Airtime Privacy Policy

  1. What information do we collect and for what purpose?
  2. Legal basis for processing in the EU
  3. Use of cookies and other technology to collect information
  4. Sharing information
  5. Your choices regarding your information
  6. Third-party tracking and online advertising
  7. Security and storage of information
  8. The General Data Protection Regulation for residents in the EU
  9. Persons under the age of 13
  10. Links to third-party websites
  11. Updates to this privacy policy
  12. Contacting us
  13. Last revision date

Airtime Media, Inc.(“Airtime,” “we” or “us”) is committed to protecting your privacy. This Privacy Policy explains how personal information about you or associated with you(“personal information”) is collected, used and disclosed by Airtime and its affiliates. This Privacy Policy applies to our websites, and our mobile apps for iPhone, Windows or Android mobile devices (collectively, our "Service”).

By accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

For the purposes of EU data protection laws ("EU Data Protection Law"), Airtime is a data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO by dpo@airtime.com.

  1. What information do we collect and for what purpose?
  2. Generally, we collect personal information from our users in order to provide you with a personalized, useful and efficient experience. The categories of information we collect can include:

    If you choose not to provide personal data, we may not be able to provide the Service to you or respond to your other requests.

  3. Legal basis for processing in the EU
  4. In the EU, the purposes for which we process your personal data are:

    1. Where we need to perform the contract we are about to enter into or have entered into with you for the Service
    2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests such as: (i) to contact you and respond to your requests and enquiries; (ii) for business administration, including statistical analysis; (iii) to provide the Service to you; and (iv) for fraud prevention and detection; and
    3. Where we need to comply with a legal or regulatory obligation in the EU.

    We may also process your personal data on the basis of your freely given, specific, informed and unambiguous consent. You should be aware that you are entitled under Data Protection Law to withdraw your consent where that has been given, at any time.  If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Service.

    Please contact us at dpo@airtime.com if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out.

  5. Use of cookies and other technology to collect information.
  6. We, and our third party partners, automatically collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.  We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

    We use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our service.

    If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies and these browser settings that block cookies may have no effect on such techniques.  You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.

    We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.

  7. Sharing Information
  8. We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Your Choices Regarding Your Information” section below.

    Remember, our Service allows you to connect and interact with others. Your profile information, including your name, photo, and other personal information, will be available publicly to other members of the Service by default when you create a profile, interact with others on the Service in public groups, and post content to public spaces.

    We may also share your personal information with:

    We may also share information with others in an aggregated and anonymous form that does not reasonably identify you directly as an individual.

  9. Your choices regarding your information.
  10. Profile and Data Sharing Settings: You may update your profile information, such as your user name and profile photo, and may change some of your data sharing preferences on your Settings page.

    Access to your Device Information: You may control the app’s access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the app to access your photo stream and camera.

    Notifications: We may communicate with you via in-app notifications. We require your permission to send you notifications when you create an account. You may opt-out of receiving notifications by adjusting your app notification settings on your mobile device. If you turn off notifications from Airtime, you will not receive any notifications regarding your messages or updates from your friends or groups.

    Marketing Communications: If you do not wish to receive promotional emails, you can change your email preferences on your Settings page on our websites, or you can click the “unsubscribe” button on promotional email communications. Note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, donation confirmations, change or updates to features of the Service, or technical and security notices.

    Data Retention: We will retain your information for as long as your account is active or as needed to provide you services and communicate with you. Please contact us at privacy@airtime.com if you wish to delete your account permanently from our systems. Please be aware that we will not be able to delete any content you have shared with others or with social media sites.

    Deleting or Anonymizing Your Content: If you are under 18 years of age, you may request that the User Content that you posted to the Service be deleted or anonymized such that your personal information will not be identifiable publicly on our Service by contacting us at privacy@airtime.com. While we will use all commercially reasonable efforts to delete or anonymize your User Content upon request, please be aware that due to the social nature of our Service, you may not be able to completely remove all of your personally identifiable User Content if, for example, that content has been stored, republished, or reposted by another user or a third party. We may also maintain your information in identifiable form for our internal use, even if your personal data is no longer visible to the public on our Service.

  11. Third party tracking and online advertising.
  12. Interest Based Advertising. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history.  We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our website and apps over time so that they may play or display ads on our Service, on other devices you may use, and on other websites, apps or services, including on Facebook.  These third parties may collect information such as click stream information, browser type, time and date you visited the site, mobile device identifiers, app usage, and/or precise geolocation data and other information. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

    Social Media Widgets and Advertising. Our Service may include social media features, such as the Facebook Like button, Google Plus, LinkedIn, Snapchat, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Service, and they may set a cookie or employee other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

    We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them. For example, we may work with Facebook to display interest-based ads to you or to your friends on Facebook through a tool offered by Facebook called the Custom Audience Tool. This tool allows us to personalize our ads based on you or your friends’ experience on our Service in order to provide ads tailored for each specific recipient. We do not share personal information about your activities on our Service with Facebook, but we share a hashed email address or phone number which permits Facebook to identify our advertising audience based on the information that Facebook collects from its users. If you do not want to receive interest-based ads on Facebook, you can adjust your ad preferences through your Facebook settings. If you do not want us to use your content to personalize advertising that we direct to your friends on Facebook, you may email us at privacy@airtime.com.

    Cross-Device Linking. We, or our third party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third party partners who employ tracking technologies, or the application of statistical modeling tools, to determine if two or more devices are linked to a single user or household.  We may share a common account identifier (such as an email address or user ID) with third party advertising partners to help recognize you across devices.  We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.

    Your Choices:

  13. Security and storage of information
  14. Airtime cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

    For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see above under "What information do we collect and for what purpose?"), except if required otherwise by law.

    Your information collected through the Service may be stored and processed in the United States or any other country in which Airtime or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and such transfers are made pursuant to appropriate safeguards. For more information regarding Airtime’s compliance with the U.S.-EU and U.S.-Swiss Privacy Shield Principles, please see our Privacy Shield Privacy Statement.

  15. The General Data Protection Regulation for residents in the EU
  16. If you are located in the EU, you have the following rights under the General Data Protection Regulation (GDPR) in respect of your personal data that we hold:

    If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

    You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

    Airtime complies with the U.S.-EU Privacy Shield Framework and U.S.-Swiss 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 from European Union and Switzerland to the United States, respectively. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program and to view our certification page, please visit https://www.privacyshield.gov. For more information regarding Airtime’s compliance with the U.S.-EU and U.S.-Swiss Privacy Shield Principles, please see our Privacy Shield Privacy Statement.

  17. Persons under the age of 13.
  18. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have inadvertently collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information collected from a child under 13, please contact us at privacy@airtime.com.

  19. Links to third party websites.
  20. The Services may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.

  21. Updates to this Privacy Policy.
  22. We reserve the right to modify this Policy from time to time. If we make any changes to this Policy, we will change the "Last Revision" date below and will post the updated Policy on this page. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Policy means that you are consenting to the changes.

  23. Contacting us.
  24. If you have questions about this Privacy Policy, please contact us at privacy@airtime.com or by writing to us at:

    Privacy Department
    Airtime Media Inc.
    PO Box 1598
    New York, NY 10016

    Last revision date.

    This Privacy Policy was last revised on, and effective as of December 18, 2018.