Privacy

Privacy Policy

AirWire Technologies

Privacy Notice

This “Privacy Notice” describes the privacy practices of Airwire Technologies and our subsidiaries and affiliates (collectively, “Airwire”, “we”, “us”, or “our”). This Privacy Notice describes how we collect, use, disclose and otherwise process personal information in connection with our websites, mobile applications (including the JAI Concierge mobile application (the “JAI App”)) and other services, and explains the rights and choices available to individuals with respect to their personal information. For convenience, our websites, mobile apps and our other services are collectively referred to as the “Services.” This Privacy Notice governs any of the Services on which the Privacy Notice is posted.

California residents should read the important information provided here.

Individuals located in the European Union and/or United Kingdom should be sure to read the important information provided here.

Personal Information We Collect

Information you give us

Personal information that you may provide through the Services or otherwise communicate to us includes, but is not limited to:

● Registration information. When you register or subscribe to any of the Services, you provide us with Personal Information such as your first name, last name, date of birth, gender, phone number, email and password.
● Feedback and correspondence information. You provide us Personal Information when you participate in market research activities, report a problem with the Services, receive customer support or otherwise communicate with us.
● Transaction details. When you make purchases through the Services, you provide us with billing and payment information. Where we use a third party payment provider to process payment card transactions, we collect the transaction details only (e.g., the invoice ID, and the date and amount of purchase).
● Voice and text data. When you utilize our JAI App, you may provide us with voice recordings and text data stored through the JAI App.
● Usage data. When utilizing our Services, you may provide us with Personal Information about how you use the Service and interact with us, including Personal Information associated with any content you upload to the JAI App or otherwise submit to us, and Personal Information you provide when you use any interactive features of the Service.
Information from Third-Party Accounts.
Our Services operate by connecting certain third-party accounts (“Third-Party Accounts”), such as Gmail or Smartcar, with your account. When you connect any Third-Party Accounts to the Services, you authorise us to process Personal Information provided to us by such Third-Party Accounts, based on your Third-Party Account settings and the permissions you grant at that time. We will process that Personal Information in accordance with this Privacy Notice. You may revoke our access at any time through your account.
Information automatically collected
We may automatically log Personal Information about you and your computer or mobile device when you access our Services. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Services.
We collect this Personal Information using cookies. Please refer to the Cookies and Similar Technologies section for more details.
Changes to your personal information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your account or emailing us at privacynotice@airwiretech.com
Cookies and Similar Technologies
What are cookies?
We may collect information using “cookies” only on our Services. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience in connection with our Services.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.
Cookies we use
Our Services use the following types of cookies for the purposes set out below:

Type of cookie	Purpose
Essential Cookies	These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered may include the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information, monitor the level of activity on our Services, and improve the Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available here.
Social Media Cookies	These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.
Targeted and advertising cookies	These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites. You can disable certain cookies by visiting this site. If you choose to remove targeted or advertising cookies, you will still see advertisements but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioural advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

Disabling cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.
Do Not Track Signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
How We Use Your Personal Information
To provide our Services
If you have an account or use our Services, we use your personal information to:

● operate, maintain, administer and improve the Services;
● manage and communicate with you regarding your account, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages
● provide support and maintenance for the Services; and
● respond to your service-related requests, questions and feedback.
To communicate with you
If you request information from us or register for the Services, we may send you Airwire-related marketing communications as permitted by law. You will have the ability to opt out of such communications.
For marketing and advertising
We may contract with third-party advertising companies and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to try to tailor the ads you see online to your interests based on your activity over time across our Service and other sites, or your interaction with our emails. These ads are known as “interest-based advertisements.” You can learn more about your choices for limiting interest-based advertising, in the Advertising choices section below.
To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
With your consent
We will request your consent to use your personal data where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal information, you may have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us.
To create anonymous data for analytics
We may create anonymous data from the personal information you provide to us through the Services. We exclude any information that may make the data personally identifiable to you. We reserve the right to use that anonymous data for our lawful business purposes.
For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate to: (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share your Personal Information
Affiliates
We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Notice.
Service Providers
We may engage third party companies and individuals to administer and provide the Services on our behalf (such as training, customer support, and hosting). These third parties may use your personal information only as directed by Airwire and in a manner consistent with this Privacy Notice, and are prohibited from using or disclosing your personal information for any other purpose.
Professional Advisors
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Advertising partners
We may disclose your personal information to third party advertising companies that collect information about your activity on the Services and other online services to help us advertise our services, and/or deliver you advertisements.
Compliance with Laws and Law Enforcement; Protection and Safety
We may disclose your personal information to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to: (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Business Transfers
We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient of such information to honor this Privacy Notice.
Your Choices
Access, Update, Correct or Delete Your Information
You may request to review, update, correct or delete your personal information, including stored voice recordings and messages, by contacting us at privacynotice@airwiretech.com.
Opt out of marketing communications.
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the communication. You may continue to receive service-related and other non-marketing emails.
Choosing not to share your personal information
Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.
Security
The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
You should take steps to protect against unauthorized access to your password and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Children
Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.
Sensitive Personal Data
We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) through the Services or otherwise to us.
If you send or disclose any sensitive personal data through the Services, you must consent to our processing and use of such sensitive personal data in accordance with this Privacy Notice. If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data through the Services.
International Transfer
We are headquartered in the United States and have affiliates and service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
Other Sites and Services
The Services may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Changes to this Privacy Notice
We reserve the right to modify this Privacy Notice at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Notice you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Services that we believe reasonably likely to reach you (which may include posting a new Privacy Notice through our Services or JAI App).
Any modifications to this Privacy Notice will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Notice indicates your acceptance of the terms of the modified Privacy Notice.
Contact Us
If you have any questions or concerns at all about our Privacy Notice, please feel free to email us at privacynotice@airwiretech.com, or write to us at:
AirWire Technologies
Attn: Legal
9670 Gateway Drive
Reno, Nevada 89521
Additional Information for California Residents
Subject to certain exceptions, the California Consumer Privacy Act and associated regulations (collectively, the “CCPA”) provides California residents certain privacy rights. To the extent the CCPA is applicable, this Section describes (1) the categories of CCPA Personal Information (defined below) that may be collected and disclosed by us, (2) rights of California residents under the CCPA, and (3) how to exercise those rights.
The term “CCPA Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

A. Categories of CCPA Personal Information Collected, Used, and Shared
We may have collected the below categories of CCPA Personal Information within the past 12 months.

● Identifiers: Information that could identify a consumer or household, such as real name, IP addresses, email address, and online identifiers.
● Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
● Internet or Network Activity: For example, information on interactions with a website, application, or advertisement.
● Geolocation Data: For example, device location data.
● Sensory information: Audio, electronic, visual, or similar information, for example, recordings from cameras or microphones.
● Profile Based on Inferences from Other Categories: For example, a profile regarding consumer preferences or characteristics.
● Personal Information: Includes items described in Cal. Civ. Code § 1798.80(e), some of which overlap with other categories, such as a name, signature, Social Security number, address, telephone number, driver’s license or state ID number, education, employment history, or credit/debit card number.
We may provide each of these categories of CCPA Personal Information to our service providers to the extent necessary for them to facilitate our business purposes, including those set forth above.

B. Your California Privacy Rights
Subject to certain exceptions, if you are a resident of California, you may have the following rights:

Privacy Right	Description
Right to Know	The right to be notified of what categories of CCPA Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Right of Access	The right to request the categories of CCPA Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the CCPA Personal Information was collected, the specific pieces of CCPA Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of CCPA Personal Information disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your CCPA Personal Information. If delivered electronically, the information shall be portable, and to the extent technically feasible, in a readily useable format.
Right to Delete	The right to have your CCPA Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your CCPA Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the CCPA Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your CCPA Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
Right to Opt-Out	The right to opt out of the sale of your CCPA Personal Information. We do not believe we have sold CCPA Personal Information in the last 12 months.
Right of Non-Discrimination	You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights, and you will not be discriminated against in any way by virtue of your exercise of these rights, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to privacynotice@airwiretech.com or fill out our online form at: www.airwiretech.com/privacy/.
We may need to verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
We may deny certain requests, or only fulfill some in part, as permitted or required by law (e.g., records retention for legal purposes such as tax accounting).
The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.
You may be eligible to receive a copy of this Section in an alternate format (e.g., printable) or language, and to do so please contact us using the information provided above.
Additional Information for Individuals in the European Union / UK
Personal information
References to “personal information” in this Privacy Notice are equivalent to “personal data” governed by European and United Kingdom data protection legislation.
Controller
AirWire Technologies is the controller of your personal information for purposes of European / UK data protection legislation. See the Contact Us section above for contact details.
Legal bases for processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at privacynotice@airwiretech.com.

Processing purpose (click link for details)	Legal basis
To provide the Services	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.
To communicate with you To create anonymous data for analytics For compliance, fraud prevention and safety For other legitimate business interests	These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with law	Processing is necessary to comply with our legal obligations
With your consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Services or by contacting us at privacynotice@airwiretech.com.

Use for new purposes
We may use your personal information for reasons not described in this Privacy Notice where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Your rights
European / UK data protection laws may give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

● Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
● Access. Provide you with information about our processing of your personal information and give you access to your personal information.
● Correct. Update or correct inaccuracies in your personal information.
● Delete. Delete your personal information.
● Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
● Restrict. Restrict the processing of your personal information.
● Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.
You can submit these requests by email at privacynotice@airwiretech.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.