Table of Contents
IMPORTANT INFORMATION AND WHO WE ARE
The term “Airlab Services” applies to the advertising platform, websites, games and other applications, and/or services controlled, operated or produced by Airlab and all advertisements and other content referenced therein.
If you have any concerns about the way Airlab process your personal data, you are welcome to contact Airlab’s data protection officer at: firstname.lastname@example.org, or write to Airlab.
Airlab will look into your enquiry and make good-faith efforts to resolve any existing or potential dispute with you. If you remain unhappy with the response you received, you can also refer the matter to your local data protection authorities.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
THIRD PARTY LINKS
Our websites or apps may, from time to time, contain links to and from the websites of our partner networks, ad partners and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data.
Please check these policies before you submit any personal data to Airlab Services or use our Airlab Services.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Device Data
- Financial Data
- Identity Data & Contact Data
- Location Data
- Marketing and Communications Data
- Transaction Data
- Usage Data
- We explain these categories of data here in the section CATEGORIES OF PERSONAL DATA BELOW.
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 offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect and process the following data about you:
Information you give us. This is information you consent to giving us about you by filling in forms on the App and the Services Sites (together Airlab Services), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use Airlab Services.
Information we collect about you and your device. Each time you visit one of Airlab Services we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
Depending on the Airlab Services you use we will rely either on consent or other lawful basis to process your personal data.
We will get your consent before sending third party direct marketing communications to you via email or text message. Please note that you have the right to withdraw consent to marketing at any time by contacting us.
You may, of course, decline to share your personally-identifiable information with Airlab. However, this means you will be unable to use the Airlab Services.
To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD AND ACCOUNT INFORMATION AT ALL TIMES
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
Please see below GLOSSARY: LAWFUL BASIS to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we will use your data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/activity when Airlab is acting as a data controller
|Type of data
|Lawful basis for processing
|To install the App and register you as a new App user
|To process in-App purchases and deliver Services including managing payments and collecting money owed to us
|To administer and protect our business and this App including troubleshooting, data analysis and system testing
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
|To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App
|Device Usage Location
|Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)
|Purpose/Activity when Airlab is acting as a data processor
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|Identity & Contact
|Performance of a contract with you
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
|Identity & Contact Financial Transaction Marketing and Communications
|(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
|Identity & Contact Marketing and Communications
|(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
DISCLOSURES OF YOUR PERSONAL DATA
We will not share your personal data for marketing purposes with companies outside Airlab, unless you have given us permission to do so.
However, in addition to the ways described above, we may share your information in the following ways:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- When the law requires us to disclose your information, we will comply
- When we need to enforce our Terms of Service, investigate fraud, reduce credit risk, exercise our legal rights or defend against legal claims
- When it is necessary for the protection of a person’s life, body or property and when obtaining your prior consent is difficult
- Your Choices and Access to your personal data
Whenever we transfer your personal data to other countries, we ensure a similar degree of protection is afforded to it by ensuring adequate safeguards are implemented. Safeguards that may be used include but are not limited to the followings:
- Transferring your personal data only to countries that have been deemed to provide an adequate level of protection for personal data.
- Implementing other appropriate safeguards, such as :
- Using the Standard Contractual Clauses adopted by the European Commission; and
- Transferring data to recipients in the United States of America who have certified their compliance with the Privacy Shield administered by the US Department of Commerce.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information. In others, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Airlab does not allow users under 13 years old to access the Airlab Services nor does Airlab knowingly collect or maintain personally identifiable information from persons under 13 years-of-age. If Airlab learns that personally-identifiable information of persons less than 13-years-of-age has been collected on or through the Airlab Services, then Airlab will take the appropriate steps to delete this information.
If you are the parent or legal guardian of a child under 13 who has become Airlab Services member, then please contact Airlab at email@example.com to have that child’s account terminated and information deleted.
If you are between the age of 13 and 18 please obtain your parents ‘permission prior to registering with our Airlab Services or providing us with any personal data.
Ad partners & Developers responsibilities and engagements
Airlab will not knowingly target any advertisements to children under the age of 13 or collect information about children under the age of 13, and if we become aware of the collection of such knowledge, will purge that information from our systems immediately.
By using the Airlab Services, ad partners and developers are agreeing not to use our services to provide advertisements to children under 13 and are ensuring their own compliance to COPPA standards.
We rely on our ad partners and developers to report any conflicts to us and do not maintain an aggressive enforcement program regarding our ad partners and developers.
The Airlab Services are not to be used in any child-directed advertisements. Any use of behavioral advertising will result in the ad partner’s account being terminated immediately. If an ad partner becomes aware that their advertisements have come into conflict with COPPA, the ad partner is required to report this to Airlab immediately.
If, you feel that any ad partners or developers are not in compliance with COPPA or other regulations, we encourage you to contact us.
YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please see below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer or your personal data.
- Right to withdraw consent.
You can exercise any of these rights at any time by contacting Airlab at: 2 Cresswell Gardens, Flat 3, SW5 0BJ London or by email: firstname.lastname@example.org. We will respond to your inquiry within 30 days of its receipt.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal third parties
- Group companies: We may share your Personal data with any member of our group of companies.
External third parties
- Trusted third parties partners: We work with trusted third party partners to perform tasks on our behalf and we may need to disclose your personal data to them to provide services to you. However, these companies are bound by confidentiality agreements with us and do not have any independent right to use your Personal data beyond what is necessary to assist us.
- Other users: We may display your chosen user name / company name / App name, along with statistics relating to advertising and user engagement on our sites and Apps and to other users of Airlab Services. Your other personal data cannot be seen by other users unless you post it in your profile or areas accessible by other users.
- Specific third parties:
- Ad partners
- Adcolony – https://www.adcolony.com/privacy-policy/
- Applovin – https://www.applovin.com/privacy/
- Facebook – https://www.facebook.com/about/privacy
- Fyber – https://www.fyber.com/privacy-policy/
- Google – https://policies.google.com/privacy
- Inmobi – https://www.inmobi.com/privacy-policy/
- Ironsource – https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
- Mopub – https://www.mopub.com/legal/privacy/
- Vungle – https://vungle.com/privacy/
- Analytics partners
- Appsflyer – https://www.appsflyer.com/privacy-policy/
- Google – https://policies.google.com/privacy
- Ad partners
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Airlab may need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the data is not accurate, complete or updated, then you may provide us with the necessary information to rectify it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Airlab may postpone or deny your request if your personal data is in current use for providing the Services or due to other legitimate purposes, such as compliance with regulatory requirements associated with Airlab.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- (a) if you want us to establish the data’s accuracy;
- (b) where our use of the data is unlawful but you do not want us to erase it;
- (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
DESCRIPTION OF CATEGORIES OF PERSONAL DATA
- Device Data: includes the type of device you use, a unique device identifier (for example, your Device’s advertising ID), network information, Internet Protocol address (“IP Address”), your operating system, the type of browser you use, time zone setting, the content and pages that you access on the Airlab Services, and the dates and times that you visit Airlab Services.
- Financial Data: bank account and payment card detail, business bank accounts, credit cards or PayPal accounts so as to facilitate payments between Ad partners, networks and publishers.
- Identity Data & Contact Data: first name, last name, email address, username, password, company name, company website, network account keys, and/or other persistent identifiers.
- Location Data: includes your current location disclosed by your IP address.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Transaction Data: includes details about payments to and from you and in-App purchases history.
- Usage Data: includes details of your use of any of the Airlab Services including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
We do not represent or warrant that our websites/apps will be available at all times, or that your use of the websites/apps will be uninterrupted or error-free. We are not responsible for your ability to access the websites/apps or for matters beyond our control.
Airlab’s EU Representative
You may contact Airlab’s EU representative at the address below:
Airlab EU Representative
5 rue du Général Delestraint