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Privacy Policy

Last update: September 24, 2019

Airtm Inc., Airtm Ltd., Airtmexico SA DE CV and any affiliated companies (collectively, and hereafter referred to as "Airtm," "we," "us," or "our") recognize and respect the importance of protecting the privacy of visitors to our website. In this Privacy Policy, we explain what types of

personal data we may come to process and for what purposes when you access our website located at Airtm.com, or any other websites, pages, features, or content we own or operate (collectively, the "Site(s)") and/or when you use the Airtm mobile app, any Airtm API or third party applications relying on such an API, and related services (referred to collectively hereinafter as "Services”. We also explain the choices you have in relation to our processing and how you can learn more about our processing and exercise your rights.

If you have any questions about this Privacy Policy, you may contact us via email at support@airtm.com.

ACCEPTANCE OF PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described below. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Services prior to the change becoming effective.

COLLECTION OF PERSONAL INFORMATION

Information You Provide to Us

Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized data as it cannot be used to identify you.

We will only collect personal information with your expressed consent and by first notifying you of the purposes for our doing so. For every purpose, you will have the option to provide consent or not. We collect personal information to provide you with our Services. When we require certain personal information from users it is because we are required by applicable law to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us.

For example, we collect personal information which is required under the law to open an account, add a payment method, or execute a transaction. We also collect personal information when you use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or sign up for an Airtm event. We may also collect personal information from you offline, such as when you attend one of our events, or when you contact customer support. We may use this information in combination with other information we collect about you, as set forth in this Notice.

Information We Collect Through Use of Our Services

When you use our Services, we may collect information about you in the following general categories:

Identity Information: When you create an account or use Airtm Services, we, or our vendors acting on our behalf may collect the following types of information to meet our legal obligations: your name, date of birth, social security number, driver number ID, personal ID, address, phone, email, full bank account details and/or credit card numbers that you link to your Airtm account or input when you use Airtm Services. Airtm will use this information to fulfill your requests and provide the relevant Services.

Location Information: If you permit the Airtm app to access location services through the permission system used by your mobile operating system (“platform”), we may collect the precise location of your device when the app is running in the foreground or background. We may also derive your approximate location from your IP address.

Contacts Information: If you permit the Airtm app to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Statement or at the time of consent or collection.

Transaction Information: We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged, and other related transaction details.

Usage and Preference Information: We collect information about how you and site visitors interact with our Services, preferences expressed, and settings chosen. In some cases we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Statement.

Device Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.

Communication Data: Our Services facilitate communications between verified Members. In connection with facilitating this service, we receive communication data, including the date and time of the communication and the content of the communication.

Log Information: When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.

Important Information about Platform Permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Airtm app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Airtm app seeks before you first use the app, and your use of the app constitutes your consent.

Information We Collect from Other Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example, when you request Services, other Members may provide us with a User rating after conducting a Peer to Peer transaction with you. We may also receive data from third parties about you. This may include technical data from analytics and advertising partners like Google, from public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws.

USE OF INFORMATION

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of how we may use this information include:

To comply with our legal obligations.
To prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms.
To process transactions and send notices about your transactions.
To verify your identity by comparing your personal information against third-party databases.
To send administrative or account-related information to you.
To enforce our agreements with third parties.
To resolve disputes, collect fees, and troubleshoot problems.
For quality control and staff training.
To enhance security, monitor and verify identity or service access, combat spam or other malware or security risks.
To provide you with Airtm Services and customer support that you request.
To better understand our customers and end-users and the way they use and interact with Airtm Services.
To provide a personalized experience, and implement the preferences you request.
To communicate with you about our events or our partner events.
To customize, measure, and improve Airtm Services and the content and layout of our website and applications.
To deliver targeted marketing, service update notices, and promotional offers based on your communication preferences (where this in accordance with the law).

Sharing of Information

We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. Airtm will never sell or rent your personal information. We may share the information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:

We share your information with third party identity verification services in order to prevent fraud. This allows Airtm to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.

We share your information with Onfido Limited ("Onfido") to verify your identity and to perform required regulatory screenings. Airtm only shares your information with Onfido in accordance with this Privacy Policy. Information shared with Onfido is treated by Onfido in accordance with its Privacy Policy, available at https://onfido.com/us/privacy/.

We share your information with Kount Inc. ("Kount") to perform transaction monitoring and screening for fraud prevention. Airtm only shares your information with Kount in accordance with this Privacy Policy. Information shared with Kount is treated by Kount in accordance with its Privacy Policy, available at https://www.kount.com/legal/privacy-policy.

With another Member to enable them to perform a requested peer to peer transaction;

With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public or other Members;

With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate;

With Airtm subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and / or logistics purposes;

With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;

In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;

With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Airtm or others;

In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;

If we otherwise notify you and you consent to the sharing; and

In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

HOW WE PROTECT YOUR INFORMATION

We have implemented security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We protect your personal information by maintaining physical, electronic, and procedural safeguards. We use network safeguards such as firewalls and data encryption, enforce physical access controls, and authorize access to personal information only for those people who require access to fulfill their job responsibilities.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address or mailing address listed below.

HOW LONG WILL WE RETAIN YOUR PERSONAL DATA

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, provided however that we may keep your personal information for five years or more from the date you cease to be our customer, depending on applicable law or regulations in the jurisdictions we operate.

DATA TRANSFER

We share information globally, both internally within Airtm, and externally with our partners and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide our Services to you. We utilize standard contract clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States and other countries.

DATA ACCESS RIGHTS

It is our obligation to only process personal that is accurate, relevant and necessary taking into account our legitimate purposes and your consent. You have the right to control that we do so, including the right to withdraw consents you have previously provided as we'll exercising the right to be forgotten by having us delete all personal information we have collected. You may exercise your rights to update personal information, change consents and/or request that your personal information be deleted permanently through account controls on the website, where applicable. Alternatively, you may contact us in the following manner:

By post: Airtm Inc., Att: Airtm Privacy Statement, 8 The Green, Suite A, Dover, DE 19901

By email: support@airtm.com

Airtm will comply with individual’s requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law.

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