protected from public disclosure where exemptions or protections are available. Nothing in this Policy shall require the disclosure of information that is exempt from disclosure under applicable public records laws, Freedom of Information laws, Sensitive Security Information (SSI) protections, critical infrastructure protections, law enforcement sensitive information protections, or other applicable legal exemptions.

Airport Sponsor Support Responsibilities

To support the reliable operation of Virtower services, the Airport Sponsor shall make a good-faith effort to provide and maintain reasonable access to electrical power, internet connectivity, and any other infrastructure reasonably necessary for the operation of Virtower-owned sensors, equipment, or services located at the airport. The Airport Sponsor shall make reasonable efforts to:

• Maintain continuous commercial power to Virtower-installed equipment.
• Maintain internet connectivity required for data transmission and system operation.
• Notify Virtower of known outages, service interruptions, or facility changes that may affect service performance.
• Provide reasonable access to equipment locations when maintenance or repairs are required.
• Protect Virtower-owned equipment from unauthorized access, tampering, or damage when such equipment is located on airport property.

The Airport Sponsor acknowledges that interruptions to electrical power, internet connectivity, or supporting infrastructure may adversely affect the availability, performance, accuracy, or continuity of Virtower services. Nothing in this Policy shall be interpreted as requiring the Airport Sponsor to guarantee uninterrupted utility or network services. The Airport Sponsor's obligation under this section is limited to making reasonable and good-faith efforts to support the continued operation of the Services.

User Account Security

Users are responsible for maintaining the security of their accounts and credentials. Users shall:

• Protect passwords and authentication credentials.
• Prevent unauthorized access to their accounts.
• Report suspected unauthorized access promptly.
• Log out of shared or public devices after use.
• Follow airport cybersecurity requirements.

Users may not share user credentials with unauthorized individuals.

Prohibited Activities

Users shall not:

• Share user credentials.
• Provide system access to unauthorized individuals.
• Attempt to bypass security controls.
• Reverse engineer, copy, duplicate, or recreate Virtower systems.
• Modify, relocate, tamper with, or interfere with Virtower-owned equipment.
• Use Virtower information for unlawful purposes.
• Publicly distribute airport-specific information without authorization.
• Misrepresent Virtower information or analyses.
• Use the platform in a manner that could adversely affect airport operations, public safety, or security.

User Responsibilities

Users are responsible for:

• Maintaining account security.
• Protecting sensitive information.
• Following airport security policies.
• Following airport cybersecurity policies.
• Reporting suspected unauthorized access.
• Using Virtower information responsibly and professionally.
• Complying with applicable laws, regulations, and airport procedures.

Users shall exercise sound professional judgment when using information provided through the Virtower platform.

Virtower Contact Information

Questions regarding this Policy, authorized use of Virtower services, data access, security concerns, operational support, or requests relating to Virtower information should be directed to:

Virtower may periodically update its contact information and support resources. Users should refer to current Virtower communications for the most up-to-date contact information.

Policy Updates

Virtower may periodically update this Acceptable Use Policy to address operational, security, regulatory, technological, or business requirements. Airport Sponsors and authorized users are encouraged to review the current version of this Policy periodically. Continued use of Virtower services constitutes acceptance of the current version of this Policy.

User Acknowledgement

By accessing, viewing, receiving, or using information available through the Virtower platform, the user acknowledges that they have read and understand this Acceptable Use Policy and agree to comply with its requirements. Access to Virtower services constitutes acceptance of this Policy and any updates issued by Virtower or the Airport Sponsor.

The Airport Sponsor is responsible for ensuring that authorized users are informed of and comply with this Policy.