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. Your California Privacy Rights
  11. Your Nevada Privacy Rights
  12. Links to third-party websites
  13. Updates to this privacy policy
  14. Contacting us
  15. 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:

    • Information you provide.
    • When you create an account, we need to collect some information about you. We may collect and store personal information you provide to us when you register for our Service, including your name, phone number, email address, password, photo or avatar, and location. We may also collect any communications between you and Airtime and any other information you provide to Airtime.

    • Data collected through the use of the Service.
    • We collect information about how you use the Service, your actions on the Service, and content you post to the Service, including the groups you belong to, your interaction with your friends and with others on the Service, and photos and videos you post to the Service through in-app messages, chat, photos, videos (“User Content”). To share photos and video, we will access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in the “Settings” app of your device. Please remember that Airtime may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. You consent to the recording, storage and disclosure of such communications you send or receive for these purposes.

    • Information we receive from social networking sites.
    • We may receive personal information about you from third parties and combine that with information we collect through our Service. For example, we may obtain information when you login through a third party social network or authentication service, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. Similarly, when you interact with our site through various social media, such as when you like, follow, or share our content through Facebook, Twitter, Pinterest, Instagram or other sites, we may receive information from the social network including your profile information, profile picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties. If you permit the social network to share your friends list or contact list information, we may use information about your connections on social media to let you know what your friends are doing on our Service, and to let your friends know what you are doing on the Service, and we may use it to suggest new friends you may want to connect with. The data we receive is dependent upon your privacy settings with the social network. Please understand that your Airtime contacts may post information about you on their social media sites and we cannot control what our users post on third party websites and services. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Service.

    • Address Book Information
    • With your permission, Airtime may access your contact list available on your mobile device or in your email accounts in order to locate your friends and contacts on the Service and to invite your friends and contacts to connect with our Service. When we invite your friends to join the Service, we will include your name and photo to let them know that you are the person extending the invitation. After sending these invitations, we may also send reminder emails to your invitees on your behalf, which may also include your name and photo. We will store these contacts for purposes of alerting you when your contacts join Airtime at a later time so that you may connect with them on the Service, and to suggest friends and connections to other members of Airtime. Airtime may also use the information collected from your contact list and your friends’ contact lists to suggest new friends you may want to connect with on the Service. We make these recommendations based on your address book information as well as your friends’ address book information and try to find common friendships or connections to introduce you to.

    • Information we receive from third parties.
    • From time to time, we may receive information about you from third parties and other users. We may also collect information about you that is publicly available.

    • How we use information generally
    • We use this information to operate, maintain, and provide to you the features and functionality of the Service, to personalize content and messaging that may be most relevant to you, to develop and improve our products and services, as well as to communicate directly with you, such as to send you email messages and push notifications, and permit you to communicate with others on the Service or on social media or invite others to join the Service. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see “Your Choices Regarding Your Information” below.

    • How we use information to customize the Service and our Advertising.
    • We may use your information to customize the Service and our communications and messaging to you and to others in all media, in which it may appear now or in the future. For example, we analyze the information provided by you and others, including, for example, information provided in your address book, your Airtime connections, and, subject to your privacy settings, your friends and connections on social media, to suggest other users you may know or that you may want to connect with on the Service. We may include your photo or avatar in email communications and invitations promoting our Service that are tailored to the recipient. For example, if you ask us to invite a friend to join Airtime, we may send an email invitation to that friend that includes a photo of you (to let them know you are the person extending the invitation) as well as a photo of one or more other users that we believe may know the same friend. Similarly, we may include your photo in invitations sent by other Airtime users to recipients we think may know you. We may also use information about you and your activities on the Service, including your photo, to provide personalized content, including targeted content and advertising on our site as well as on other sites and services, including on Facebook. We use data to help make the advertisements we show more relevant to you and to others, but we do not use your content in your email, chat, or video calls to target ads to you. By using our Service you agree that we may use your information to customize your content and provide you with more targeted advertising, as well as to customize the content and promotional messaging we send to others. 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:

    Where we need to perform the contract we are about to enter into or have entered into with you for the Service.

    Where we need to comply with a legal or regulatory obligation in the EU.

    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 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.

    • The public and other members of the Service.
    • Your profile information and content you post to public areas of the Service, including public groups, will be viewable by others on the Service and the public. We may include your public information, including your name and photo, in customized content and promotional messaging to other users or potential users. Please do not provide personal information you would not want to be public. You may be able to control the visibility of some of your information and actions in your Settings (see “Your Choices Regarding Your Information” below);

    • Other users of the Service.
    • We share your information with third parties with whom you communicate with on the Service. You control who you want to communicate with and what information you share. Sharing information with others on our platform is done at your own risk;

    • Third parties at your request.
    • For example, you may have the option to share your activities on Airtime with your friends through email, text or on various social media sites;

    • Other brands owned or controlled by Airtime
    • and other companies owned by or under common ownership as Airtime, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, to the extent permitted by law. These companies will use your personal information in the same way as we can under this Privacy Policy;

    • Third party vendors, consultants and other service providers
    • That perform services on our behalf, in order to carry out their work for us, which may include identifying and serving targeted advertisements, content or service fulfillment, or providing analytics services;

    • Other parties in connection with any company transaction
    • Such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings;

    • Third parties as required
    • to as required by law or if we reasonably believe that such action is necessary to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use Agreement, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Airtime, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

    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.
    • 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.

  10. Third party tracking and online advertising.
    • 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:

      • Interest-based advertising.
      • To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu

      • Cross-device linking.
      • Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

      • Mobile advertising
      • You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

        Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

      • Google Analytics and Advertising
      • We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices .

  11. Security and storage of information
  12. 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.

  13. The General Data Protection Regulation for residents in the EU
  14. 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:

    • Right of access
    • The right to obtain access to your personal data;

    • Right to rectification.
    • The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete;

    • Right to erasure.
    • The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed;

    • Right to restriction
    • The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data;

    • Right to portability
    • The right to portability allows you to move, copy or transfer personal data easily from one organization to another;

    • Right to objec
    • You have a right to object to processing based on legitimate interests and direct marketing.

    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.

  15. Persons under the age of 13.
  16. 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

  17. Your California Privacy Rights.
  18. If you are a California resident, California’s “Shine the Light” law, Civil Code Section 1798.83, permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at privacy@airtime.com. Please note: this Privacy Policy will be updated to inform you of any rights you may have under the California Consumer Privacy Act (CCPA) when it goes into effect in 2020.

  19. Your Nevada Privacy Rights.
  20. If you are a Nevada resident, you may have certain rights with respect to the sale of your personal information. Please contact us by emailing privacy@airtime.com to exercise your rights under Nevada law.

  21. Links to third party websites.
  22. 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.

  23. Updates to this Privacy Policy.
  24. 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.

  25. Contacting us.
  26. 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

  27. Last revision date.
  28. This Privacy Policy was last revised on August 26, 2019, and effective as of September 26, 2019.