Privacy Shield

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 (the “Privacy Shield Principles”) 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 about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

Purpose

The purpose of this Airtime Privacy Shield Statement (“Statement”) is to outline how we comply with the Principles with respect to the personal information we collect from EU and Swiss individuals and transfer into the United States. If you would like to obtain additional information regarding our privacy practices in connection with information collected on this website in general, please refer to our General Privacy Policy. If there is any conflict between this Statement and the Privacy Policy, this Statement shall prevail.

Scope

This Statement applies to any personal information received by Airtime from the European Union (including Lichtenstein, Norway, Iceland and the United Kingdom) or Switzerland in reliance on Privacy Shield Principles.

Airtime Data Processing Activities

Airtime at times acts as a data processor or a data controller when processing personal data transferred from the EEA or Switzerland. Though the types of data Airtime collects and processes may vary depending on the Account Terms and our customers’ preferences, data we collect typically includes personal information relating to students and schools, billing and payments information, web browsing behavior and other information relating to a user’s device used to access the services, and other information as described in our Privacy Policy. Airtime processes this data to provide our business and consumer services; billing and payments; customer service and product support; communications and marketing; online advertising; analytics to inform and improve our services; and for other internal purposes.

Principles

  1. Notice
  2. We will provide individuals with notice of our data collection and processing practices in our Privacy Policy, describing what personal information we collect, the purpose and use of personal information, the categories of third parties with whom we may share such information (and the purposes for which we do so), the individual’s right to access such information, the choices and means through which the individual may limit the use and disclosure of personal information, and other disclosures consistent with the Notice Principle.

    Where we process personal information on behalf of an educational or other institution (each a “School”) with which you have a direct relationship, we will assist them upon request to provide appropriate notice to you.

    You can read about our data collection and processing practices in our main Privacy Policy.

  3. Choice
  4. We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents and service providers, or before we use it for a purpose other than it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request to privacy@airtime.com.

    Where we process personal information on behalf of a School, we will work with that School to comply with any individual’s choices for limiting use or disclosure of personal information, if possible.

  5. Onward Transfers (Transfer to Third Parties)
  6. Airtime may transfer personal information to certain third parties (as further described in our Privacy Policy).

    Consistent with the Privacy Shield Principles, Airtime may transfer personal information to third parties in the following circumstances:

    • With the public, third parties, and/or other members of the service, when information is publicly available or when we have your consent or permission to make the disclosure.

    • With third party vendors, service providers or other agents that perform services on our behalf in connection with the operation of our business, for example, vendors who provide payments processing, fraud prevention, web hosting, or analytic services. These agents may process personal information only for a limited and specified purpose and we take reasonable and appropriate steps, including entering into written contracts, to ensure the agents will provide the same level of privacy protection as required by the Privacy Shield Principles. Where the transfer is to a third-party agent acting on our behalf, Airtime may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage.

    • With vendors or other third party data controllers that are not acting on our behalf, for example, third parties that perform online advertising or tracking services as described in our Privacy Policy. We share personal information with these third parties if you have not opted-out of such disclosure and we take reasonable and appropriate steps, including entering into written contracts, to ensure these third parties will provide the same level of privacy protection as required by the Privacy Shield Principles.

    • We may disclose personal information to third parties when the disclosure is reasonably necessary for compliance or regulatory purposes or the establishment of legal claims.

    • We may disclose personal information to a third party in connection with a company transaction, such as a merger, sale, reorganization or similar proceeding, provided the recipient is required to provide the same level of protection as required by the Privacy Shield Principles.

    • In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  7. Security
  8. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction.

  9. Data Integrity and Purpose Limitation
  10. We will process personal information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by individuals. Where we receive personal information from a School, it shall be the School that determines those purposes. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

  11. Access
  12. EU and Swiss individuals have the right to reasonable access to the personal information about you that we hold. On request, we will also take reasonable steps to correct, update, amend or delete any information that is demonstrated to be inaccurate, except where the burden or expense of doing so would be disproportionate to the risks to your privacy in the case in question or where the rights of third parties would be violated. Where we process personal information on behalf of a School, we will direct any individual requests for access or to limit use or disclosure to the School, and we will work with such School in complying with such requests in accordance with applicable law and our obligations under Privacy Shield.

    An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to privacy@airtime.com. If requested to remove data, we will respond within a reasonable timeframe.

  13. Jurisdiction and Enforcement
  14. As part of our participation in Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission.

  15. Lawful Requests
  16. Airtime may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  17. Contact Airtime and Recourse
  18. In compliance with the Privacy Shield Principles, Airtime commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. If you have any questions about this Statement or the information that we collect from you in reliance on Privacy Shield, please contact us at privacy@airtime.com or write to:

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

    In the event that you are concerned about how personal information you have provided to Airtime has been used, please address your inquiry or complaint first to us at the address listed above. Airtime takes all concerns about privacy and use of personal information very seriously, and shall endeavor to reply to you within 45 days of receiving a complaint.

    Airtime has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-customers for more information and to file a complaint. This service is provided free of charge to you.

    If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

    Last revision date.

    This page was last revised on, and effective as of July 24, 2019.