Last modified: 10 September 2022
To Whom Does This Policy Apply
Customers: as noted above, this includes any individual who registers individually or on behalf of an entity or organization in order to use the Services.
Site Visitors: visitors to our Site, including those who may also opt in to receive commercial communications from AirCode. This does not include any visitors to our Customers' individual websites.
Event Attendees: AirCode hosts and/or sponsors annual conferences and is an active participant at many other conferences, summits, and additional events (collectively, "Events"), and collects personal information from individuals when they attend (or register to attend) Events.
What Information Do We Collect
What personal information we collect and process depends on how and why you use our Platform. Generally, we process personal information that we receive:
Directly from you when you provide it to us, such as in connection with our Services or Event registrations.
Indirectly, through automated technologies such as cookies, or from third parties.
On behalf of our Customers, when we process the personal data of their End Users as part of our Services.
This is all explained in more detail below.
Information We Collect Directly From You
You can generally visit our Site without having to submit any personal information. If you request more information, or sign up for our Services, we will collect personal information as follows.
Optional Information. We may also ask you to submit personal information if you choose to use interactive features of the Platform, including participation in surveys, promotions, requesting customer support, or otherwise communicating with us.
Information We Collect Indirectly
Device and Usage Information
When you download, use or interact with the Site, even if you do not have an account, we, or authorized third parties engaged by us, may automatically collect information about your use of the Site via your device, some of which is considered personal information. "Device and Usage Information" that we collect consists of:
Information About your Device: information about the devices and software you use to access the Site — primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Site, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size, and other similar technical information.
Usage Information: information about your interactions with the Platform, including access dates and times, hardware and software information, device event information, log data, crash data, cookie data. This information allows us to understand the screens that you view, how you've used the Platform (which may include administrative and support communications with us), and other actions on the Platforms. We, or authorized third parties, automatically collect log data when you access and use the Platform, even if you have not created an account or logged in. We use this information to administer and improve the Services, analyze trends, track users' use of the Platform, and gather broad demographic information for aggregate use.
Note that Device and Usage Information is collected from our community boards, as well as from our Customers' End Users who visit our Customers' websites hosted by AirCode or that use our Services.
Based on Device and Usage Information, we are also able to determine general location information ("Location Information").
Location Information: we use a third-party database to map the general location to which each IP address corresponds ("Location Information"). The Location Information that is mapped from an IP address is limited to country and city – we do not identify precise location. We use Location Information in order to more effectively provide our Services to our Customers. In addition, as part of our Services, we also share Location Information (based on End Users’ IP addresses) to our Customers, so that they may also more effectively provide their products and services to their End Users.
Cookies and Similar Technologies
Information from Third Parties
In some instances, we process personal information from third parties, which consists of data from our partners, such as transactional data from providers of payment services, or information from third parties with whom we host or sponsor Events. In all such cases, individuals are informed of our processing activities and/or able to choose certain preferences at the time of collection. From time to time, we may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered through a AirCode sales submission with information we receive from a third-party sales intelligence platform to enhance our ability to market our Services to Customers or potential Customers.
Information We Process on Behalf of Our Customers
As noted above, we deploy and host websites and provide other analytics tools for our Customers. These Customers may collect personal information from their End Users in connection with the products or services that they offer to End Users. Because we host our Customers' websites and provide other analytics tools, we process End Users' information when they use our Customers' websites, web applications, and APIs. This information may also include, but is not limited to, IP addresses, system configuration information, and other information about traffic to and from Customers' websites (collectively, the "Log Data"), as well as Location Information derived from IP addresses. We do not, however, collect or process End Users’ IP addresses through the use of our analytics Services. All of this information is stored on our Platform as part of our Services, but Customers are responsible for the content transmitted across our network (e.g., images, written content, graphics, etc.), as well as any personal information they collect. Customers are also solely responsible for notifying their End Users of their personal information collection, use, and disclosure. With respect to Log Data, we collect and use Log Data to operate, maintain, and improve our Services in performance of our obligations under our Customer agreements. For example, Log Data can help us to detect new threats, identify malicious third parties, and provide more robust security protection for our Customers. It also helps us with improving our Platform, as explained below.
With the Device and Usage Information collected by our third-party analytics services, such as Google Analytics, as well as Log Data, we generate and process aggregated information, such as statistical or demographic data. Aggregated Information may be derived from personal data, but may not considered personal data if it does not directly or indirectly reveal your identity. For example, we may track the total number of visitors to our Platform, or review Log Data, or track the number of visitors to each page of our Site. We aggregate this data to calculate the percentage of users accessing a specific feature of the Platform and analyze this data for trends and statistics.
We do not directly collect your payment information and we do not store your payment information. We use third-party, PCI-compliant, payment processors, which collect payment information on our behalf in order to complete transactions. While our administrators are able to view and track actual transactions via customer portals, we do not have access to, or process, your credit card information.
Interactive and Public Spaces
The Platform may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features ("Interactive and Public Spaces"). If you choose to participate in any of these Interactive and Public Spaces, please be aware that any information that you post may be read, collected, and used by others who access it. If you wish to remove your personal information from any of our Interactive and Public Spaces, please contact us.
How Do We Use Personal Information That We Collect
We use your personal information for a number of different reasons, as further explained below.
In addition, for users located in the EEA and the UK, we must have a valid legal basis in order to process your personal data. The main legal bases under the European Union's General Data Protection Regulation (GDPR) that justify our collection and use of your personal information are:
Performance of a contract — When your personal information is necessary to enter into or perform our contract with you.
Consent — When you have consented to our use of your personal information via a consent form (online or offline).
Legitimate interests — When we use your personal information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal obligation — When we must use your personal information to comply with our legal obligations.
Legal claims — When your personal information is necessary for us to defend, prosecute or make a claim.
Below are the general purposes and corresponding legal bases (in brackets) for which we may use your personal information:
- Providing you access to and use of the Platform [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims].
- Processing and completing transactions, and sending you related information, including purchase confirmations and invoices and important notices [depending on the context, performance of a contract or legitimate interests].
- Responding to your queries and requests, or otherwise communicating directly with you [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims].
- Improving the content and general administration of the Platform, including system maintenance and upgrades, enabling new features and enhancing both Site Visitor and Customer experience [legitimate interests].
- Detecting fraud, illegal activities or security breaches [legitimate interests].
- Providing our Services to our Customers [depending on the context, performance of a contract or legitimate interests].
- Hosting or sponsoring Events [depending on the context, performance of a contract or legitimate interests].
- Ensuring compliance with applicable laws [compliance with a legal obligation].
- Conducting statistical analyses and analytics by monitoring and analyzing trends, usage, and activities in connection with the Platform [consent where required (e.g. 3rd-party cookies), or legitimate interests].
- Increasing the number of customers who use our Platform through marketing and advertising [consent where required, or legitimate interests].
- Sending commercial communications, in line with your communication preferences, about products and services, features, newsletters, offers, promotions, and events [consent and in some cases, depending on location, with existing customers, legitimate interests].
When We Share Information
We only disclose your personal information as described below.
Third-Party Service Providers
AirCode discloses users' information to our third party agents, contractors, or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Platform, and in some cases collect information directly, for example as explained in Payment Processing above. Below is an illustrative list of functions for which we may use third-party service providers:
- Hosting and content delivery network services
- Analytics services
- CRM providers
- Lead generation partners
- Marketing and social media partners
- Customer support services
- Payment processors
- Hosting and content delivery network services
- Functionality and debugging services
- Professional service providers, such as auditors, lawyers, consultants, accountants and insurers
As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses or business units. Alternatively, we may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. As part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation or other corporate reorganization in which AirCode participates, or to a purchaser or acquirer of all or a portion of AirCode's assets, bankruptcy included.
When we act on behalf of our Customers (as a data processor or service provider), we may provide End Users' personal information to our Customers in order to comply with their requests, End Users' requests and/or regulator requests, among others.
Occasionally, we will provide our Customers with aggregated information that does not identify End Users directly, in order to provide information about usage, demographics (such as location) or other general information.
If you are an Event Attendee that has registered for an Event with AirCode, we will provide your personal information to the Event sponsors. Such Event sponsors may use your personal information for their own direct marketing purposes and otherwise in accordance with the terms of the Event sponsors’ own privacy policies.
We share aggregated, automatically-collected or otherwise non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users' interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through the Platform. We do not share personal information about you in this case.
Legal Obligations and Security
If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement. Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis. Links to Third Party Sites
What You Should Know about Domain Registration
Note that if you purchase a domain name from AirCode, we may be required to collect registrant data for the purposes of domain registration and listing via the WHOIS protocol. We may also be required to share this with ICANN, the relevant registrars and other such providers with whom we contract in order to provide our domain name services, as well as when served with a legitimate request from third parties. Registration data may include the domain name, registrant name and contact information, and information on the domain name server. Such registration data may be made publicly available by ICANN.
How to Change Your Communication Preferences
To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update any information in our possession that you have previously submitted via the Platform. Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the "unsubscribe" link included at the bottom of all emails from AirCode. You may also adjust your preferences through your account settings if you have a AirCode account, or send an email to firstname.lastname@example.org.
Access and Accuracy
AirCode uses reasonable efforts to keep your personal information accurate. We will provide you with online access to your personal information so that you may review, update or correct personal information that we hold.
Note that in order to protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections. To access your personal information, please visit the relevant account management sections of our Platform. If you cannot access your personal information on the Platform, please send an email to email@example.com.
How Long Do We Keep Your Personal information?
General Retention Periods
We use the following criteria to determine our retention periods:
- The amount, nature and sensitivity of your information;
- The reasons for which we collect and process the personal data;
- The length of time we have an ongoing relationship with you and provide you with access to our Platform; and
- applicable legal requirements.
We retain personal information for as long as needed to provide our Services. Note, however, that with respect to our Customers with active accounts, we may retain certain essential account information, but otherwise regularly delete other information that is less essential to the provision of our Services in order to minimize our storage of data.
We also will retain personal information that we've collected from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a "litigation hold"). In this case, the information must be retained as long as needed for exercising respective potential legal claims.
When we no longer have an ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.
For any questions about data retention, please contact firstname.lastname@example.org.
In some instances, we may choose to anonymize your personal data instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal data can be linked back to you or any specific user.
Data Security And Integrity
We take steps that are reasonably necessary to securely provide our Platform. We have put in place reasonably appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to personal data only to those employees, agents, contractors and the third parties who have a business need-to-know.We also have procedures in place to deal with any suspected data security breach. If required, we will notify you and any applicable regulator of a suspected data security breach. We also require those parties to whom we transfer your personal information to provide acceptable standards of security.
Notwithstanding, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, take special care in deciding what information you send to us via email. For any questions about the security of your information, please contact email@example.com.
Additional Information for Users in the EEA and the UK.
These rights are subject to certain rules around when you can exercise them.
Customers, Site Visitors and Event Attendees in the EEA or the UK.
If you are located in the EEA or the UK and you are a Customer, Site Visitor or Event Attendee, and wish to exercise any of the rights set out above, you may contact us at firstname.lastname@example.org using the term "DSR" as your email subject line.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under those circumstances.
If we cannot reasonably verify your identity, we will not be able to comply with your request(s). We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Note that this is especially true when you engage a third party to assist you in exercising your rights.We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law. In addition, we will always balance your rights against those of other data subjects in connection with any requests, and in some cases this may require us to redact our responses or deny a request.
Customers also can access, correct, export, or update their Account Information by editing their profile or organization record at https://aircode.io. We ask that Customers use this option as a first step when rectifying information.
If you no longer wish to receive our marketing/promotional information, we remind you that you may withdraw your consent to direct marketing at any time directly from the unsubscribe link included in each electronic marketing message we send to you. If you do so, we will promptly update our databases, and will take all reasonable steps to meet your request at the earliest possible opportunity, but we may continue to contact you to the extent necessary for the purposes of providing our Services.
Finally, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us directly first.
End Users in the EEA or the UK.
AirCode has no direct relationship with End Users. Our Customers are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their End Users, and this includes handling all data subject requests. We rely on our Customers to comply with the underlying legal requirements and respond directly to End Users when End Users wish to exercise the rights set forth above. However, if an End User sends a request to AirCode to access, correct, update, or delete his/her information, or no longer wishes to be contacted by a Customer that uses our Services, we will direct that End User to contact the Customer's website(s) with which he/she interacted directly, and cooperate with our Customers as required by applicable law in order to ensure that our Customers satisfy their End Users' requests.