Legal

Privacy Statement through July 1, 2023

Effective as of September 19, 2022. — Previous Version

Airship Group, Inc. and its affiliates, including, Apptimize, LLC., Urban Airship UK Ltd., Urban Airship Germany GmbH, Airship France SAS, and Urban Airship India Private Ltd. (collectively, “Airship,” “we” or “us”) offers mobile and customer engagement platforms, including the Gummicube ASO services.  Airship is committed to protecting the privacy of Personal Information you provide to us, and applies the Privacy by Design and Data Protection by Default principles across our product enhancement, development, and operations.  When referring to “Personal Information” in this Statement, we mean information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. your name, email address, device information, IP Address). Accordingly, Airship provides this privacy and information practices statement to inform you about our information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Statement”).

1. What this Privacy Statement covers.

This Privacy Statement applies to Personal Information that we collect when you: (i) visit websites we operate and that link to this Privacy Statement, including www.airship.com and www.apptimize.com (the “Sites”); (ii) use our training and testing mobile or software applications, mobile wallet passes, or any other software applications made available by us for use on or through computers and mobile devices that link to this Privacy Statement; (iii) visit our branded social media pages; (iv) visit our offices; (v) receive communications from us, including emails, phone calls or texts; (vi) register for, attend and/or otherwise take part in our events, webinars or contests; (vii) submit a job application to us; (viii) submit information to us in connection with a potential business relationship with us; or (ix) register to use the Airship Platform as an authorized user (for example, as an employee of one of our customers who provided you with login access to the Airship Platform) or contact us for support, referred to in this Statement as “Account Information”, (collectively, including the Sites, the “Services”).  “You” refers to any individual who visits or uses the Services.

In general, with respect to the Personal Information we collect directly from the Sites or other Services, Airship is a data controller. This means that as a data controller we determine the purposes for which and the manner in which the Personal Information we collect is to be processed. 

With the exception of Account Information, this Privacy Statement does not apply to our security and privacy practices concerning the Personal Information we receive and process on behalf of our customers through Airship’s technology platforms (including the Airship Customer Engagement Platform, and the Apptimize Testing Platform) and related services (collectively, “Airship Platform”).  In this capacity, we are acting in the role of a data processor or service provider on behalf of our customers, and our security and privacy commitments are detailed in and governed by our agreements with our customers, including the Terms of Subscription Service or such other applicable agreement entered into between our customer and Airship and that is related to our customer’s access to and use of the Airship Platform. Airship does not have control over and is not responsible for the data practices of our customers.  For privacy information related to our customers’ uses of the Airship Platform in connection with their mobile applications, websites, emails, texts or other digital properties, please reach out to the respective customer directly. 

In addition, the Services may contain links to other third party websites.  The privacy statements and policies of such third party websites govern their respective personal information and security practices as provided in Section 12 of this Privacy Statement. California residents and customers with business in the State of California may read our supplemental CCPA Privacy Notice here.

2. What Personal Information does Airship collect?

The Personal Information we collect will be determined by the type of interaction you have with Airship, as described in further detail in the following categories:  

2.1 Personal Information we collect directly.

Site usage. When you use the Services or fill out forms on our Site, we may provide you with opportunities to sign up to receive specific information or Services, download content, or register for an event or webinar, and we may ask for your contact information. Personal Information we may collect includes, but is not limited to:  name, title, company name, industry, company address, phone number or email address, country, downloads and engagement with Airship content and other publications.  Our sites use cookies and other technologies, and as a result we also collect information as described in Section 5 below. When activating or installing updates to our mobile applications or mobile wallet passes, we may collect information about your device (manufacturer, model, IP address), or information about the application such as the version, date of activation, successful or unsuccessful updates. 

Registering for and attending a meeting or an event.  If you register to attend an event or meeting (whether in  person or online), we may ask for your contact information (name and email address), job title, employer, and may retain copies of meeting audio and video recording in accordance with our Data Retention Policy and based on your consent to participate in a recorded meeting. If you attend an event, we may, with your consent, scan your attendee badge which will provide us with your information, such as name, title, company name, address, country, phone number,email address, and record of event attendance.

Your communications with us. We collect Personal Information from you such as name, email address, phone number, mailing address, job title, marketing subscription status, and information regarding your engagement with Airship content and other publications when you request information about our Services, register for our newsletter, download or otherwise engage with our content and publications, request customer or technical support, apply for a job or engage with a job posting, or otherwise communicate with us.

Account Information for Airship Platform. If you register to use the Airship Platform as an authorized user  or sign up for a free account, we collect Personal Information about you that may include name, email address, IP address, company name, job title, and website name or information.  

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include name, email address, employer, job title and other contact information.. 

Social media content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

Registration for sweepstakes or contests. We may run sweepstakes and contests.  Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners. 

Visiting our offices.  If you visit our offices, you may be required to register as a visitor and provide your name, email address, phone number, company name and time and date of arrival. If applicable, we may also collect screening information as permitted by applicable law related to our health and safety protocols during the COVID-19 pandemic.

2.2 Personal Information collected from others.

Information from Other Sources. We may also receive other information including your Personal Information from other sources and third parties such as public databases, joint marketing partners, social media platforms, as well as from other third parties who provide us with contact information for prospects or leads. When acquiring information from third parties, we will obtain contractual or other legally compliant commitments from the third parties that the information was acquired lawfully and with the appropriate level of consent.

Billing Information. Through our third-party billing and payment processors, and to the extent we charge a fee for the Services, we may collect billing, payment, and contract related information from you if you are a business representative of one of our customers.  

3. How does Airship use Personal Information and what are the legal bases for these uses?

We use Personal Information that we collect about you or that you provide to us for a range of different business purposes.  Depending on how you interact with us, we and our third-party service providers use Personal Information in a variety of ways, including:

Providing information and Services you requested. We may use the Personal Information about you to fulfill requests for programs, Services, or information that you may request such as information about potential or future Services, including to: (a) generally manage your information and accounts; (b) respond to questions, comments and requests; (c) provide access to certain areas and features of the Services; (d) link or combine information we get from others to help understand your needs and provide you with better Service; and (e) allow you to register for events, participate in a contest or promotion, post in a forum or participate in webinars, and provide related information and communications.

To fulfill a contract or take steps linked to a contract. This is relevant when you register for the Airship Platform. We may use the Personal Information about you for administrative purposes or to fulfill the obligations of a contract, including, without limitation, to: (a) to fulfill your and prospective customers’ requests related to the Airship Platform or other products that you have requested; (b) to provide you with the Airship Platform for which you have registered; (c) perform internal quality control; (d) maintain and improve our Services; (e) verify identity; (f) send communications regarding the Services, your account, or any changes to any Airship policy or terms of use; (g) process payments; (h) provide technical and customer support; and (i) enforce our Terms of Use, Acceptable Use Policy or other agreement entered into with you.

Marketing products and services. We may use Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or information about future services. We may provide you with these materials by phone, postal mail, text or email, as permitted by applicable law. Such uses include: (a) to tailor content, advertisements, and offers; (b) to notify you about offers, products, and services that may be of interest to you; (c) to provide Services to you; (d) measure interest in the Services; (e) process and deliver contest entries and rewards; (f) monitor and analyze trends, usage and activities in connection with our Services; (g) for other purposes disclosed at the time that you provide Personal Information; or (h) otherwise with your consent. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.

Research and development. We may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products, processes and services. 

Deidentified and aggregated data. We may use your Personal Information and other information about you to create de-identified or aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. De-identified or aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified or aggregated information is not Personal Information, does not identify you or any individual, and Airship may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within Airship and with third parties for our or their purposes in a de-identified or aggregated form that is designed to prevent anyone from identifying you. 

Public content. If you post any content to our website forums or social media accounts, we may publish this content and make it generally available to any user or visitor of our website.

Complying with legal obligations.  We may use your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligation under applicable laws to protect our rights or as necessary to protect against misuse or abuse of our Sites or Services, prevent potentially prohibited or illegal activities and fraud, promote safety and security of the Services and in protecting our rights and the rights of others, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.

Other Uses. We may use your Personal Information for other purposes disclosed to you at the time you provide Personal Information, with your consent or to conduct our business and pursue our legitimate interests, such as registering and managing visitors to our offices, investigating and responding to any comments or complaints that you may send us, providing internal training, and recruiting, interviewing and hiring job candidates. 

4. With whom does Airship share Personal Information?

We disclose your information to third parties only as necessary to carry out your request, for a variety of our professional or legitimate business purposes, including to provide our Services, to protect us or others,  in the event of a major business transaction such as a merger, sale, or asset transfer, as described below, or as otherwise required or permitted by law. Where we do transfer your personal data to third parties or service providers, appropriate safeguards will be in place in order to ensure correct and secure data processing in compliance with applicable data protection law.

4.1 Disclosures to provide our Services

Service Providers. Airship may share Personal Information with our service providers that we have retained to perform Services on our behalf including (i) provision of IT, hosting, backup, storage, and related Services; (ii) provision of information and Services you have requested; (iii) payment processing and to collect amounts owed to Airship; and (iv) customer service activities. These third-party service providers may have access to or process your Personal Information for the purpose of providing these services for us. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. Airship has executed appropriate contracts with our service providers that prohibit service providers from using or sharing your Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Business Partners. From time to time, Airship may partner with other companies to jointly offer products, services or programs (such as webinars, events or downloadable content). If you purchase, specifically express interest in, or register for a jointly-offered product, service or program from or through Airship, we may share your Personal Information with our business partners. Airship does not control our business partners’ use of shared Personal Information and their use of such Personal Information will be in accordance with their own privacy policies. If you do not wish for your Personal Information to be shared in this manner, you may opt not to purchase or to specifically express interest in a jointly-offered product or service, or you may otherwise opt-out through any mechanism offered at the time the Personal Information is collected.

Affiliates. We may share Personal Information with our affiliated companies. 

Advertising Partners. Through our Services, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. Please refer to Section 5 below for more information on how these technologies and tracking tools work.  If you prefer not to share your Personal Information with third-party advertising partners, you may follow the instructions in Section 11 below. 

4.2 Disclosures to protect us or others

Protection of Airship and others. We may disclose Personal Information about you when we have a good faith belief that we are required to provide information: (a) if we are required to do so by law, court order or legal process; (b) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (c) under the discovery process in litigation; (d) to enforce Airship policies or contracts; (e) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (f) if we, believe that disclosure is otherwise necessary or advisable. 

In addition, from time to time, server logs and other systems may be reviewed for security purposes (e.g., to detect unauthorized activity on the Services). In such cases, records containing Personal Information may be shared with service providers, third parties and law enforcement bodies in order that they may prevent fraud and/or identify users in connection with their investigation of the unauthorized activities.

4.3 Disclosure in the event of merger, sale, or other asset transfers

Business Transfers. We reserve the right to disclose or transfer any Personal Information in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). 

5. What device and usage data does Airship process?

We use common information-gathering tools for collecting usage data, cookies, web beacons and similar technologies to automatically collect information that may contain Personal Information from your computer or mobile device as you navigate our Sites or use our Services.

5.1 Cookies, web beacons and other tracking technologies in our Services.   

As you navigate the Sites and use the Services, certain passive information may also be collected through the use of cookies, web beacons and other tracking technologies to obtain certain information about your computer, device, browsing actions, and patterns. This includes IP addresses, cookie IDs, navigational data, content clicked, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, your browser settings, your device type and similar information, the date and time you access our Services and other device identifiers. This type of information is used for the purposes of gathering data to provide improved administration of our Services and to improve the quality of your experience when interacting with our Services (see Your Privacy Rights section below for more information). If you consent to the use of cookies and web beacons when you navigate the Sites and use the Services, we will collect information through those tools. 

Cookies. A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, to develop a record of the user’s online activity. When you visit our Sites, we or an authorized third party may place a cookie on your browser and/or device which collects information, including Personal Information, about your online activities over time and across different sites.  Cookies allow us to track usage, determine your browsing preferences and improve and customize your browsing experience.  For more information about cookies and web beacons, please visit http://www.allaboutcookies.org/.  

We use both session-based and persistent cookies on our Sites.  Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your computer or device.  Persistent cookies remain on your computer or device after you close or turn off. You can control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our Services.  

Types of cookies on our Sites.

• Essential Cookies. These cookies are necessary for the Sites to function and cannot be switched off. Some examples include: session cookies needed to transmit the website, authentication cookies, and security cookies. These cookies also support certain features on the Sites, such as the live chat feature. You can set your browser to block or alert you about these cookies, but some parts of the site will then not work. 
• Functional Cookies.  These cookies enhance functions, performance and services on the Sites. They enable us to count visits and traffic sources so we can measure and improve the performance of our Sites. Functional cookies also enable us to improve how our Sites function and to help us provide you with more relevant communications, including marketing communications.  They help us to know which pages are the most and least popular and see how visitors move around and use the Sites. We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications and to enable certain features on the Sites.
• Targeting Cookies.  These cookies track activity across websites in order to understand a visitor’s interest, and to direct specific marketing to them.  Targeting and advertising cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. 

To change your cookie settings and preferences for the Site you are visiting, use the Cookie Settings link at the bottom of the webpage. 

Web beacons. We also use web beacons (sometimes called “pixel tags” or “tracking pixels”). These are tiny graphics files that contain a unique identifier that is embedded in our Sites and in our emails or other communications that are sent through our Services. This enables us, for example, to monitor the traffic patterns of users from one page within our Site to another, to track access to the communications sent through our services, to understand whether you have come to our Sites from an online advertisement displayed on a third-party website or whether you have viewed advertisements on our Sites or through the Services, or to improve our Sites’ performance. For more information about cookies, and how to disable them, please see “Your Privacy Choices” below.

SDKs. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties, including analytics and advertising partners, to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you.

5.2 Social media features.   

Airship may collect Personal Information to enable individuals to use online social media resources offered either by Airship or a third party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.

In addition, social media links such as Facebook, LinkedIn, Twitter, Instagram and YouTube (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our Site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features apart from your visit to our Site are governed by the privacy policy of the company providing it.

5.3 Analytics.   

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting and other similar providers to collect information regarding visitor behavior and visitor demographics on some of our Sites, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. You can also opt out of our analytics partners by setting your preference in the Cookie Settings link at the bottom of the web page of the Site you are visiting.

6. International data transfers

We store Personal Information sent or collected via or by us in the United States or the European Economic Area, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. To facilitate our global operations, we may transfer, store and access such information from the locations where Airship has operations – specifically the United States, France, Germany, the United Kingdom, or India. Your Personal Information may be processed in any of these countries, and they may have data protection laws that are different or that may not provide the same level of data protection as your country.  For such cases, we rely on international transfer mechanisms such as the European Commission approved Standard Contractual Clauses, adequacy decisions about certain countries, or we will ask you for your prior consent for the transfer of your Personal Information, as applicable. In addition, we ensure the recipient of your Personal Information has in place adequate levels of protection for your Personal Information. For more information about the protections in place and a sample copy of the model contractual clauses, please contact us at privacy@airship.com.     

7. Privacy Shield framework*

Notwithstanding the fact that it has been held to no longer provide a valid mechanism for transfers of Personal Information from the EU to the U.S., Airship continues to comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland and the United Kingdom to the United States in reliance on Privacy Shield. Airship has certified to the Department of Commerce that the company adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern, as applicable. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Airship commits to resolve complaints about our collection or use of your Personal Information. EU, Swiss and UK individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: privacy@airship.com.

If your Personal Information was received in reliance on the Privacy Shield Framework and you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider JAMS, at no cost to you, at https://www.jamsadr.com/eu-us-privacy-shield. Under certain conditions, more fully described on the Privacy Shield website, https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration after other dispute resolution procedures have been exhausted.

Airship remains liable for the processing of Personal Information received under the Privacy Shield and subsequently transferred to a third party acting on our behalf if this entity processes such Personal Information in a manner inconsistent with the Privacy Shield Principles.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Airship is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

*The Privacy Shield program does not apply to Airship Group, Inc.’s affiliate, Apptimize, LLC, and the Apptimize Service.

8. What security measures does Airship have in place?

The security of Personal Information provided to us is of utmost importance  to us. We have implemented industry-standard technical, administrative, and physical safeguards to help protect information on our servers against unauthorized access, alteration, disclosure or destruction. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify us at privacy@airship.com.

9. How long does Airship retain Personal Information?

We retain the Personal Information we receive as described in this Privacy Statement for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

10. Are Airship’s Sites intended for children?

Due to the nature of our business, Services are not marketed to or intended for minors under the age of 18. Airship does not knowingly solicit or collect Personal Information from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the Contact Us information below, and we will take steps to delete such Personal Information from our Services.

11. Your privacy rights

You have certain choices available to you when it comes to your Personal Information. Below is a summary of those choices, how to exercise them and any limitations.

Opt-out. Where you have consented to our processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this section. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Where your consent for the processing of Personal Information is otherwise required by law or contract, we will comply with the applicable law or contract.  Note that, due to the nature of the Services or of the Airship Platform, you may have to log in to your account or provide the email and/or other identifying value that is associated with your Personal Information in order for us to complete your request. Note that if you withdraw your consent to processing, some features of the Services may not be available.

Email unsubscribe. An “Unsubscribe” link will be provided in each email communication sent by us so that you can opt out. However, we may continue to send non-promotional, transaction-related emails regarding any products, the Airship Platform, or any Services you have requested in response to your  request. We may also need to send you certain communications regarding our programs and Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Use or this Privacy Statement).

Opt-out of cookies and ads. We will only use cookies with your permission in compliance with applicable laws. You may stop or restrict the placement of technologies on your device or remove them by adjusting your preferences as your browser or device permits, or for this Site using the Cookies Settings link at the bottom of the webpage. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.  To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Airship does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. For information about “do-not-track”, visit http://www.allaboutdnt.org.

Access, correct, amend, port, restrict processing, or delete Personal Information. You have the right to control or change certain uses and disclosures of your Personal Information, as set out in this Privacy Statement. Subject to any exemptions provided by law, you have the right to: seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request to know more details about the categories or specific pieces of personal information we collect; to ask that we correct, update, amend or delete your Personal Information; to ask that we do not sell your Personal Information (where “sale” is defined according to the local regulations in your state of residency); and to not be discriminated against for exercising these rights. Please note that we do not currently sell your Personal Information as sales are defined under the laws of Nevada or California, as further detailed below in the sections dedicated to those locations. We will respond to such requests within a reasonable timeframe. 

You may log into your account or email privacy@airship.com to exercise one of the individual rights outlined above with regard to Personal Information held about you by us. Such requests will be processed in accordance with local laws. We will respond to such requests within a reasonable timeframe. Although we make good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. In addition, please note that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

EU residents. If you are located in the European Economic Area or the UK, in addition to the rights mentioned above, you also have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law. In addition, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making currently does not take place on our Sites or Services.

CA residents. Please refer to the California Privacy Rights page here.

Colorado residents. If you are a resident of Colorado, you have the right to: opt out of the processing of Personal Information; seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request deletion of Personal Information; or obtain and transfer your Personal Information. You can exercise these rights by contacting us at privacy@airship.com with the subject line “Colorado Data Rights Request” and providing us with your name and the email address associated with your account. 

Nevada residents. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at privacy@airship.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

Virginia residents. If you are a resident of Virginia, you have the right to: seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request corrections of inaccuracies in your Personal Information; request deletion of Personal Information; or to opt out of processing of your Personal Information for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.  Please note that we do not currently sell your Personal Information or engage in profiling as those terms are defined in the Virginia Data Consumer Protection Act. You can exercise these rights by contacting us at privacy@airship.com with the subject line “Virginia Data Rights Request” and providing us with your name and the email address associated with your account. 

Customer Data. If you are an individual seeking to exercise your data protection rights (including to seek access to, or to correct, amend, delete, port or restrict processing) in respect of Personal Information stored or processed by us on behalf of one of our customers within the Airship Platform, then you should direct your request to our customer (the data controller). Upon receipt of a request from one of our customers for us to remove the personal data, we will respond to their request within provided in our agreements with the customer. We will retain Personal Information that we process and store on behalf of our customers for as long as needed to provide the services to our customers.

Redress, compliance and accountability. If, after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact: privacy@airship.com.

Airship will address your concerns and attempt to resolve any privacy issues in a timely manner.

If you are an EU, Swiss or UK citizen and feel that Airship is not abiding by the terms of this Privacy Statement, please contact us at the contact information provided below. If any request remains unresolved, you may contact the national data protection authority for your EU Member State, Switzerland or United Kingdom.

12. Third party sites

Please note that our Services may contain links to other websites or digital properties for your convenience and information. We do not control third-party websites, digital properties or their privacy practices, which may differ from those set out in this Privacy Statement. We do not endorse or make any representations about third-party websites or digital properties. Any Personal Information you choose to give to an unrelated third party is not covered by this Privacy Statement. We encourage you to review the privacy policy of any company, website or digital property before submitting your Personal Information. Some third parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Statement.

13. Changes to this Privacy Statement

We may update this Privacy Statement from time to time as deemed necessary in our sole discretion. We will provide notification of any material changes to this Privacy Statement through our Sites or as otherwise required by applicable law. We encourage you to review this Privacy Statement periodically to be informed regarding how we are using and protecting your Personal Information and to be aware of any policy changes. Your continued relationship with us after the posting or notice of any amended Privacy Statement shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Statement take effect immediately after being posted or otherwise provided by us.

14. Contact Us

If you have any questions about our privacy practices or this Privacy Statement, or if you wish to submit a request to exercise your rights, please contact us at:

Airship Group, Inc.

1225 West Burnside, Suite 401

Portland, OR  97209

privacy@airship.com

1-855-385-3155