Privacy Policy

This privacy policy ("Policy") describes how the Company (Summer Advisors Ltd) collects, uses, discloses and shares personal information of consumer users of this website https://theairr.com/ ("Website") as well as the information and materials provided in connection to it ("Contents"). The Company may offer for sale or download licenses to certain products or services provided on the Website to the Customers ("Services").

In accordance with the Terms of Service, the users having access to the Website and the Contents may be divided into two groups:

1. Legal entities willing to join/joined the Website on the commercial basis ("Customers");
2. Customers' investors, affiliated companies, other legal entities, employees, consultants, representatives and other third parties, who have granted access to the Website and relevant Content by the Customers ( "Customers' Users"), collectively referred to as the Users.

For the purposes of data collection and processing, the information provided is divided into two categories:

1. Information on Customers' Users, including but not limited to their personal data, provided by themselves, by relevant Users, collected automatically by the Website ("Customers' Users Data" );
2. Customers' information posted for processing and sharing with Customers' Users ( "Customers' Data").

This Policy determines a legal framework for collecting and processing of the Users' data by the Company.

I. Legal Requirements:

The Website is operated by the company Platform AIRR LTD, being subject to the EU regulation ("Company"), in particular, the General Data Protection Regulation (GDPR). In most cases, the Company processes personal information on behalf of the Users as a data processor, but in certain circumstances the Company processes personal information as a data controller for the purposes of communicating with the Users, administering the Users' accounts and for carrying out data analytics and enrichment.

To maintain high level of the privacy protection the Company strictly follows the GDPR. The Company's privacy policy is based on 6 main principles provided in GDPR:

1. Lawfulness, Fairness and Transparency: data processing is to be performed fairly, in accordance with applicable laws and in a transparent manner;
2. Purpose Limitation: data processing is limited to a purpose of the Services provision;
3. Data Minimisation: personal data collection takes place in a volume necessary for processing purposes;
4. Accuracy: the Company takes all reasonable steps to keep the Users' personal data accurate and up to date, otherwise the Company erases it;
5. Storage Limitation: the Company stores the Users' personal data in a form, which permits to identify the Users as a data subject as long as it is necessary for processing purposes;
6. Integrity and Confidentiality: while processing the Users personal data, the Company ensures protection against unauthorised or unlawful processing, accidental loss, destruction or damage

II. The Company uses the following methods of privacy protection:

• organizational measures, including employee training and limiting access on a "need-to-know" basis; and,
• technological measures, including the use of passwords and encryption

Before using the Website the Users shall express consent to have their personal data processed for purposes of the Services provision. The Users are entitled to withdraw their consent at any time. In order to comply with the applicable law, to open a personal account on the Website the Company may require the Users to provide some confidential information or personal data (including, but not limited to a scan of passport, utility bill, bank reference letter, CV, e-mail, mobile phone number for physical persons; corporate documents and financial statements for legal entities). Such requests are justified by legislation fighting the funding of terrorism and money laundering activities.

III. Personal Information the Company Collects

Protection of the Users' personal data is one of Company's major priorities. Personal data processing is performed in accordance with applicable law and in a transparent manner. The Company stores the Users personal data in a form, which permits to identify the Users as data subjects as long as it is necessary for processing purposes. While processing the Users personal data, the Company ensures protection against unauthorised or unlawful processing, accidental loss, destruction or damage. The following information may be collected and processed by the Company for abovementioned purposes:

1. Information collected directly from the Users input The Company may collect the Users' name/title, postal address, email address, phone number, username, password, demographic information (such as occupation), tax ID number, bank account information, as well as other information the Users provide while using the Website. The Company may also collect credit card information, banking information, and/or billing address of the Customers. Information hosted in the accounts of the Users is also treated as it may be personal data.
2. Information collected from publicly available resources The Company may get information about the Users from other sources, such as Internet websites, social networks and other publicly available resources.
3. Information automatically collected

The Company may collect information about the devices accessing the Website, including but not limited to information about the type of device, its location, operating system used, unique device identifiers and crash data. The type of information the Company collects depends on the type of device used and its settings. For example, when visiting the Website, the Company logs the Customers' Users' computer operating system type, browser type, browser language, pages they viewed, how long the Users spent on a page, location, access times and information about the use of and actions on the Website.

The Company does not use any identifiable processed data of Customers for its own purposes. Collected data is only processed by the Company on behalf of the Users to provide them with the Services under this Policy and the Terms. The Company does not collect or process the Users' data for any commercial purposes.

IV. Using the Information Collected

All personal information collected may be used on the following ways:

1. By using the information collected the Company seeks to improve the Website, the Contents, the Services provided to the Customers. For example, the Company may use the information to support delivery of the Services to the Customers, assist with their Service requests, monitor for errors, remedy security or technical issues, analyze the Website performance;
2. Information collected helps the Company verify the access to the Services;
3. Information collected may be used to update the Users on relevant new services and benefits as well as to send information including confirmations, invoices and billing, technical notices, updates, security alerts, and administrative messages;
4. The Company may use the Users personal information to combine it with other personal information already collected.
5. Information may be used to investigate, and deter against fraudulent, unauthorized, or illegal activity in order to protect the Users' rights and interests;
6. The Company may also collect information for data analysis, audits, enhancing the services, identifying usage trends and determining the effectiveness of the Services.
7. Collection of data is justified by complying with the Company's legal obligations, resolving disputes, and enforcing its agreements.

V. Sharing the Information Collected

The information collected by the Company is stored securely. However, in some cases personal information may be shared, but strictly in accordance with this Policy. The information collected may be shared in the following cases:

1. to comply with laws and regulatory requests;
2. to provide high level of personal data protection (reporting on security breaches, or assisting with investigating and preventing fraud or security issues);
3. to protect the Company's interests and rights by enforcing tsi agreements, policies, and terms of use;
4. to perform the Users' instructions (for example, open access for certain auditors, consultants and other third parties);
5. for marketing, analytics or research purposes (aggregated or anonymized data are to be used);
6. for maintenance purposes the information may be shared with the Company's employees in the volume necessary for performing duties;
7. with the Users' consent to engage third party companies or Customers' Users as service providers to process information and support the Company's "Services"

VI. "Opt-out" Option

The Company seeks to satisfy the best interests of the Users and provides an opportunity to "opt-out" from certain information provided. For example, the Company may send to the Users marketing e-mails with information on new services and products in order to propose the best options for business cooperation. If the Users are not interested in such e-mails, they may contact support@theairr.com to cancel this distribution. The Users may also use "opt-out" option to update, modify or delete any personal information collected by the Company. In this case the Users may contact support@theairr.com. The Company kindly notifies that "opt-out" option does not concern e-mails containing information about the Users' accounts, its security or the Company's business dealings with the Users that are necessary for fulfilling the Company's obligations.

VII. Third-parties Information

The Website may contain hyperlinks to websites operated by third parties. The Company does not review, control or examine the content of such websites and is not responsible for any third parties websites' content, availability, advertising, products, information, materials or use of information. The Users are encouraged to review the terms of use applicable to those sites.

VIII. How to contact us

For any questions or concerns about this Policy contact support@theairr.com