Privacy Policy
Last updated: March 14, 2024
Welcome to AireXpert! The privacy and security of your personal information is important to us. If you have any questions at all about this Privacy Policy, please do not hesitate to contact us at privacy@airexpert.net.
TABLE OF CONTENTS
● Applicability of this Privacy Policy
● Data Privacy Framework Program for EU, UK and Swiss Individuals
● What Information Do We Collect?
● How Do We Use the Information We Collect?
● Do We Share Your Personal Information?
● How Do We Secure Your Personal Information?
● Your Rights Regarding Your Personal Information
● Links to Third-Party Websites
● How We Respond to Do Not Track Signals
● A Note to Users Outside of the United States
Applicability of this Privacy Policy
This Privacy Policy (“Privacy Policy“) applies to the AireXpert software and software-as-a-services platform, our website, and any related mobile applications and other websites or services provided by AireXpert (collectively, the “Services“) and explains how Eng.io Ventures, Inc. dba AireXpert (“AireXpert,” “we,” “us,” or “our“) collects, uses, shares and otherwise processes information relating to natural persons (“Personal Information“). All capitalized terms not herein defined have the meanings ascribed to such capitalized terms in the AireXpert Master Services Agreement (the “Agreement“), which is hereby incorporated by reference. This Privacy Policy applies to any individual employee of our Corporate Customers and any other user of, or visitor to, the Services (“Client” or “you”). This Privacy Policy does not apply to information collected by us offline or through any other means, or to any third party’s (including our Corporate Customers) collection or use of information.
AireXpert processes Personal Information in the role of a processor where your Personal Information was submitted to us by one of our Corporate Customers. If you wish to exercise any of your rights with respect to your Personal Information for which we are a processor, please contact your employer (the Corporate Customer) directly.
We may update this Privacy Policy from time to time to reflect changes in our privacy practices. If we do, we will notify you of any changes by posting a notice on the Services. Changes that materially affect your rights or our obligations will go into effect thirty (30) days following such notification, at which point we will update the “Last Updated” date at the top of the page. Non-material changes or clarifications will take effect immediately. We encourage you to periodically check the Services and this page for updates.
You acknowledge that your use of the Services indicates to us that you have read this Privacy Policy and consent to the privacy practices described, and your continued use of our Services after we publish or send a notice about any changes to this Privacy Policy indicates that you have read and consent to the updated Privacy Policy.
Data Privacy Framework Program for EU, UK and Swiss Individuals
Effective March 2024
Eng.io Ventures, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Eng.io Ventures, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S.DPF. Eng.io Ventures, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S.DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or theSwiss-U.S. DPF Principles, the Principles shall govern. To learn more about theData Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Eng.io Ventures, Inc.’s commitments under the DPF are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
This statement applies to Personal Data that we handle. For purposes of this statement, “Personal Data” means information that:
- Is transferred from the European Economic Area (EEA), Switzerland and/or the United Kingdom to the United States, in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF
- Is about, or pertains to, a specific individual
- Can be linked, either directly or indirectly, to that individual
DPF Principles
Eng.io Ventures, Inc. ensures our collection, use, and retention of Personal Data comply with the DPF Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability.
Notice
This policy describes the purposes for which we collect and use your Personal Data, the types of third parties to which we disclose your Personal Data, the choices and means, if any, we offer you for limiting the use and disclosure of your Personal Data, and how to contact us.This policy will be made available to you before we use or disclose your Personal Data for a purpose other than that for which it was originally collected.
Choice
Eng.io Ventures, Inc. offers you the opportunity to limit how your Personal Data is used or disclosed. We will provide you with reasonable mechanisms to exercise your choices.
As mentioned further in this policy, we do not rent, sell, or permit PersonalData to be used for reasons other than those for which it was originally provided. If this practice should change in the future, we will update this policy accordingly and provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your Personal Data, please submit a written request to privacy@airexpert.net.
Accountability for Onward Transfer
AireXpert’s accountability for Personal Data that it receives in theUnited States under the DPF Principles and subsequently transfers to a third party is described in the DPF Principles. In particular, AireXpert remains responsible and liable under the Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with thePrinciples, unless AireXpert proves that it is not responsible for the event giving rise to the damage.
Security
Eng.io Ventures, Inc.maintains reasonable and appropriate security measures to protect Personal Data fromloss, misuse, and unauthorized access, disclosure, alteration, or destruction in accordance with the DPF.
Data Integrity and Purpose Limitation
We use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. We take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current.
Access
Pursuant to the Data Privacy Framework Principles, EU, UK and Swiss individuals have the right to obtain our confirmation of whether we maintain Personal Data relating to you in the United States. Upon request, we will provide you with access to Personal Data that we hold about you. You may also correct or amend incomplete or incorrect information, or delete the Personal Data that has been processed in violation of the principles. An individual who seeks access, or who seeks to correct, amend, or delete data transferred to the United States under DPF, should direct their query to privacy@airexpert.net.These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. We may request specific information from you to confirm your identity. Recourse, Enforcement, and Liability
In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Eng.io Ventures, Inc. commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S.DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact privacy@airexpert.net.
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. Eng.io Ventures, Inc. has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visitwww.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.
Eng.io Ventures, Inc. commits to cooperate with EU data protection authorities (DPAs), the United Kingdom Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU, the UK and Switzerland in the context of the employment relationship. EU, UK or Swiss individuals with HR complaints should not refer anything to BBB NationalPrograms.
EU, UK or Swiss individuals wishing to contact their Data Protection office may find more information at the following links:
EU DPA’s: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Swiss FDPIC: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf
The Federal Trade Commission has jurisdiction with enforcement authority over AireXpert’s compliance with the Data Privacy Framework Principles.
Required Disclosure
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Amendment
We may amend this policy from time to time by posting a revised statement on this website. If we amend the policy, the new policy will apply to Personal Data previously collected only insofar as the rights of the individual affected are not reduced. So long as we adhere to the EU-U.S. DPF Program, we will not amend our policy in a manner inconsistent with the EU-U.S. DPF Program.
What Information Do We Collect?
We collect information, including Personal Information, only where we have a lawful basis. Lawful bases on which we rely include your consent where you have given it, contract where processing is necessary for us to perform our obligations pursuant to a contract with you, and legitimate interests of our business such as operating and providing the Services to you.
We collect, store, and use information we get from your use of the Services, including the following categories of information (which, for clarity, include Personal Information):
● Your profile information, which includes first name, last name, email address, phone number, your role at the Corporate Customer, and any other information you share when you create an account with us or otherwise access the Services.
● Other Personal Information you voluntarily submit to the Services as part of your use thereof, which may include location, a profile picture, etc.
● Other details about you that you voluntarily submit to Corporate Customers as part of your use of the Services.
● Your responses to surveys that we may ask you to complete for research purposes or to help direct AireXpert activities. Details of how you use the Services.
● Your internet protocol address (i.e., IP address) and, if you access the Services from a mobile application, mobile device identifiers and non-email authentication.
● Browser and device information and information collected through Tracking Technologies (defined below), such as cookies, pixel tags, and other technologies.
How Do We Use The Information We Collect?
We use the information we collect for a variety of purposes, including to improve the Services, optimize our technology, and refine and customize our offerings and user experience.
In particular, we use the information we collect to:
● Administer and provide theServices, enable you to use its features, and improve the overall user experience.
● Communicate with you through email, text, SMS, message via social media platforms, telephone, or any other medium for which we have contact information so that we can provide you with information and updates about the Services.
● Respond to comments and questions and provide technical support and customer support.
● Analyze how you and other Clients use the Services using tools like Google Analytics, MixPanel, and other tools to help us understand traffic patterns and know if there are problems with theServices.
● Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
● Link or combine user information with other Personal Information.
● Compare information for accuracy, update our records, and verify it with third parties.
● Fulfill any other purpose for which your provide it.
● In any other way we describe when you provide the information.
Do We Share Your Personal Information?
We do not rent or share your Personal Information with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide the Services or any specific service you have requested or authorized. We currently do not share personal data with third parties for their direct marketing purposes without your consent. We currently do not sell your Personal Information.
To help us do our work, we may provide limited access to some of your Personal Information to the following third parties:
● Collaborating Organizations:Sometimes we collaborate closely with other groups to further our mission. In these cases, we may share your name, contact information, and other details you provided when making an account with our partners.
● Service Providers: We work with a wide range of third-party providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, bulk SMS services, and other non-governmental organizations. We do not authorize them to use or disclose your Personal Information except in connection with providing their services.
We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization, or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Services; to protect AireXpert’s rights or property; for any other purpose disclosed by us when you provide the Personal Information; and with your consent. In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes.
We will also share Personal Information with companies, organizations or individuals outside of AireXpert if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Information is reasonably necessary to (1) detect or protect against fraud or security issues, to enforce the Agreement, (2) meet any enforceable government request, (3) defend against legal claims, or protect against harm our legal rights or safety, or that of our staff and/or users.
Cookie Policy – What are Tracking Technologies, such as Cookies and Web Beacons, and How Do We Use Them?
We, or third parties we do business with, may use certain technologies to automatically collect log files and other information about your usage of, and the devices you use to access, the Services (“Tracking Technologies”). For example, we may use Tracking Technologies like cookies, log files, web beacons, session replay scripts, or similar technologies to help us analyze our web page flow, customize our services, content, and advertising, measure promotional effectiveness, and promote trust and safety. You may delete and block all cookies from the Services, but parts of the Services will not work. We want to be open about our cookie use.
Even if you are only browsing the Services, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Services)is automatically collected about you. This information will be collected every time you access the Services and it will be used for the purposes outlined in this Privacy Policy.
You can reduce the information cookies collected from your device. An easy way of doing this is often to change the settings in your browser. If you do that you should know that (a) your use of the Services may be adversely affected (and possibly entirely prevented), (b) your experience of this and other sites that use cookies to enhance or personalize your experience may be adversely affected, and (c) you may not be presented with advertising that reflects the way that you use our and other sites. You find out how to make these changes to your browser at this site: www.allaboutcookies.org/manage-cookies/. Unless you have adjusted your browser settings so that it will refuse cookies, our system will send cookies as soon as you access the Services. By using the Services you consent to this, unless you change your browser settings.
Web beacons may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow. Our third-party advertising service providers may also use web beacons to recognize you when you access the Services and to help determine how you found the Services. If you would like more information about this and to know your choices about not having this information used by these companies, please visit: the Digital Advertising Alliance’s website, http://www.aboutads.info/, or the NetworkAdvertising Initiative’s website, http://networkadvertising.org/consumer/opt_out.asp.
How Do We Secure Your Personal Information?
We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. The safety and security of your Personal Information also depends on you. If you create an account with us, you are solely responsible for keeping your account details confidential, including any access credentials like passwords or mobile device PINs.
State Privacy Rights
We do not meet the conditions as outlined in Section 1798.140 of the California Consumer Privacy Act of 2018 (the “CCPA”) and therefore are not subject to CCPA requirements. We also do not meet the eligibility conditions outlined in the Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Oregon Consumer Privacy Act, Texas Data Privacy and Security Act, or Montana Consumer Data Privacy Act and are therefore are not subject to the requirements of these laws. For specific information related to your ability to access and correct your personal information, see “Your Rights Regarding Your Personal Information” below.
Your Rights Regarding Your Personal Information
You have certain rights with respect to the storage, use, and sharing of Personal Information that is submitted to us, which are listed below. If you wish to exercise any of your rights with respect to your Personal Information, please contact your employer (the Corporate Customer) directly. If you contact us, we will use commercially reasonable efforts to work with the applicable Corporate Customer to respond to your request.
If your employer has entered into an agreement with AireXpert pursuant to which an alternative privacy policy applies to your personal information, then such alternative privacy policy terms will apply to our use of your personal information in lieu of this Privacy Policy. Please contact your employer for additional information regarding this.
● Changing, Correcting, or Deleting Your Personal Information. All users may review, update, correct, or delete the Personal Information furnished by a user, and/or other content uploaded by the user, to a Corporate Customer.
● Downloading or Accessing Your Personal Information. You may obtain a copy of your Personal Information, as well as information about its processing.
● Withdrawing Consent (Opting Out). Where processing Personal Information is based on your consent, you have a right to withdraw consent at any time for future processing.
● Lodging Complaints. You have aright to lodge a complaint with a data protection authority.
Links to Third-Party Websites
We may provide links to other websites through our Services. We have no control over these websites and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third-party websites.
By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third-party websites.
How We Respond to Do Not Track Signals
Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.
Children Under 16
The Services is not directed to individuals who are under age ofsixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at privacy@airexpert.net and the information will be deleted.
GDPR Notice
We collect the categories of personal information identified in “What Information Do We Collect?” above. The data that AireXpert collects is generally in the category of business contact information of corporate employees which contains name, work e-mail and work phone number and is specified above.
In compliance with the European Union (“EU”) General Data Protection Regulation(“GDPR”) and United Kingdom (“UK”) General Data Protection Regulation(“UK GDPR”), we rely upon the following legal basis defined in the GDPR and UK GDPR to collect, use, share and otherwise process the personal information of individuals located in the EU or UK:
· Necessary for the purposes of AireXpert or a third party’s legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms.
Where we collect, use, disclose and otherwise process your information based on legitimate interests, we rely on the following legitimate interests:
· Performing services for or on behalf of our clients, including maintaining or servicing accounts, providing customer service, client communications, client relationship management, processing or fulfilling transactions, verifying identity information, processing payments, and other services
· Marketing our products: We use your information as necessary to pursue our legitimate interests in marketing our products to you. For example, where permitted by digital marketing law, we may contact you by email to let you know of products you might be interested in.
· Providing, improving and developing our products: We use your information as necessary to pursue our legitimate interests in tailoring and improving our products. For example, we may send you a survey or questionnaire to understand your experience in purchasing from us.
If you are located in the EU or UK, under certain circumstances, you have the right:
· To access the personal information we maintain about you
· To receive information about how we process your personal information
· To correct your personal information
· To have your personal information erased
· To object to or restrict how we process your personal information
· To request your personal information be transferred to a third party
· To withdraw any consent you may have given us to process your personal information
We transfer personal information to the categories of recipients identified above in “Do We Share Your Personal Information?”.
Data Retention
We retain personal information for so long as is necessary to carry out the legitimate interests identified above. Personal data shall be retained in active process environment only for the minimal period for which it is required for processing. Thereafter, the data shall be archived securely asper the requirement identified under legitimate interest.
Subsequently, data shall be continued in secure archiving or destroyed as per the identified legitimate interest requirements of AireXpert. Legal obligations on data retention shall be factored into the legitimate interest assessment.
Contact Information for EU and UK Residents
AireXpert has designated individuals who receive emails directed to the privacy@airexpert.net inbox and are the contacts to handle all data subjects requests and complaints. The core activity of AireXpert does not involve processing sensitive data on a large scale or involve large scale, regular, and systematic monitoring of EU and UK data subjects. Thus there is no requirement to designate a “Data Protection Officer” as envisaged under GDPR or UK GDPR at this time.
If you are an EU or UK resident, you have the right to object to our processing that is based on legitimate interests by contacting us at the address or number below. If you are located in the EU or UK and you believe that we have infringed your rights under the GDPR or UK GDPR, please contact us by sending an email to privacy@airexpert.net.
You have the right to lodge a complaint with a supervisory authority, in particular in your applicable Member State.
A Note to Users Outside the United States
AireXpert is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be collected, transferred to, stored and otherwise processed in any country where we have facilities or in which we engage service providers.
We may also process Personal Information using other compliance mechanisms to ensure that transfers of Personal Information are provided an adequate level of protection as required by law, such as by entering into appropriate contractual arrangements (such as, where applicable, the standard contractual clauses for the transfer of data as approved by the European Commission) or by asking for your prior consent.
Contact Us
Please do contact us at privacy@airexpert.net if you have any complaints or concerns with respect to your privacy. If you believe we are unable to assist you, you may have the right to lodge a complaint with a supervisory authority in the relevant jurisdiction.
For individuals in the European Union, a list of Supervisory Authorities is available here:
https://edpb.europa.eu/about-edpb/board/members_en.
Individuals in the United Kingdom may find more information about the ICO here :
Swiss individuals may locate FDPIC information here:
However, we are committed to working with you to resolve any complaint or concern you may have with respect to your privacy.