This privacy policy (“Policy”) informs you of your choices and our practices in relation to your Information (as defined below).
Our services are not available for use by children and are intended for persons over the age of 18 years old and 21 years old in some jurisdictions. Please refer to your country laws in accordance with age-appropriate guidance.
To comply with the current ‘UK Data Protection Act’ for Children, specifically the Age Appropriate Design Code (also known as the Children’s Act), risks have been assessed. More information can be found at https://ico.org.uk/for-organisations/childrens-code-hub/.
This policy will explain areas of our app or website that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights
For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual. This includes Information relating to your use of: (a) our mobile app (“Mobile App” the “Service”); (b) www.airolen.com and any other dedicated websites which link to this policy (“Website”). When you use the App or you accept our rules and policies which set out how we handle your Information, and you understand we may collect, process, use and store your Information as described in this Policy. “Payment” refers to deposits made using tokens via your virtual wallet
If you do not agree with this Policy, you must not use our app or website. If you change your mind in the future, you must stop using our app or website, and you may exercise your rights in relation to your Information as set out in this Policy.
This Privacy Policy does not apply to information that you may submit to third-party websites or mobile applications that may link to the Websites or be linked to on the Websites. We are not responsible for the actions or privacy practices of third-party websites and applications; please consult those websites and applications directly to understand their privacy practices
We may collect and use the following Information about you:
1.Information you provide to us: We receive and store information provided to us or given to us in any other way, including your: name, mailing address, phone number, email address, picture, date of birth, payment information, registration information, social media and messaging platform handle, optional biographic and demographic information, processional and licensure
information, information for wallets you create or connect via our Websites, survey responses, and any other information that you voluntarily provide. This includes information that you share with us on third-party websites and platforms.
2. Information collected via our customer support channels, for example, when you contact us via email, you may provide us with (a) your full name, email and (b) any information you choose to provide to allow us to assist you. This information is not used or shared for any purpose other than to assist with your reason for contact.
3. Information you provide when using the app or website: You are only required to submit personal information, should you choose to opt into marketing emails, such as newsletters and updates.
4. Information provided: It is the responsibility of the you, the ‘user’ to ensure your details are accurate and up to date and, where possible, to only provide such information as is necessary when you contact us.
Information we automatically collect or is generated about you when you, register for newsletters or updates or connect to our app or website:
1.Identifiers, such as your name, email address, IP address, device and app ID, unique ID, location data and device information (such as model, brand and operating system)
2. Cookies: we use cookies and other similar technologies (e.g. web beacons, log files, and scripts) (“Cookies”) to enhance your experience when using our services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies or instruct the device or web browser to provide notice at the time of installation of cookies or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed. For more information about our Cookies policy, click here
3. Information regarding your use of the website or app, such as date and time stamps of events, interactions with our teams
4. Location based data - Using an app: is collected within the app and can only be collected if you, the ‘user’ has your location services activated. When the app is installed it will ask for permission to allow the app to access your location service, you can accept or deny. You can also go into your settings on your phone and disable this at any time. Website: When you visit our Websites or interact with our online services, we may receive information about your location and your device, including a unique identifier for your device. Location information allows us to provide location-based services, such as advertising and other personalized content.
Our Websites may use “cookies,” (please refer to our Cookies Policy) tagging and other tracking technologies to help enable us to enhance or personalize your online experience. This information includes computer and connection information such
as statistics on your page views, traffic to and from our Websites, referral URL, ad data, your IP address, device identifiers, transaction history, and your web log information.
Information received from third parties:
1. Information from Social Media: When you interact with us or our Websites or on a social media platform, we may collect the personal information that you make available to us, including your account ID, username, and other information included in your posts. If you choose to log into your account with or through a social networking service, we and that service may share certain information about you and your activities. When you give us permission, we may also collect information from your social media account on your behalf.
2. Analytics information: We integrate certain analytic software, Google analytics, a third-party analytics provider. They provide reports that help us optimize our features. This information may include user activity but is not identifiable information.
3. Information from mobile measurement partners: we receive information from third parties to allow us to track performance and to detect fraud. This includes, IP address, location and in some circumstances transaction information.
4. Third-Party Terms and Policies. When connecting your virtual wallet to our app or website to log in, third-party terms or policies may apply. It remains the responsibility of the user to ensure you have read and agree to their terms.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses
We will only use your personal data (such as name, email address or telephone number if provided to us) when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a. Where we need to perform the contract, we are about to enter into or have entered into with you
b. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c. Where we need to comply with a legal obligation.
d. Or, where you have opted in to receive any marketing material
Certain purposes that either 'constitute' a legitimate interest or 'should be regarded as' a legitimate interest. These are: fraud prevention; network and information security; and indicating possible criminal acts or threats to public security.
Some processing is necessary because it is in our or a third party’s legitimate interests, such as those of visitors, members or partners
We may collect information in a way that does not directly identify you; we may collect information you have shared with us and we may use and share such information as necessary for our business purposes and as permitted by applicable law. The Lawful Bases we rely on and our legitimate interests We process your information on the following lawful bases and in furtherance of the following legitimate interests:
1. Provide you with the service. More in particular, we will use Information to perform our contractual obligation towards you to allow you to connect to our services via your virtual wallet. The Information we process when doing so may include a unique identity which does not identify your personally.
2. Improve and monitor use. To improve our service for our customers. When doing so, we may collect information such as a unique identity which will allow us to analyze information about your device such as battery, Wi-Fi strength, device manufacturer, model and operating system
3. Conduct analytics. To analyze interaction and to (a) create anonymized and aggregated data; (b) create segments of users who show particular characteristics or interests; and (c) conduct predictive analytics about your interests.
4. Provide you with advertising. We will present you with newsletters advertising updates and / or offers. Where it is required, we will only do so where we have your consent. In situations where your consent is not required, or where we provide contextual advertising, we do so on the basis of our legitimate interests. If you no longer want to receive targeted advertising, please see our Cookie Policy which explains how you can opt out and change your browser and device settings.
5. Prevent fraud, defend Airolen against legal claims or disputes, enforce our terms and to comply with our legal obligations. To detect fraud or any other user behavior which prejudices the integrity of our services, (2) taking steps to remedy aforementioned fraud and behavior, (3) defending ourselves against legal claims or disputes, and (4) enforcing our terms and policies. When doing so, we will process the Information relevant in such a case, including information you provide us, information we automatically collect about you, and information which is provided to us by third parties.
DATA PROCESSING LEGAL BASIS Providing services. We need to provide services via the Website Contract Providing newsletters/offers/updates which may be interesting to you Consent for newsletters; Legitimate Interests for offers and updates. Registering you as a user Contract Compliance with applicable anti-money laundering and know your client rules Legal obligation Keeping the Website running (managing your requests, remembering your settings, hosting, and back-end infrastructure) Legitimate Interests Preventing frauds, illegal activity, or any violation of the terms or Privacy Policy. We may disable access to the Website, erase or correct personal data in some cases Legitimate Interests Improving the Website (testing features, interacting with feedback platforms, managing landing pages, heat mapping the Website, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this) Legitimate Interests Customer support (notifying you of any changes to the Website, services, solving issues, any bug fixing) Legitimate Interests
YOUR CHOICES ABOUT HOW INFORMATION ABOUT YOU IS USED AND SHARED
In many instances, you have choices about the information you provide and how we use that information.
Marketing Emails: By providing us with an e-mail address, you acknowledge that we may use your e-mail address to communicate with you. You can opt-out of receiving promotional and other marketing emails from us by using the “unsubscribe” feature in our marketing e-mails.
Financial Incentives: We may run promotions from time to time and ask you to share personal information with us. We will always give you clear notice about these types of programs when you sign up, and participation is always voluntary. If you change your mind, you will be able to opt out, and if you do not participate, you will still be able to use our services. To enter any such promotion, you will be asked to supply information about yourself, including personal data such as name, email address, or other information. This information is supplied by you on a voluntary basis. If you do not wish to provide personal information, you should not use the promotion.
Vendors and service providers, we rely on for the provision of the service, for example:
1. Cloud service providers who rely on for data storage, being AWS (Amazon Web Server)
2. Analytics providers. We work with a number of analytics, segmentation and mobile measurement service providers who help us understand our user base. This includes Apple, Google, AWS (Amazon Web Server).
3. Advertising partners. We may include an ad-supported service. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads within the app or website, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, personalise advertising, or similar activities. For more information on how to limit or opt-out from personalized advertisement, please see our Cookie Policy
4. Partner Exchanges: These processors are responsible for the processing of your Information and may use your Information for their own purposes in accordance with their privacy policies, please refer to their individual policies.
5. Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).
6. Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.
Third-Party Privacy Practices
If you access any service through a third-party platform such as Apple or Google (“Third Party Services”), you must understand that those Third Party Services may collect other information about you (including information you share with them directly or about your use of the app or website) in accordance with their own terms and privacy policies. The privacy practices described in this Policy do not apply to Third Party Services. Any links to Third Party Services do not imply that we endorse or have reviewed the Third-Party Services.
Security
Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimize the Information we process.
Your Information will be processed by our employees and service providers, Apple, Google, AWS (Amazon Web Services) and Mailchimp. We take steps to ensure all transfers are protected by adequate safeguards. When you download the app via Google Play or Apple, you will need to read their Terms and Policies which are independent of Airolen’s Terms and Policies. We may share with Google, Apple, AWS (Amazon Web Services) data we have collected from your device in order to track user experience, such as app or website crashes. This information does not include identifiable or personal information.
It is unlikely, however, should we need to transfer your personal data out of the Marshall Islands, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your data to countries that have been deemed to provide an adequate level of protection for personal data.
Your Information, provided to us, by you, will be stored for up to 6 years. When deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are:
1. The right to request access to your personal data
2. The right to request correction of your personal data
3. The right to request erasure of your personal data
4. The right to object to processing of your personal data
5. The right to request restriction of processing your personal data
6. The right to request transfer of your personal data
7. The right to withdraw consent
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to 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.
We reserve the right to modify this Policy at any time. If we make material changes to this Policy, we will notify you by updating the date of this Policy and posting it on the Websites. We may also provide notification of changes in another