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Privacy Policy

LAST UPDATED: July 11, 2022

TABLE OF CONTENT

1. Introduction

2. What information do we collect?

3. How do we use your information?

4. Who will your information be shared with?

5. Do we use cookies and other tracking technologies?

6. How do we handle your social logins?

7. Is your information transferred internationally?

8. What is our stance on third-party websites?

9. How long do we keep your information?

10. How do we keep your information safe?

11. Do we collect information from minors?

12. What are your privacy rights?

13. Do we make updates to this policy?

14. How can you contact us about this policy?



  1. INTRODUCTION 

Thank you for choosing to be part of the Airtm community! Here at Airtm, we take privacy very seriously. Through this Privacy Policy, we are going to explain to you what information we collect, how we use it and what rights you have in relation to it; take some time to read it carefully.

If there are any terms in this Privacy Policy that you do not agree with, or if you have any questions or concerns about our policy or our practices with regards to your personal information, please contact our Privacy Officer at digitalrights@airtm.io

This Privacy Policy applies to all information collected through our websites (https://www.airtm.com/en/), mobile applications ("Apps"), products, services, sales, marketing or events (we refer to them collectively in this Privacy Policy as the "Services").

If you are a U.S. consumer and have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.

Airtm reserves 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 email address specified in your account) or by means of a notice on our Services before the change takes effect.

Summary 

  1. Introduction

  2. What information do we collect?

  3. How do we use your information?

  4. Who will your information be shared with?

  5. Do we use cookies and other tracking technologies?

  6. How do we handle your social logins?

  7. Is your information transferred internationally?

  8. What is our stance on third-party websites?

  9. How long do we keep your information?

  10. How do we keep your information safe?

  11.  Do we collect information from minors?

  12.  What are your privacy rights?

  13.  Do we make updates to this Privacy Policy?

  14.  How can you contact us about this Privacy Policy?


2. WHAT INFORMATION DO WE COLLECT? 

2.1 Personal information (PI) you voluntarily disclose to us.  

→ In Short: We collect the personal information you provide to us such as name, date of birth, full address, contact information, passwords and security data, payment information, and social media login data.

We collect personal information that you voluntarily provide to us, both during online and offline activities, such as when registering on our website or in our Apps, expressing an interest in obtaining information about us or our Services, when participating in activities on our platform (such as posting messages in our online forums or entering competitions, contests or giveaways), events, or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. 

The personal information we collect can include the following:

• Name and contact data: when you create an account or use of our Services, we, or our providers acting on our behalf, may collect the following types of information to comply with our legal obligations: your name, date of birth, social security number, driver identification number, personal identification number, address, telephone, email, full bank account details and / or credit card numbers that you link to your Airtm account or enter when you use Airtm Services, and your country and state of residence. Airtm will use this information to satisfy your requests and provide the corresponding Services.

• Credentials: we collect passwords, password hints, and similar security information used for authentication and account access;

• Transaction data: Airtm collects transaction details related to your use of our Services, including the type of service requested, the date and time the service was provided, your financial account information, the amount charged and other details related to the transaction. 

• Social Media login data: we provide you with the option to register using social media account details, like your Facebook, Google or other social media account; if you choose to register in this way, we will collect the Information described in the section called "Social Logins" below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.


2.2 Information automatically collected

→ In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.

We automatically collect certain information when you visit, use or navigate the Services; this information does not directly reveal your name or contact information, but may include other information that is reasonably capable of being associated with you, such as device and usage information, IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily used to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. 

In some cases,  information is automatically collected through the use of cookies, pixel tags and similar technologies that create and maintain unique identifiers. For more information about these technologies, please refer to our Cookie Statement.

2.3 Information collected through our Apps 

→ In Short: We may collect information regarding your geo-location, mobile device, push notifications, and Facebook permissions when you use our Apps.

Please note: Important information about platform permissions 

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that applications cannot access without their consent. These mobile platforms have different permission systems to obtain your consent. The applicable platform may notify the user the first time that the Airtm application requests permission to access certain types of data and allow the user to give his consent (or not) to that request. For example, Android devices will notify you of the permissions that our Apps request before you use them. If you do not agree to give our Apps permission to use the requested information, please do not use our Apps.

If you use our Apps, we may also collect the following information:

• Geo-Location information: if you allow the Apps to access location services through the permission system used by your mobile operating system ("platform"), we may collect the exact location of your device when the application is running in the foreground or in the background. We can also derive your approximate location from your IP address.

• Mobile device access: we may request access or permission to certain features from your mobile device. For example, if you allow the Apps to access your device's address book 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 Privacy Policy or at the time of consent or collection. If you wish to change our access or permissions, you can do it in your device’s settings.

• Mobile device data: we may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

• Communication data: the Services offered by Airtm facilitate communication between verified Airtm users. In connection with the facilitation of this service, Airtm receives communication data, including the date and time of communication and the content of the communication.

• Push notifications: we may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

• Registration information: when you interact with the Services,  we collect server logs, which may include information such as your device's IP address, dates and times of access, the features of the application or pages visited, application crashes and other system activity, the type of browser and the third-party site or service you were using before interacting with our Services.

• Social logins: If you log in to our Services using a third-party account such as a Facebook account or Google account, we, by default, access your basic account information made available by that third party. For example, if you log in via your Facebook account we access your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

2.4 Information collected from other sources

→ In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

Airtm may also receive information from other sources and combine it with the information we collect through our Services. For example, when a user requests services, other users can provide us with a user rating after making a P2P transaction. 

We may also receive data about our users through third parties. This may include technical data from analytical and advertising partners such as Google, public databases, credit bureaus, identity verification partners, resellers and channel partners, joint marketing partners and social media platforms. Our identity verification partners use a combination of government records and public information available about you to verify your identity. This information includes your name, address, job function, public employment profile, credit history, status on the sanctions lists maintained by public authorities and other relevant data. 

Airtm obtains such information to comply with its legal obligations, such as anti-money laundering laws.


3. HOW DO WE USE YOUR INFORMATION?

→ In Short:  In general, we use personal information to create, develop, operate, deliver and improve our services, content and advertising, as well as for loss prevention and fraud prevention purposes. 

We use personal information collected via our Services for a variety of business purposes described below:

• Legitimate business interests ("Business Purposes");

• In order to enter into or perform a contract with you ("Contractual Reasons");

• For compliance with our legal obligations ("Legal Reasons"). 

We use the information we collect or receive for the following purposes:

• Account Creation. We use your full name and basic contact data, national identifiers and your credentials or your Social Media login data (as applicable) to facilitate account creation and the account login process, with your Consent. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we also use the information you allowed us to collect from those third parties to facilitate account creation and the account login process. See the section below headed "How do we handle your social logins?” for further information.

• Identity Verification. We use your full name and basic contact data, national identifiers,  geolocation data, and information collected from other sources, such as our identity verification partners, in order to verify your identity. We do this for Legal Reasons such as compliance with anti-money laundering laws. For more information about our identity verification practices, please refer to the “Who will your information be shared with?” section of this Privacy Policy below.

• Marketing. We use your full name, basic contact data and geographic location to send you marketing and promotional communications. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" information below).

• Account administration. We use your full name and basic contact data, your financial and transaction data, and automatically collected data to send you administrative information. We send you this information for Business Purposes, Legal Reasons and/or in some cases for Contractual Reasons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

• Performance of the Services. We use your full name and basic contact data, your financial and transaction data, and automatically collected data to provide our Services to you. For example, we may use your information to fulfill and manage your transactions and exchanges made through the Services. We use this information for Contractual Reasons.

• Testimonials. We use your name, email and other testimonial details you provide to us to post testimonials relating to the Services. We post testimonials on our Services that may contain personal information. If you wish to update, or delete your testimonial, please contact us.

• Targeted Advertising. We use your basic contact data, e-mail address and location to deliver you targeted advertising. We may work with third parties to develop and display content and advertising tailored to your interests and/or location and to measure its effectiveness. For more information about targeting advertising that is delivered in connection with your use of the Services, please refer to our Cookie Statement.

• Feedback. We use your full name, e-mail and transaction data to request feedback. We may use your information to request feedback and to contact you about your use of our Services.

• Safety and Security. We use your full name and basic contact data, national identifiers, your financial and transaction data and information collected from other sources, to protect our Services, for Business Purposes and/or Legal Reasons. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention) and for complying with our national and international legal obligations. 

• User-to-User Communications. We use your full name and basic contact data, as well as your financial data to enable user-to-user communications, with your consent. 

• Enforcement. We use your full name and basic contact data, national identifiers,  your financial and  transaction data, automatically collected data and information collected from other sources to enforce our terms, conditions and policies, for Business Purposes, Legal Reasons and/or in some cases for Contractual Reasons.

• Subpoenas and Other Legal Requests. We use your full name and basic contact data, national identifiers, your financial and transaction data, automatically collected data and information collected from other sources  to respond to legal requests and prevent harm, for Legal Reasons. For example, if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. In general, we can use your information to resolve disputes, charge fees and solve problems.

• Internal Business Purposes. We use your full name and basic contact data, your transaction data, behavior data and other automatically collected data and information collected from other sources for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, our marketing and enhancing your user experience. We also use the information for quality control and staff training.


4. WHO WILL YOUR INFORMATION BE SHARED WITH?

→ In Short: We share information to comply with laws, to protect your rights, and to fulfill business obligations.

We take care of allowing your personal information to be accessed only by those who reasonably need it to perform their tasks and duties, and sharing it with third parties who have a legitimate purpose to access it. We may share the information we collect about you as described in this Privacy Policy or as described at the time of collection or processing, including for the following purposes: 

• Identity - Verification: we share your information with third-party identity verification services to comply with applicable regulations and to keep track of our users and prevent illegal activities. This sharing allows Airtm to confirm your identity by comparing the information you provide us with public records and other third-party databases. These service providers may create derived data based on your personal information that can be used only in connection with the provision of identity verification and fraud prevention services. Airtm’s ID-Verification partners include:

  • Onfido Limited

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

  • Kount Inc.

We share your information with Kount Inc. ("Kount") to track transactions and detect fraud. Airtm only shares your information with Kount in accordance with this Privacy Policy. The information shared with Kount is treated by Kount in accordance with its Privacy Policy, currently available at https://kount.com/legal/privacy-policy/  . 

  • RegTech

We share your information with Regtech Inc. (“Regtech”) to manage AML-related procedures like identity verification, name screening, transaction monitoring, etc.

Airtm only shares your information with Regtech in accordance with this Privacy Policy. The information shared with Regtech is treated by Kount in accordance with its Privacy Policy, available at http://amlpartners.com/regtech-one-platform/

• Compliance with laws and regulations: we may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital interests and legal rights: we may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

 • Vendors, consultants and other third-party service providers: we may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. 

We may also allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time: this information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. We also allow certain third-party advertising partners to collect information about the users of our Service for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting.  To learn more about online advertising and how you may be able to control some of this activity, please refer to our Cookie Statement. Unless otherwise described in this Privacy Policy, we do not sell or rent your information, or trade any of your information with third parties for their promotional purposes. 

• Business transfers: we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Third-Party advertisers: we may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you (see our Cookie Statement for more details). 

• Affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

• Business Partners: we may share your information with our business partners to offer you certain products, services or promotions.

• We may disclose your personal information for any other purpose with your Consent.

• Other users and general public: with other members so that they can carry out a requested peer-to-peer transaction.

Moreover, when you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Site or App, such personal information may be viewed by all users and may be publicly distributed outside the Site and our App in perpetuity.

If you interact with other users of our Services and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

→ In Short: although we do not use First Party Cookies, we do use Third Party Cookies and other tracking technologies to collect and store your information.

We may use tracking technologies to access information. For example, Localization Cookies and AWS Cloudfront help Airtm to provide a localized experience: we use them to verify if our service is provided in your country and for providing the service in your preferred language. 

In addition to our tracking technologies, we may also use various Third  Party Cookies and technologies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on. Please refer to our Cookie Statement for more information about our use of these technologies.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

→ In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.

Our Services offers you the ability to register and login using your third-party social media account details (like your Facebook or Google logins): where you choose to do this, we will receive certain profile information about you from your social media provider. 

The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. 

We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the Services; please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider, so we recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.


7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

→ In Short: We may transfer, store, and process your information in countries other than your own.

We share information globally, both internally between Airtm and its affiliates, and externally with our partners and with those with whom you connect and share worldwide in accordance with this Privacy 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 described in this Privacy Policy. 

Please note that these data transfers are necessary to provide you with our services. If the country of destination does not have data protection or other laws as comprehensive as those in your country, we will  take  measures to transfer your personal information in accordance with this Privacy Policy and applicable law.

8. WHAT IS YOUR STANCE ON THIRD - PARTY WEBSITES?

→ In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

The Services may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. 

We cannot guarantee the safety and privacy of data you provide to any third parties: any data collected by third parties is not covered by this Privacy Policy and we are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites Services. 

You should review the policies of such third parties and contact them directly to respond to your questions.


9. HOW LONG DO WE KEEP YOUR INFORMATION? 

→ In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 

In general, we keep your personal information for 5 years from the date you cease to be our client, as required by the bank secrecy and anti-money-laundering laws that Airtm must comply with. The criteria used to determine the period for which personal information about you will be retained varies depending on the legal basis under which we process the personal information:

• Consent. Where we are processing personal information based on your Consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain circumstances, to have certain of your data erased (as described in more detail in our Privacy Rights Policy).

• Business Purposes. Where we are processing your personal information for our Business Purposes, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects.

• Contractual Reasons. Where we are processing personal information for Contractual Reasons, we generally will retain the information 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 the contractual relationship. 

• Legal Reasons. Where we are processing personal information based on a legal obligation, we generally will retain the information for the period of time necessary to fulfill the legal obligation. In some cases, we may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal 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 information, as well as the potential risk of harm from unauthorized use or disclosure of your personal information. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible. 


10. HOW DO WE KEEP YOUR INFORMATION SAFE?

→ In Short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate security measures designed to protect your personal information.

Airtm has implemented appropriate technical and organizational security measures designed to protect the security of any personal information processed: we protect your personal information by maintaining physical, electronic and procedural safeguards. We use network safeguards such as firewalls and data encryption and authorize access to personal information only for those who require access to fulfill their work responsibilities.

However, please remember that we cannot guarantee that the Services are  100% secure and transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment, use a secure password and take personal basic security measures (for example, do not share your account details and passwords with other people and remember that Airtm never asks for your password or other account details via email, text message or similar ways). 

In addition, we cannot guarantee or guarantee the security or confidentiality of the information you transmit to us or receive from us over the Internet or wireless connection, including email, telephone or SMS, since we have no way to protect 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 postal address indicated in Section 14. 

11. DO WE COLLECT INFORMATION FROM MINORS?

→ In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age: by using the platform, you represent that you are at least 18.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. 

If you become aware of any data we have collected from children under age 18, please contact us as soon as possible (Section 13 for contact details).  


12. WHAT ARE YOUR PRIVACY RIGHTS?

→ In Short: In some jurisdictions, such as the United Kingdom, the European Economic Area, many Latin American countries and some US states, you have rights that allow you greater access to and control over your personal information.

Depending on which country’s laws apply, your privacy rights may include:

• The right to request access and obtain a copy of your personal information;

• The right to request rectification of your personal information;

• The right to request erasure of your personal information;

• The right to restrict the processing of your personal information;

• If applicable, the right to data portability;

• If applicable, the right to object to the processing of your personal information;

• Where we rely on your consent for processing of your personal information, as described in this Privacy Policy, you may also have the right to withdraw your consent to such processing. 

If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority). If you are based in the European Economic Area, Switzerland or the United Kingdom, information about how to contact your local data protection authority is available here. However, we encourage you to first reach out to us by using the contact details set out in the Contact Us section below so that you have an opportunity to address your concerns directly and so that we may find a solution together before you lodge a complaint. 

For more information about your privacy rights and how to exercise them, please see our Privacy Rights Policy

13. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

→ In Short: Yes, we will update this Privacy Policy from time to time.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. 

We encourage you to review this Privacy Policy frequently to keep informed about our privacy practices.

14. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

If you have questions or comments about this Privacy Policy, email our Privacy Officer at digitalrights@airtm.io or send us a letter at:

Airtm Inc. 

500 108th Ave NE

Suite 1100

Bellevue, WA 98004


We would be happy to hear any feedback and answer any questions you may have.



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