Privacy Policy

Last updated: 13 December 2022

This Privacy Policy discloses the privacy practices of AIRTOMIC PTY LTD, a company duly incorporated in Australia, having its business address at 81-83 Campbell Street Surry Hills NSW 2010, our offices, subsidiaries, and associated companies (“Airtomic,” “we” or “us”).

Airtomic receives, collects, stores and manages personal information according to the following Privacy Policy, with the goal of incorporating the “Privacy by Design” approach. When collecting your personal information, Airtomic ensures the secure storage of your data by taking appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of personal information. For the purpose of this Privacy Policy, Airtomic is the owner and data controller.

By using our website https://airtomic.co/ (“Website”), you agree to the terms and conditions of this Privacy Policy.

This Privacy Policy forms a binding agreement between Airtomic and you, being our customer, partner, or user.

1. Data Collected

1.1 Data that you voluntarily provide us with:

1.1.1 You may provide us with your personal information in a number of ways, including, without limitation, when you:

• use the Website;

• fill out and submit any form;

• have previously provided us with personal information prior to this Privacy Policy or last updates coming into effect;

• subscribe to our email list, and/or service updates;

• attend our hosted events;

• request support;

• contact us directly in person or via any medium, including but not limited to by mail, telephone, and commercial electronic messages;

• contact us to purchase our products, services or engage with us in relation to any business matter;

• communicate with us for any matters and interact with or browse the Website generally.

1.1.2 Personal information that we may receive includes, but is not limited to:

1) contact information such as name and email address;

2) billing information;

3) more detailed personal preferences;

4) more detailed contact preferences.

1.1.3 Airtomic may receive this data from you when you manually enter such data, or we may receive such data from third parties. We may combine such data.

1.1.4 By giving us this data, you consent to this data being collected, used, disclosed, transferred as described in this Privacy Policy.

1.2 Data that we collect automatically

1.2.1 We collect data from every visitor and customer of our Website and services, in particular, we automatically collect data about your visit to the Website, your usage of our services, and your browsing activities. This anonymized information may include IP address, browser type, browser language, cookies data, performance specifications of the customer’s hardware and software, date and time of access to the Website, other information about how you interacted with our Website and our services.

1.3 Data from your use of the Website and our products

1.3.1 We may receive data about how and when you use the Website, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This data may include, for example, your IP address, time, date, browser used, and actions you have taken within the Website. This type of data helps us to improve our Website, services, and products for both you and all of our customers.

1.4 Cookies and tracking

1.4.1 Cookies are small data files that are placed on your computer or mobile device when you visit a website. Website owners use cookies to make their websites operate, improve functionality and user experience, as well as to provide reporting information.

1.4.2 We may set our own cookies and use third parties cookies (e.g. for advertising, statistics, and analytics).

1.4.3 We use different types of cookies, including:

1) Essential website cookies: these are important cookies as they are necessary to provide you with services available through our Website, such as access to secure areas.

2) Performance and functionality cookies: these cookies are necessary to enhance the performance and functionality of our Website but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

3) Analytics and customization cookies: these cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, to help us customize our Website for you in order to enhance your experience, or to personalize our content and ads.

4) Advertising cookies: these cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. Please read the following link to know more about online advertising: https://www.networkadvertising.org/understanding-online-advertising/.

5) Social Media cookies: these cookies are placed by social media plugins, and other tools meant to provide or improve the content on a website (for example, services that allow the playing of video files, or that create comments sections).

1.4.4 You may opt out from cookies at any time by customizing your cookie preferences. However, in some cases, we will not be able to provide you with all services.

1.5 Data from third party sources

1.5.1 We may receive some information about you, such as name, email address, demographic information, IP address, and location from third parties.

1.6 Opting-Out

1.6.1 You may decline to have your personal information collected via third party tracking technologies by navigating to the settings feature in your browser and declining all third party cookies or declining third party cookies from specific sites, or, for mobile, limiting ad tracking or resetting the advertised identifier via the privacy settings on your mobile device.

1.6.2 You can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:

• http://www.networkadvertising.org/choices/

• http://www.youronlinechoices.com/

• http://optout.aboutads.info/

• www.allaboutcookies.org

2. Use of the Data

2.1. We only use your personal information for the following purposes:

2.1.1 to perform transactions requested by you;

2.1.2 to display content from external platforms;

2.1.3 to perform user database management;

2.1.4 to personalize your experience when purchasing our products and using our services;

2.1.5 to maintain our relationships with you, promote Airtomic;

2.1.6 to send you informational and promotional content that you may subscribe to or unsubscribe;

2.1.7 to communicate about our Website, products, services and provide customer care in response to your inquiries;

2.1.8 to enforce compliance with the applicable law;

2.1.9 to protect our rights and safety as well as the rights and safety of our customers and third parties;

2.1.10 to contact you via surveys to conduct research about your opinion of our products;

2.1.11 to provide information to representatives and advisors;

2.1.12 to prosecute and defend a court, arbitration, or similar legal proceeding;

2.1.13 to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements;

2.1.14 to provide suggestions about products that you may be interested in and which you may opt out;

2.1.15 to transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.

3. Minors

3.1 Minors and children under age of 18 (or other legal age of your country of residence) should not use our Website. We do not knowingly transact or form any binding legal relationship with minors. If you access our Website, you represent that you have the legal capacity to enter into a binding agreement. If you are under 18, we require that you inform a parent or guardian about our Privacy Policy as well as obtain their consent to use our Website.

4. Sharing of Data

4.1 We do not share personal information, unless:

4.1.1 Doing so is appropriate to carry out your own request;

4.1.2 We believe it is needed to enforce our Privacy Policy, or if it is legally required;

4.1.3 We believe it is needed to detect, prevent or address fraud, security or technical issues;

4.1.4 Otherwise protect our property, legal rights, or that of others.

4.2 We may share your information with our operating offices and in any other places where the parties involved in the processing are located. Airtomic has in place an intra-group transfer agreement to safeguard these personal data transfers. If, in the future, we re-organise or transfer all or part of our business, we may need to transfer your information to new entities or third parties through which our business will be carried out. Depending on customer’s location, the data may be transferred to a country other than where the customer is located. If any such transfer takes place, you can contact Airtomic for enquiring more details.

4.3 We do not share your personal information with third parties, except for our service providers, such as providers of cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services.

4.4 This is the list of our third party service providers with contact and other details. Please contact us to receive an updated list of our third party service providers.

HubSpot	https://www.hubspot.com/	HubSpot, Inc. 25 First Street, 2nd Floor Cambridge, MA 02141 United States	For data storage
DigitalOcean	https://www.digitalocean.com/	DigitalOcean, LLC 101 Avenue of the Americas, 10th Floor, New York, NY 10013 USA	For data storage
Stripe	https://stripe.com/	Stripe, Inc. The One Building, 1, Lower Grand Canal Street, Dublin 2, Ireland	For payment processing
Google	https://www.google.com/	Google Inc. 1600 Amphitheatre Parkway in Mountain View, California	For advertising
Facebook	https://www.facebook.com/	Facebook Inc. 1 Hacker Way Menlo Park, CA 94025	For advertising
LinkedIn	https://www.linkedin.com/	LinkedIn Corporation 1000 W. Maude Avenue Sunnyvale, CA 94085 USA	For advertising
TikTok	https://www.tiktok.com/en/	TikTok Inc. 5800 Bristol Parkway, Suite 100, Culver City, CA 90230	For advertising

4.5 We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share personal information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use personal information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of personal information with our Agents.

5. Safeguarding your Personal Information

5.1 The protection of your personal information is vital to us. We take commercially reasonable measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information. These security measures include, but are not limited to, 2-factor authentication, SSL certificate for HTTPS.

5.2 Our employees, contractors, and any business partners can access personal information on a need-to-know basis, and under strict duties of maintaining confidentiality. We use encryption for sensitive information and we test our system on a regular basis to ensure we comply with industry practices and standards. While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet, or method of electronic storage, is completely secure, and we cannot guarantee absolute security of any data.

5.3 You agree to protect the security of your login information and password and not to transfer such information to any third party. We will not be liable to you for the use of your account by any third party.

5.4 If you become aware of any unauthorized use of your account, you shall immediately notify us in writing.

6. Access to your Personal Information

6.1 You may access your personal information held by us to correct, update and remove inaccurate or incorrect data. You have the following rights:

6.1.1 delete some or all personal information that we held about you;

6.1.2 change or correct your personal information that we held about you;

6.1.3 object to, or limit or restrict, use of your personal information;

6.1.4 right to access and/or take your personal information: you can ask us for a copy of your personal information in machine readable form;

6.1.5 access information we hold about you.

7. Changes to the Privacy Policy

7.1 We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make major changes in the way we collect or use information, we will notify you by posting an announcement on the Website or sending you an email.

8. Merge of Company

8.1 If Airtomic merges with, or is acquired by, another company or organization, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser or any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

9. Data Retention

9.1 We retain your personal information for as long as we need it to fulfil the purposes for which we originally collect it or as needed to provide with our services, except if required otherwise by law. Personal information collected for the purpose of the legitimate interests shall be retained as long as needed to fulfill such purposes. In certain cases, it is allowed to retain personal information for a longer period if the user has explicitly consented to such processing until the consent is withdrawn. In some cases, we may determine the period of data retention based on the period we need to access the data for the provision of services, receiving payment, or for any other auditing or legal purposes. Once the retention period expires, the personal information will be deleted without any possibility to rectify or transfer the deleted personal information. 10. GDPR and Client Data provided by Users

10.1 As a service provider, we recognize our role under the European Union's General Data Protection Regulation (GDPR) as a data processor, rather than a data controller, for any client data containing personal information subject to GDPR requirements. This distinction means that our clients and users, as data controllers, retain control over the collection, usage, and processing of personal data. We neither collect nor determine the usage of any personal data within client data, nor do we have control over its collection methods or purposes. Our responsibility as a data processor involves processing personal data solely in accordance with the instructions provided by our clients and users. We are dedicated to upholding the confidentiality, integrity, and security of the personal data we process on their behalf.

11. Limited Use Disclosure

11.1 Airtomic's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

12. Contact Us

12.1 If you have any questions about this Privacy Policy, or want to submit a written complaint to us about how we handle your personal information, please contact us at: [e-mail]