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
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.
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 email@example.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.
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.
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.
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.
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.
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 firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
As part of our participation in Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission.
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.
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 email@example.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.