AIRSIDE MOBILE, INC. PRIVACY POLICY

Last Updated November 30, 2018 by Airside Mobile Inc.

We, Airside Mobile, Inc. (“Airside“), are concerned about privacy issues and want you to be familiar with how we collect, use and disclose Personally Identifiable Information (as defined below). This Privacy Policy describes our practices in connection with Personally Identifiable Information that we collect through any of the mobile applications that we make available to the public (the “App“), or our websites. This Privacy Policy does not address the collection, use or disclosure of information by any of our affiliates or by third parties.

By using the App, you agree to the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use the App or our web site(s).

We reserve the right to change this Privacy Policy at any time. When we change the Privacy Policy in a material manner, we will attempt to notify you through in-app notifications (if your settings permit notifications) or by alerting you to the updated Privacy Policy the next time you launch the App. Any changes to our Privacy Policy will become effective on the effective date listed on the Privacy Policy. If you do not agree to such changes, you can close your account and request that your information be deleted.

You can determine when this Privacy Policy was last revised by referring to the “LAST UPDATED” legend at the top of this page. Any changes to our Privacy Policy will become effective upon our posting of the revised Privacy Policy on the App.

1. WHAT TYPES OF INFORMATION DO WE COLLECT FROM YOU?

1.1. Personally Identifiable Information (or “PII”)
PII is information that identifies you as an individual. In order for you to take advantage of particular opportunities provided through our Apps or websites including expediting customs & immigration processes, monitoring itineraries, and receiving offers, we may require that you furnish PII.

We may collect PII from you, such as your name, postal address, telephone number, e-mail address, passport information, date and place of birth, credit card number or other payment account number (including the three (3) or four (4) digit validation code for your credit card), when you voluntarily provide it to us or when your employer provides any such PII to us under the auspices of corporate subscription agreements to one or more of our services.

1.2. Non-Personally Identifiable Information (or “Non-PII”)
Non-PII is aggregated information, demographic information and any other information that does not reveal your specific identity. We and our third party service providers may collect Non-PII from you, and we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the App. We and our third party service providers may also use cookies, pixel tags, web beacons, and other similar technologies to better serve you with more tailored information and facilitate your ongoing use of our App.

2. HOW DO WE USE INFORMATION COLLECTED FROM YOU?

We do not sell or share your information (PII) with third parties for marketing purposes.

Personally Identifiable Information. We may use PII:

  1. to fulfill your requests, e.g., to allow you to order and receive items through our partners or to provide you with specific information that you request.
  2. to send you important information regarding the App, changes to our terms, conditions, and policies and/or other administrative information.
  3. to fulfill your purchase(s) (e.g., to process credit card payments in connection with your order).
  4. to customize content on our App.
  5. to expedite, only at your specific request, customs and immigration services by sharing selected PII with the U.S. Government, specifically the U.S. Customs & Border Patrol.

Non-Personally Identifiable Information
Because Non-PII does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non-PII with our affiliates and suppliers to improve our service offerings and to ensure the security and functionality of the App. In some instances, we may combine Non-PII with PII (such as combining your name with your geographical location). If we do combine any Non-PII with PII, the combined information will be treated by us as PII hereunder as long as it is so combined.

IP Addresses and Mobile Device Identifiers
We do not collect or use Mobile Device Identifiers assigned by device manufacturers or wireless service providers. Please note that we treat IP Addresses, server log files and related information as Non-PII, except where we are required to do otherwise under applicable law.

3. HOW IS PERSONALLY IDENTIFIABLE INFORMATION DISCLOSED?

We may disclose PII:

  1. to our third party service providers, with your consent, who provide services such as payment processing, customs & immigration processes, order fulfillment, internet service providers, IT services, customer service, and credit card processing.
  2. to fulfill your purchase
  3. to identify you to any person to whom you send messages regarding App-related content through social media services integrated into the App (only when you explicitly choose to use those social media services. For example, if you choose to link to your Twitter account and choose to send a message via the Twitter button within the App, your tweet will be identified as coming from your Twitter account).
  4. to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
  5. to comply as we believe to be appropriate: (a) under applicable law including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.

4. OTHER IMPORTANT NOTICES REGARDING OUR PRIVACY PRACTICES

Forums and Profiles
We may make available through the App services (for example, message boards, chat functionality, “profile pages” and blogs, among other services) to which you are able to post information and materials. Please note that any information you disclose through such services becomes public information and may be available to visitors to the Site and to the general public. We urge you to exercise discretion and caution when deciding to disclose your PII, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PII YOU VOLUNTARILY DISCLOSE TO THIRD PARTIES THROUGH THE APP.

Third Party App
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including without limitation any of our affiliates and any third party operating any site to which this Site contains a link. The inclusion of a link on the Site does not imply endorsement of the linked site by us or by our affiliates.

US Customs & Border Patrol (US CBP)
To fulfill a request for expedited service for US CBP processes, Airside will facilitate the transmission of relevant PII at your specific direction to US CBP via secure, encrypted processes that meet the US CBP requirements for transmission of PII. Airside is NOT responsible for the use of such information by the US Government, including US CBP, and is NOT responsible for any actions the US Government, including US CBP, may or may not take based on that information.

Transportation Security Administration (US TSA)
To fulfill a request for expedited service for US TSA processes, Airside will facilitate the transmission of relevant PII at your specific direction to US TSA via secure, encrypted processes that meet the US TSA and US state DMV requirements for transmission of PII. Airside is NOT responsible for the use of such information by the US Government, including US TSA, and is NOT responsible for any actions the US Government, including US TSA, may or may not take based on that information.

Security
We use reasonable organizational, technical and administrative measures to protect PII under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive information through email.

Opt-In
During the use of the Service, you are asked to explicitly opt-in to the sharing of your PII to third parties, such as US CBP and US TSA. We will not share such information without being provided with specific consent.

Changing or Suppressing PII
If you would like to review, correct, update, suppress or otherwise limit our use of your PII that has been previously provided to us, you may do so by adjusting your preferences in the ‘Settings’ functions for the apps or by contacting us at flightcrew@airsidemobile.com We may need to retain certain information for record-keeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed.

Retention Period
We will retain your PII for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. You may elect to allow us to retain PII for your convenience between travel activities. You will be asked to approve such retention.

Note Regarding the Use of the Site by Children
The Apps are not directed to individuals under the age of thirteen (13), and we request that such individuals not provide PII through the Site. However, legal guardians may enroll travel documents on behalf of their children on their own mobile devices.

Contacting Us
If you have any questions regarding this Privacy Policy, please contact us by e-mail at dpo@airsidemobile.com.

Please note that e-mail communications will not necessarily be secure; accordingly you should not include credit card information in your e-mail correspondence with us.

5. GDPR COMPLIANCE

Airside Mobile complies with the European Union General Data Protection Regulation (GDPR) guidelines enacted by the EU to protect data. Originally adopted in April of 2016, the regulations go into effect on May 25, 2018.

All inquiries concerning GDPR should be sent to our DPO (Data Protection Officer) via email at dpo@airsidemobile.com. The DPO or a member of their team will respond within 48 hours.

Airside Mobile offers several products. Please consult the appropriate section for more detail.

Mobile Passport and APC

Airside Mobile only collects Personally Identifiable Information (PII) that you authorize and enter into our application or kiosk. These elements can include passport information (including name and passport number), photographs and fingerprints. In addition, our system will collect non-PII information (arrival and flight data) and other relevant system data (location and time of day) for processing submission.

Formatted information is securely presented for processing to by US Customs and Border Patrol (CBP) and passage is either granted or denied by them. Once the passage status is determined by CBP, we inform the user of their decision. We are unaware of the algorithms used by CBP to determine this status and encourage data subjects to contact them directly if they have questions. Airside Mobile cannot facilitate these communications.

To log the transaction, we rely on pseudonymization techniques to maintain security of your information. Personal identifying information (such as the passport number and name) are not retained. As such, we are unable to process requests for erasure or export for a data subject since we cannot attribute the information we have to an individual.

Mobile Proof

Airside Mobile only collects PII information that you authorize and/or enter into our application and this data is securely stored in our systems. Personal information such as name, address, and billing information (including payment information such as credit card) is collected to establish your account. This information is retained by our systems in an encrypted form that we can decrypt and access to provide your service.

All personal data stored by the customer in their locker is encrypted and Airside Mobile cannot (by design) decrypt this information without your key. This key is not stored by us and without it, we are unable to respond to requests from anyone, including the customer, for this information to be exported in a decrypted form.

Data subjects may request erasure or data export when closing your account. For data export, billing information will be obfuscated to protect clients and encrypted information will be delivered as a binary object.

6. CONTACT INFORMATION

For further information, please contact us at:

Privacy Office: privacy@airsidemobile.com

GDPR Representative : dpo@airsidemobile.com

Airside Mobile DPO : dpo@airsidemobile.com

Information Security : security@airsidemobile.com

US office PSTN : +1 703 345-5832