Aircore Privacy Notice

AIRCORE PRIVACY NOTICE

Last Updated: November 30th, 2022

Welcome! We are Aircore. We provide real-time social and collaboration APIs for websites and applications. This Privacy Notice explains how Aircore, Inc. (“Aircore”, “Company”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites (the “Sites”), including www.aircore.io, including developer.aircore.io, their subdomains, their subdomains, and any other websites we own and operate that link to this Privacy Notice, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”). It does not address our privacy practices relating to Aircore employees and other personnel.

This Privacy Notice also does not apply to the collection, use, disclosure, and otherwise processing of personal information in connection with our Software, including our application programming interfaces and software development kits (“SDKs”) (collectively, the “APIs”). Please see the Aircore API Privacy Notice for more information about the data that may be processed through the use our APIs.

Aircore is the controller of the personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used.

Our Collection and Use of Personal Information

We collect personal information in a variety of ways. For example, you may provide us your personal information when you register for an account, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of our Service.

We may link or combine your activities and information collected from you on our websites with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You

We may collect the following categories personal information submitted to us by individuals through the Services:

Account Information, including first and last name, email address, user ID and password, profile information, payment and purchase history information, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Service, and for customer support purposes. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
Payment Information. If you sign up for one of our Services requiring payment (i.e., subscription), we collect the information provided in connection with such payment. Depending on your subscription type, you may be able to pay via wire transfer, credit card, or check and we may collect the financial information associated with such payment (e.g., routing and account number, wire transfer information details). Please note that we use third party payment processors, including Stripe to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice. To view Stripe’s privacy policy, please click here.
Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
Newsletter, Marketing Emails, and Blog Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
Event and Webcast Information, including registration information, call-in details, attendee badge information, and contact information. We use this information to administer and facilitate the Services and improve and grow our business.
Feedback Information. We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
Employment Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.

Personal Information Automatically Collected

As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:

Log Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services. Log data may overlap with the other categories of data below.
Analytics Data, including the electronic path you take to our services, through our services and when exiting our services, UTM source, as well as your usage and activity on our services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with.
Location Data, such as coarse geographic location we or our third-party providers may collect, and which may be derived from your IP address.

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see our Cookie Notice.

Personal Information from Third Parties

We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual.

We may receive the same categories of personal information as described above from the following third parties:

Within Aircore: We may receive personal information from other companies and brands owned or controlled by Aircore, and other companies owned by or under common ownership as Aircore.
Social Media or Third-party Platforms: When an individual interacts with our Services through various social media networks, including through Reddit, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
Service Providers: Our service providers that perform services solely on our behalf, such as marketing providers and payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, and information about your communications and related activities. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
Information We Receive from Authentication Services You Connect to our Service: Some parts of our Service may allow you to login through a third party social network or authentication service, such as Google or GitHub. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site. If you choose to connect a Google or Gmail account to our Sites, we will ask you to grant us application permissions to access your Gmail account. These permissions are necessary to sustain the functionality of our Sites. We will store your authentication token and account email address. This data will be securely stored to be used by us to provide you with the Service (including but not limited to logging into your account and sending emails). This data will not be voluntarily shared with any third parties, but we may provide this information to legal authorities upon their lawful request. Should you choose to disconnect your Gmail account or decide to close your account, any information from Google that is stored on our servers will be removed permanently. We do not use data obtained from our customers (from their Google accounts) for advertising purposes. We may need access to the user data to resolve a support issue, provide advice on service usage or provide any other help requested by the user, or as such access may be necessary for a security investigation or to comply with applicable laws. We use this information to operate, maintain, and provide to you the features and functionality of the Service. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Site, technical and security notices).
Other Sources: We may also collect Personal Information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Aircore commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Aircore satisfies the requirements under applicable law.

Additional Uses of Personal Information

We may use personal information we collect to:

Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including providing you with a white paper you have requested or an online product demonstration;
Manage our organization and its day-to-day operations;
Verify your identity and entitlement to products or Services, when you contact us or access our Services;
Register you for and provide you access to events and webcasts;
Communicate with individuals, including via email, text message, social media and/or telephone calls;
For marketing and advertising purposes, including to market to you or offer you through email, direct mail, phone or text message information and updates on products or services we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
Process payment for our Services;
Facilitate customer benefits and services, including customer support;
Identify and analyze how individuals use our Services;
Conduct research and analytics on our customer and user base and our Services;
Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
Help maintain the safety, security and integrity of our property and Services, technology assets and business;
To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
Comply with contractual and legal obligations and requirements;
To fulfill any other purpose for which you provide personal information; and
For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

Our Disclosure of Personal Information

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

Within Aircore: We may share personal information with other companies owned or controlled by Aircore, and other companies owned by or under common ownership as Aircore, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the Third-Party Data Collection and Online Advertising section and our Cookie Notice for more information.
Business Partners: From time to time, we may share personal data with our business partners for transactional purposes.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:

in connection with the establishment, exercise, or defense of legal claims;
to comply with laws or to respond to lawful requests and legal process;
to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
to detect, suppress, or prevent fraud;
to protect the health and safety of us and others; or
as otherwise required by applicable law.

With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

Our Disclosure of Personal Information

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

Within Aircore: We may share personal information with other companies owned or controlled by Aircore, and other companies owned by or under common ownership as Aircore, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the Third-Party Data Collection and Online Advertising section and our Cookie Notice for more information.
Business Partners: From time to time, we may share personal data with our business partners for transactional purposes.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:

in connection with the establishment, exercise, or defense of legal claims;
to comply with laws or to respond to lawful requests and legal process;
to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
to detect, suppress, or prevent fraud;
to protect the health and safety of us and others; or
as otherwise required by applicable law.

With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

Third-Party Data Collection and Online Advertising

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

Please see Online Ads of the Control Over Your Information section below, to learn how you can opt out of interest-based advertising.

For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section below and our Cookie Notice.

Control Over Your Information

You may control your information in the following ways:

Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacy@aircore.io. We may not be able to modify or delete your information in all circumstances.
Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/ or if you are in the European Economic Area, United Kingdom or Switzerland: https://youronlinechoices.eu/.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

V.Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

Links to Third-Party Websites or Services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@aircore.io.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

United States

California

If you are a California Resident, please see our California Privacy Notice for additional California-specific privacy information.

Nevada

If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at privacy@aircore.io with the subject line “Nevada Opt Out Request” to submit such a request.

Colorado, Connecticut, Utah, Virginia

In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your personal information:

Right of access. You may have the right to obtain:

confirmation of whether, and where, we are processing your personal information;
information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
information about the categories of recipients with whom we may share your personal information; and
a copy of the personal information we hold about you.

Right of portability. You may have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
Right to rectification or correction. You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you.
Right to deletion or erasure. You may have the right, in some circumstances, to require us to delete erase your personal information.
Right to restriction. You may have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
Right to opt-out. You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or to “sell” or “share” your personal information with third parties in certain contexts.
Right to withdraw consent. If you have provided consent for the processing of your personal information, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
Right to appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.

To Exercise Your Right to Access, Right of Portability, Right to Correction, Right to Deletion, or Right to Appeal

Please submit a request by either:

Emailing us at privacy@aircore.io with the subject line, “Individual Rights Request,” or
Completing our Individual Rights Form

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of Connecticut. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and details of transactions on our Services.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

To Exercise Your Opt-Out Rights

Unless you have exercised your Right to Opt-Out, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration, or use your information for all the purposes described in this Privacy Notice, including for targeted advertising and certain profiling activities. The third parties to whom we share your personal information may use such information for their own purposes in accordance with their own privacy policies.

You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. We may not process your request if we, in good faith, believe that the request is fraudulent. In such instances, we will send a notice to the requestor explaining our decision.

To exercise the Right to Opt-Out of personal information sharing for targeted advertising purposes, certain profiling activities or data “sales,” you may submit a request by clicking on the following link:

‍‍RIGHT TO OPT OUT

‍European Economic Area, United Kingdom or Switzerland

The Aircore Data Protection Officer can be reached at: DPO@aircore.io

Legal Bases for Processing

We only process and retain your personal information as permitted under applicable law. For example, we will only process your information where we have established a lawful basis to do, as follows:

When it is necessary for the performance of a contract to which you are party, or to take steps at your request prior to agreeing a contract: This applies to any processing where you sign a contract with us, for example when you become our customer, participate in our affiliate or premium partner program, or deliver services to us as a vendor or contractor. This may also include our Terms of Service.
We have a legitimate interest which we believe outweighs your interests or fundamental rights and freedoms. This applies to the following processing activities:

When we communicate: To respond to your inquiries and, on some occasions, keep records in case of complaints or legal claims.
When you use our Services: When you access and use our Services, we process technical and analytics data to see if and how our Services can be improved, so that we can offer you a better user experiences in the future.
Global Suppression List: Avoid contacting you again if you have withdrawn your consent to marketing-related activities.
Marketing to existing customers (unless you have consented to such marketing): To find, customize and offer products and services we hope you find useful and relevant, i.e., provide you with excellent customer service.
Sharing personal information with other parties: To run our business efficiently and securely.

Your consent: Wherever you clearly consent to the processing, for example when you sign up for our newsletters or events, request a demo, or a free trial or a download. Here, your consent is implied, meaning that you consent by submitting a particular form. We also rely on your consent for using cookies and other technologies on our website and here you explicitly agree to these. Note that your default setting depends on your location (country), as the rules for using such technologies vary across jurisdictions.

We are subject to a legal obligation: For any processing where we need to comply with laws and regulations related to bookkeeping, accounting, taxation and employment, for example for keeping records.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).

If you wish to exercise one of these rights, please contact us using the contact details in this Privacy Notice or you may contact the Aircore DPO at DPO@aircore.io.

Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights.

Marketing and Advertising

From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our Services. Most marketing messages we send will be by email. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.

We may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule (where applicable). If you wish to unsubscribe from such communication, please see the details set out above under Control over Your Information.

Data Retention

We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in this Privacy Notice, and in accordance with our legitimate business interests and applicable law. For example, if your personal information is subject to the EU GDPR or UK GDPR, the criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:

Contract. Where we are processing personal data is based on contract, we generally will retain your personal data for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
Legitimate Interests. Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights and freedoms.
Consent. Where we are processing personal data based on your consent, we generally will retain your personal data until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that personal data.
Legal Obligation. Where we are processing personal data based on a legal obligation, we generally will retain your personal data for the period of time necessary to fulfil the legal obligation.
Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.

Storing and Transferring Your Personal Information

Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
International Transfers of Your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Services from the EEA, UK or Switzerland, your personal information will be processed outside of the EEA, the UK and Switzerland.

In the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Notice.