Last Updated: May 18, 2023
- Information We Collect
- How We Collect Your Information
- How We Use the Information Collected
- How We Share Your Information
- How Do We Protect Your Information?
- Consumer Rights Regarding Personal Information
- Other Privacy Choices
- Retention of Personal Information
- Additional Disclosures for Individuals Outside the United States
- Other Important Information
- How to Contact Us
Information We Collect
Legal definitions of personal information can vary across different jurisdictions. We strive to comply with laws in all the jurisdictions where our customers are located, but for purposes of this Policy consider "personal information" to be any information that identifies you as an individual or is directly relatable to an identifiable individual. Not all information we collect is personal information under this definition. For example, information that has been de-identified or aggregated in a way that no longer allows identification of a particular person would not meet this definition.
In order to provide you with our products and services, we may collect, store, and process personal information from the categories shown in the table below. Our listing of these categories does not mean that all categories or the examples listed in each category are collected about everyone who uses the Websites. We are providing a full list here in the spirit of transparency.
- Identifiers: Name; postal address; physical address; telephone number; email address; date of birth; and account password
- Demographic information: Age, national origin, race, citizenship, or gender
- Audio, visual, or similar information: Photos, videos or other recordings you choose to share with us
- Geolocation data: Physical location, including latitude or longitude, and movement data
- Device information: Information about your device and software characteristics; connection information; device brand and model; device operating system; device type; and device Identifier for Advertiser (IFA)
- Commercial information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- Inferences drawn from other information: Any profile created about you that reflects likely preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitude
How We Collect Your Information
Directly from you. We collect personal information directly from you when you provide it to us, for example, when you create an account to use our services; request a demo; submit an inquiry or comment to us online; or sign up to join a mailing list.
Indirectly from you. We may automatically collect personal information from you when you visit the Websites through the use of tracking technologies or by other passive means. This "passively collected" information helps us to improve our offerings and allows us to ensure the services work as designed and in a way that meets your expectations. Some examples of the sources of this passively collected personal information include:
- Viewing History and Preferences. When you browse the Websites, we may collect information about your use. For example, if you search our blog database, particularly while logged into the services, we may collect information about that action and form inferences about what information our users find most helpful.
- Log Information. We may automatically record information that your browser or mobile device sends whenever you access the services, and especially when you are logged into your account. These logs may include information such as, IP address, access times, the referring website, browser type, browser language, your computer operating system, your mobile device and mobile operating system, the name of your Internet service provider or your mobile carrier, and one or more cookies (discussed below) that may uniquely identify your browser.
From third parties. We may collect personal information about you from third parties for our business purposes. These third-party sources vary, but could include the following:
- Social Media Technologies and Similar Third-Party Services. You can link your social media or other third-party account to Aiir as your login for certain portions of the Websites and to facilitate posts to your pages/accounts, to upload photos, and to interact with tweets, posts, and comments available through various platforms. By linking these services, you authorize us to collect, store and use any information they may give us as a result of that connection. You can choose not to use these services and set up your account with us directly or disconnect your Aiir account from these third-party accounts at any time. We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., "likes," comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users' public profiles.
- Payment Processors. Third-party processors (the "Payment Processors") provide us with online e-commerce solutions to process payments through the Websites. When you use these third-party services, your personal information, including payment card numbers and certain identifiers, are collected and stored by the Payment Processors pursuant to their terms and procedures. The Payment Processors store data in a safe and secure manner with access limited to authorized personnel pursuant to the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored by the Payment Processors only as long as is necessary to complete your purchase transaction. We do not see your full payment card number and do not store your payment information. PCI-DSS requirements help ensure the secure handling of payment card information.
- Your Employer or Its Authorized Agents. Because our services are directed at other businesses, most of the people visiting and using our Websites do so on behalf of the company they work for. We may communicate with other people who work for your employer and, as part of those communications, we may be provided with personal information about you. For example, the person who initially sets up the Aiir services for a company may provide us with contact information for someone in the accounts payable department for purposes of paying for the services or contact information for someone in the IT department for purposes of integrating our services with their operations. We may maintain information about all of these persons even though we have not yet communicated with them directly. All of these uses are for our and our clients' business purposes, but out of an abundance of caution we list them here as they are potentially "third-party" sources of information we collect under certain laws.
How We Use the Information Collected
We use your personal information to provide you with services, to operate and improve our Websites, to send you messages, and for other purposes described in this policy or disclosed to you on our Websites or in connection with our services. For example, we may use the information we collect from you on our Websites:
- To create and maintain your Aiir account.
- To personalize and improve your experience on our Websites.
- To respond to comments and questions and provide customer service.
- To deliver service messages and other services and content you request and to send information related to accounts and services, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
- To send you information about new promotions, products, and services offered by Aiir and our selected partners.
- To analyze the performance of promotional efforts.
- To create de-identified or aggregated lists of information for any of the uses stated above.
- To diagnose problems with the Websites and to improve, upgrade or enhance the Websites and our services.
- To comply with legal obligations, resolve disputes and enforce agreements.
- To notify you regarding any concerns with the services, including, as required by law, in the event that personal information you provided to us is exposed to unauthorized third parties.
- To carry out other purposes that are disclosed to you and/or to which you consent.
How We Share Your Information
The categories of personal information that we may have shared for a business or commercial purpose include any of the categories of personal information shown in the table at the beginning of this section. We do not "sell" your information in the traditional sense of the word, but out of an abundance of caution and in light of very broad views of what it means to "sell" information in certain privacy laws, we are disclosing that the ways in which we share information about you could be considered a sale in some jurisdictions. Some examples of ways in which we may share personal information include:
- In the broadest sense of the term, we may "share" personal information with other users when you comment or respond to a post on the Blog or utilize similar publicly viewable interaction features that are made available on the Websites. We think this is self-evident, but out of an abundance of caution and in light of very broad interpretations of what must be disclosed to you in certain privacy laws, we are disclosing this information to you. We generally do not remove such publicly available posts even upon request.
- We may share personal information with third parties that perform services on our behalf, for example, our technical service providers. By using the services, you consent to the processing and handling of your personal information by our service providers in the manner and for the purposes described here and in their respective privacy policies. We will not authorize these third parties to use your personal information except as necessary to provide services to us or for purposes authorized by us.
- Just as we may receive information from your employer about you, we may provide information to your employer for their business purposes related to the services we provide to them.
- Additionally, we may disclose your personal information (1) to comply with a law, regulation or other governmental request, for example, to comply with subpoenas, court orders, legal process or requests by law enforcement or governmental entities; (2) to investigate or defend against third-party claims against us; (3) where we believe the rights, property or safety of Aiir, its users or the public is at risk; (4) to detect, prevent or investigate fraud or other illegal activity or to enforce this policy; (5) to repair or resolve technical issues in the operation of the Websites; (6) if required by law, to respond to a request by you to disclose the information, including a request to allow access to your personal information by third parties designated by you; (7) with your knowledge and consent; (8) to address emergencies or acts of god; and (9) as an asset of the business in the event of a sale, merger or other business combination or transfer involving us or our affiliated entities.
How Do We Protect Your Information?
Aiir takes the security of your personal information seriously. We implement commercially reasonable technical, physical and administrative security measures to protect against the loss, misuse and unauthorized access, disclosure, alteration and destruction of personal information collected through the Websites.
Unfortunately, the transmission of information via the Internet is not completely secure. We cannot and do not guarantee that your personal information will never be accessed by an unauthorized party or otherwise breached during transmission through the Internet. Additionally, any contact with us by email or by way of our Websites might not be secure. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.
In the event that we believe any information that you provided to us has been exposed to unauthorized third parties, we will notify you as required by law or upon our own choice. In the event of such unauthorized exposure, we expressly reserve the right to provide notice to you electronically via any email address you have provide to us if permitted to do so by law. If you have reason to believe that your personal information, including the password you created for access to the Websites, is no longer secure, please notify us immediately by contacting us via one of the methods listed below.
Consumer Rights Regarding Personal Information
Depending on where you live you may have certain privacy rights created by law. While laws vary between jurisdictions, we strive to provide the same basic level of privacy rights to everyone regardless of where you live. Thus, the rights described here may be used by anyone with whom we interact or about whom we collect personal information, subject to the legitimate business needs of customers on whose behalf your information was provided to us.
Right to Know. When you request that we provide you with the information we collect or disclose we will provide you with an individualized response about our collection and use of your personal information. Unless we are required to provide more information by an applicable law in your jurisdiction, that response will be limited to the following:
- Specific pieces of personal information we have collected about you.
- The categories of personal information we have collected (for reference see the table above for categories and examples of personal information that we may collect).
- The sources from which we have collected your personal information.
- Our business or commercial purpose for collecting or selling personal information.
- Whether we have sold your personal information for a business or commercial purpose.
- The categories of third parties to whom we have sold personal information, if any.
Right to Correct. You have the right to ask us to correct inaccuracies in the personal information we have collected, taking into account the nature of the personal information and the purposes of the processing.
Right to Request Deletion. When you request that we delete your personal information, we will delete personal information we maintain about you from our records as of the date of your request subject to certain limitations—primarily those created by our business relationship with your employer. We will also request that any service providers that we know maintain your data on our behalf also delete your personal information. In some cases, deletion may be accomplished through de-identification of the information.
Please note that certain information may be excepted from your deletion request. For example, we may keep your information where necessary to detect and resolve issues related to system security and fraud detection.
Exercising Your Right to Know, Correct or Delete. To exercise the rights to know, correct or delete information described above contact us via our online Contact Us form or by email to firstname.lastname@example.org or write to us at the addresses listed in the How to Contact Us section below.
We cannot respond to your rights requests if we cannot verify your identity or the authority of your agent to make the request and confirm that the personal information we maintain relates to you. When you make a request, we may verify your identity as required by law.
You must also describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. If we have questions regarding your request you must make an effort to respond to our inquiries. If we do not understand your request we may not be able to comply.
Where possible, we will respond to a verified rights request within 45 days of receipt. If we require more time, we will inform you of the reason and the need for an extension. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
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. In certain cases we may contact your employer with this information.
Authorized Agents. You may designate an authorized agent to make requests on your behalf. We will require verification that you did in fact give that person your authorization. Unless the law requires otherwise, your authorized agent must provide contact details for you. We will contact you to confirm that you authorized the agent to act on your behalf. Once you confirm, we will promptly respond to the rights request. Please note, we will not share information about a business customer with anyone not clearly affiliated with that business.
_Non-Discrimination. _We will not discriminate against you for exercising any of the rights listed in this section. Specifically, we will not:
- Deny you or your employer services, except to the extent that not having personal information prevents us from providing the services.
- Provide you or your employer a different level or quality of services, except to the extent that not having personal information limits our ability to provide the services.
- Charge or suggest that we will charge your employer different prices or rates for the services, including through granting discounts or other benefits, or imposing penalties.
Other Privacy Choices
In addition to the rights discussed above, there are various other ways you can choose to access, update, or limit the personal information you provide to us.
- Unsubscribe from Marketing Emails. If you have created an account or registered to use our services and provided us with an email address, we may email you information about enhancements to our systems and product offerings. You may opt-out of receiving those communications by following the "unsubscribe" instructions that are included in our emails.
- Mobile Application Users. You may choose to uninstall our applications from your mobile device and delete the associated data.
- Social Media Accounts. As discussed above, you may be able link your social media or other third-party accounts to your Aiir account. By linking our services to these third-parties, you authorize us to collect, store and use any information they may give us as a result of that connection. You can disconnect your Aiir account from these third-party accounts at any time following the instructions available from those companies.
- Do-Not-Track Disclosure Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Retention of Personal Information
Additional Disclosures for Individuals Outside the United States
If you are located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing. When we process your personal information, we will do so in reliance on the following lawful bases:
- Legal obligation. Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject.
- Contractual relationship. Where it is necessary for us to use your personal information in order to perform a contract to which you are a party or to take steps at your request. An example would be collecting and using your contact information in order to fulfill your purchase orders.
- Legitimate interests. We rely on this basis to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced and does not unduly impact your rights. For instance, it is in our legitimate interest to use personal information to protect the Websites from any attacks and to ensure appropriate security. When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where the use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to do so by law).
- Consent. We may obtain your consent to use your personal information in certain circumstances. We will ensure that when we obtain your consent you are free both to give it and to decline to give it. Additionally, you may always withdraw your consent at any time without any further detriment to you.
Before collecting and/or using any special categories of data (as that term is defined in the EU General Data Protection Regulation, or as an equivalent term is defined by other privacy laws) we will establish a lawful exemption which will allow us to use that information. This exemption will typically be your explicit consent or the establishment, exercise or defense by us or third parties of legal claims.
Data Processing and Cross-Border Information Transfers of Users Outside of the United States. Aiir is aware that there are certain restrictions on the cross-border transfer to the United States of personal information collected from residents of countries located in the European Economic Area ("EEA") and the United Kingdom. As a result, Aiir has made intentional arrangements to store data it processes on behalf of its business clients on servers that are located in Ireland. However, because Aiir is a distributed company with personnel working in the United States, it is possible that when you interact with us (e.g., when you submit a question to us via the "Contact Us" portion of the Websites), information you provide in that format may be viewed or used by personnel in the United States. Please be advised that if you are located in the EEA or another region of the world that restricts data transfers to the United States, the information you provide to us through these sorts of voluntary interactions may not be deemed to have the same level of data protection as that provided by your home country. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer, to the fullest extent allowed under the law. In all such instances where personal information that we process on behalf of our customers is transferred to the United States, we will take all reasonable steps necessary to ensure that appropriate safeguards designed to protect personal information are implemented (e.g., entering into approved standard contractual clauses).
Questions or Complaints. If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
Other Important Information
Eligible Users. Persons accessing the Websites should be clients or potential clients of Aiir's services.
No Use of Websites by Persons Under 16. Aiir is committed to protecting the safety and privacy of young people using the Internet. The Websites are not directed at or intended for use by persons under 16 years old. If you are under the age of 16 you should not be visiting the Websites. We do not knowingly collect or retain personal information from persons under the age of 16. If you are under the age of 16 and are visiting the Websites please exit immediately and do not disclose or provide any information to us. If you are a parent or guardian who thinks your child has disclosed information to us, please contact us so that we can remove that from our systems.
Links to Third Party Websites. Our Websites contain links to other websites. Please be aware that we are not responsible for the privacy practices or content of other websites. If you submit personal information to any of those websites, your information is governed by their privacy statements. We encourage our users to be aware when they leave our Websites and to read the privacy policies of other websites and online services.
We may update or change our privacy practices and this policy from time to time. If we update the policy, we will publish the revised policy on this page or as otherwise required by law. The date at the top of this policy reflects the date of the most recent update. Your continued use of this Website after we make changes is deemed, to the extent allowed by law, to be acceptance of those changes, so please check the policy periodically for updates.
How to Contact Us
Users from the EEA may contact our GDPR Article 27 representative, who is an employee residing within the EEA, at email@example.com or by writing to the attention of the EU Representative at our main corporate address below.
You may write to our Data Protection Officer or EU Representative at:
The Beacon Centre
Users from the United States and other parts of the world may also write to us at:
244 5th Ave #200
New York, NY 10001