Privacy Policy

PLEASE TAKE TIME TO READ OUR PRIVACY POLICY ("POLICY") AS IT SETS OUT IMPORTANT INFORMATION RELATING TO HOW WE HANDLE YOUR PERSONAL INFORMATION.

This Policy sets out the terms on which Airth, Inc. ("Airth", "airth.io", "we", "our", "us") collects and processes administrator and user information on our website ("Site"), as well as such other platforms and services as we may make available from time to time which link to or otherwise incorporate this Policy by reference, including the Airth Marketplace (collectively the "Services"). Use of the Services is subject to the Agreement (available at LINK_HERE) ("Agreement"), and this Policy is incorporated into and forms a part of the Agreement, together with all other terms and policies linked or otherwise referenced within the Agreement or hereunder.

Please read this Policy carefully. By accessing or using the Services, by accepting the Agreement or by entering into any other agreement with Airth that governs access to or use of the Services and incorporates this Policy by reference, you agree that (1) you have read, understand this Policy, and (2) you consent to the collection and use of data on the terms set forth in this Policy. If you do not agree with this Policy, do not access or use the Services.

HOW TO CONTACT US

Questions, comments and requests regarding this Policy should be addressed to our Data Protection team through the following means: contact@airth.io

We will respond to your complaint, inquiry, or information request as we have the capacity to do so.

INTRODUCTION

We will collect personal information when you use the Site and the associated services, and as part of the normal course of business. This Policy sets out how we collect and use personal information, and your rights regarding our use of your personal information.

Airth also works with software vendors, and this Policy applies to both your use of Airth software and to your use of third-party software accessed through the Site.

CHANGES TO THIS POLICY

We reserve the right to update this Policy at any time and at our sole discretion, in accordance with the Agreement and applicable laws. If we make material changes to this Policy, we will notify you by updating the date of this Policy and placing a prominent notice on our Services, posting any amendments to this page, and/or using such other means as we deem appropriate. We may, and if required by law, will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services.

Any modifications to this Policy will be effective upon the earlier of the posting of the new terms, upon implementation of the new changes within the Services, or as otherwise indicated at the time of posting. In all cases, your continued use of the Services after the posting of any modifications to this Policy indicates your acceptance of the terms of the modified Policy.

DEFINITION OF PERSONAL INFORMATION

Information that we collect from you through the Services will fall into two categories:

(1) "personal information", which means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual. The term "personal information" can include information such as your name, address, telephone number, and e-mail address, but can also include indirect identifiers such as your IP address or device identifier.

(2) "non-personal information", which means data that is collected in relation to your use of the Services, but which does not qualify as 'personal information'. Such non-personal information is not subject to the terms of this Policy.

Personal and non-personal information are both referenced throughout this Policy as "your information" or "information about you".

DATA THAT WE COLLECT

Depending on the technologies that you use to access or use our Services, and how you interact with us with our Services, we may collect information about you directly, automatically, and through third parties when you use or otherwise access the Services. The types of information that you may provide in each category, along with the technologies that we use to collect such information and our purposes for using or otherwise processing personal information, are described in the sub-sections below.

User Data

"User Data" is the personal information that you provide to us directly when you sign up to receive informational or marketing e-mails from us, register for an account, update or change information for your account, send us e-mail messages, and/or otherwise use our Services. We describe the most common types of User Data below:

• Information For Account Registration. You will be required to provide your personal information to sign up for an account on the Services and to use or access certain tools and features of the Services. If you register for an account on our Services, you may be required to provide us with personal information such as:
  • Your contact information, including your full name, work e-mail address, physical address, and phone number; and
  • Personal details such as your birth date, gender, and state of residence; and
  • The business or organization you work for or represent, and related professional or employment-related personal information.

You do not have to provide personal information that is not shown as required to receive our Services (as indicated within the platform); the only consequence of not providing such personal information is that it will not be taken into consideration when we make our recommendations or otherwise provide Services to you.

Subscription To Receive Notices. Airth may offer the ability to subscribe to the Services and to receive updates about the Services via e-mail. To subscribe, you may be required to provide us with personal information such as your name and e-mail address.

Communications with Airth. When you send e-mail messages to Airth, we may receive personal information about you, and may use the information provided by you to respond to your communication and/or as described in this Policy. We may also archive this information and/or use it for future communications with you where we are permitted by law to do so.

You are responsible for verifying the accuracy of the personal information you submit (or that is submitted on your behalf) to the Services and ensuring that any personal information that you provide (directly or indirectly) is kept up to date for the purposes for which you provide it. Inaccurate information may affect your ability to use the Services, the information you receive when using the Services, and our ability to contact you.

Some personal information that you submit can be removed at any time upon your request. Note, however, that some personal information is necessary to use our Services. As such, even if you remove all of your personal information from your account, we may retain some of your personal information to comply with our legal obligations or as necessary to provide the Services to you.

Note that we may collect your personal information directly from you as well as third parties with whom we do business, such as service providers offering benefits solutions to you. Additionally, in connection with providing the Services to you, we may combine your personal information with information that we collect from public sources as well as other information that we receive about you from our business partners and other third parties.

Services Usage Data

We automatically track and collect certain types of information about visits to our Services ("Services Usage Data"). Information that we automatically collect may include personal information such as the User's IP address, geolocation data, device identification, browser type, and operating system, as well as the referring or exit pages, the page(s) requested, and cookie information. Based on the User's IP address, we may be able to obtain further personal information about the User, such as the identity of their internet service provider and the geographic location of their point of connectivity. The suppliers that we use to enable us to provide the Services may also collect Services Usage Data about your visits to the Services and Site.

We may use information about you to create and use anonymous, statistical or aggregated data. Such aggregated data does not allow any party to identify you or any other specific User, and is not personal information subject to this Policy. We use such aggregated data to maintain and operate the Services, to improve the quality of the Services, to create new services and features, and for further internal, commercial and statistical purposes.

Cookie Policy

The Services use automated data collection technologies known as 'cookies' or 'web beacons'. A cookie is a small text file which includes a unique identifier that is sent by a web server to device you use to visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as "cookies".

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

We also may include web beacons in e-mail messages or newsletters to track whether you open the messages. We use this information to customize our services and measure the overall effectiveness of our online content, advertising campaigns, and products and services we offer through the Site.

Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser. Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser's settings. Please be aware that such action could affect the availability and functionality of the Site.

Do-Not-Track Signals

Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. As of the date on which this Policy was last updated, however, there is no standardized DNT signal. As such, our Services do not currently respond to browser DNT signals. If you do not wish to be tracked, you may be able to opt out by selecting certain options in the settings of the browser or device that you use to access the Services, or by using third-party applications and programs.

OUR USES OF PERSONAL INFORMATION

Information About Our Practices

We use personal information that we collect from you to process your requests, to facilitate your use and our administration and operation of the Services, to provide you with information or services you request, and to learn more about and improve the Services and for the purpose for which information was provided. Examples of our uses include:

• Providing you with our Services by:
  • Allowing you to set up a user account and profile;
  • Communicate with you about your account and our Services; and
• In connection with developing, maintaining, or improving our Services by:
  • Analyzing how you use the Services;
  • Understanding user interest and engagement on the Services;
  • Providing customized content or Services;
  • Researching and developing our Services;
  • Detecting security incidents, or protecting against malicious, deceptive, fraudulent, or illegal activity;
  • Debugging to identify and repair errors; and
  • Sending marketing communications (including emails) about our Services.
• Complying with our legal obligations.

Where permitted by law, we may combine any of the information that we collect from you with other information, including information that we obtain from third parties, or with information derived from any other products or services we provide. Such combined information will be used to improve our Services we offer you, to improve analytics and functionality, and for other business and commercial purposes relating to the Services.

SALE OR SHARING OF PERSONAL INFORMATION

As of the "Last Updated" date of this Policy, Airth does not sell, rent or lease your personal information to third parties. We do, however, allow third parties such as our business partners and service providers (e.g., internet and cloud hosting services providers, such as Amazon Web Services), and merchants to process your personal information to enable us to provide the Services, as well as the other purposes specified in this Policy. We may also share personal information with third parties when you request that we do so or otherwise give your consent—for example, if you authorize the linking of your account on our Services to your accounts on third-party platforms, we may share your personal information with those third-party platforms as necessary to link your accounts.

In addition to the above, we may disclose your personal information to the government or other third parties where we are legally obligated to do so—for example, if such information falls within the scope of a criminal or fraud investigation, or a matter of national security, law enforcement or other issues of public importance (such as, where applicable, situations where an individual is at risk or danger of death or serious physical injury).

Lastly, we may also disclose your personal information if required to do so by law or if we otherwise believe it appropriate and/or necessary: (a) to comply with any decrees, laws and/or statutes or in an effort to comply with any legal process served upon us or upon the Services; (b) to maintain, safeguard and/or preserve our rights or property; (c) act under exigent circumstances to protect the personal safety of our Users and/or the public; (d) to complete our obligations in the event that Airth is acquired through a sale, merger, or otherwise experiences a change in corporate control; and/or (e) to enforce our rights and agreements, and otherwise in connection with our Agreement and other agreements. We reserve the right to disclose or transfer any information we have about you as part of, or during negotiations of, any merger, sale of company assets, or acquisition, or in any other situation where personal information may be transferred with other assets of Airth.

If we determine that it is necessary and advisable to disclose your personal information, we may do so without notice to you.

PROTECTING PERSONAL INFORMATION

Airth uses commercially reasonable security measures to protect the information that we collect about you. Nevertheless, you are responsible for securing the account that you use to access our Services. Your obligations may include, as applicable, monitoring your account activities, choosing a secure password, and maintaining the confidentiality of your password. We cannot guarantee the security of any personal information that you submit to our Services, nor can we guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. If you elect to provide any personal information to us, you should be aware that you provide it at your own risk. Airth cannot be held responsible for your failure to keep your account information secure.

MARKETING COMMUNICATIONS

We only send e-mails to persons who have consented to receive communications from us. We may use third-party email providers to deliver these communications to you. You may also opt out of receiving marketing e-mail communications at any time by contacting us, or by clicking on the "Unsubscribe" link at the bottom of the e-mail and following the instructions provided.

Please note that even if you opt out of receiving promotional e-mails from us, you may still receive relationship e-mails from us, including responses to e-mails that you sent to us prior to opting out, notices of updates or changes to our policies and procedures, or other messages relating to your account and/or your use of the Services. Additionally, because our system for processing opt-out requests is not automatic, you may continue to receive some communications from us during the processing period.

PERSONAL INFORMATION RETENTION

Airth will retain personal information for as long as it is needed for or otherwise serves the purposes outlined in this Policy, subject to applicable law. All personal information subject to this Policy is retained in accordance with our policies and practices, applicable law, and contractual obligations. Personal information collected for the purposes related to the performance of a contract or agreement between you and Airth will be retained until such contract or agreement has been fully performed. We may need to retain your information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc.

There may be occasions where we are unable to fully delete, anonymize, or de-identify your personal information due to technical, legal, regulatory compliance or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate such information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

REGARDING USE OF THE SERVICES BY CHILDREN

Airth does not knowingly collect any information directly from anyone under 13 years of age. If you are less than 13 years of age, we request that you do not submit information to us. If we become aware that we have inadvertently collected "personal information" (as defined by the United States Children's Online Privacy Protection Act) from children under the age of 13 without parental consent, we will take reasonable steps to delete it as soon as possible as required by applicable law.

REGARDING LINKS TO OTHER WEBSITES

From time to time, we may provide links to third-party websites on the Services. Any such links from the Services to third-party resources are provided for your convenience. Personal information you provide on third-party platforms is not subject to this Policy.

RIGHTS UNDER DATA PRIVACY LAWS

Your information is stored in the United States. If it is necessary to transfer your information, we will ensure that your personal information is protected by appropriate safeguards as required by applicable data protection laws.

Note, however, that as of the "Last Updated" date indicated on this page, Airth is not subject to the General Data Protection Regulation of the European Union or the United Kingdom, nor to any state-level data privacy laws of the U.S. (including Colorado, California, Connecticut, Montana, Oregon, Texas, Utah, and Virginia).