Legal

Privacy Statement

Effective as of October 9, 2023 — Previous Version

Airship Group, Inc. and its affiliates, including, Apptimize, LLC., Urban Airship UK Ltd., Urban Airship Germany GmbH, Airship France SAS, Airship Business France SAS, and Urban Airship India Private Ltd. (collectively, “Airship,” “we” or “us”) offers mobile and customer engagement platforms through the Airship Service, the Apptimize Service and the Gummicube ASO Services, (collectively referred to as the “Airship Platform”). Airship is committed to protecting the privacy of Personal Information you provide to us, and applies the Privacy by Design and Data Protection by Default principles across our Airship Platform product enhancement, development, and operations.

When referring to “Personal Information” in this Statement, we mean information that personally identifies (e.g. your name, email address, device information, IP Address) an individual or other data that relates to or could be reasonably linked to such information. Accordingly, Airship informs you via this privacy and information practices statement about our information practices, the kinds of information we collect, how we intend to use and share that information, and the rights you have with respect to the processing of such information by us, (“Privacy Statement”).

1. What this Privacy Statement covers

1.1 Scope of this Privacy Statement

This Privacy Statement applies to Personal Information that we collect when you: (i) visit websites we operate and that link to this Privacy Statement, including www.airship.com, https://www.airship.com/de/home/, www.airship.com/fr/, https://go.airship.com/accounts/register/plan/starter/,
https://go.airship.com/accounts/login/, www.gummicube.com, and www.apptimize.com (the “Sites”); (ii) use our training and testing versions of the Airship Platform for mobile or software applications, mobile wallet passes, or any other software applications made available by us for use on or through computers and mobile devices that link to this Privacy Statement; (iii) download or otherwise engage with content and publications such as viewing videos, reading content our Site, interact with our chat bot, or visit our branded social media pages; (iv) visit our offices; (v) receive communications from us, including emails, phone calls or texts; (vi) register for, attend and/or otherwise take part in our events, webinars or contests; (vii) participate in recorded meetings; (viii) submit a job application to us; (ix) submit information to us in connection with a potential business relationship with us; (x) register to use the Airship Platform as an authorized user (for example, as an employee of one of our customers who provided you with login access to the Airship Platform) (which is referred to in this Statement as “Account Information”); (xi) contact us for support or information; or (xii) work at partners or suppliers of Airship and interact with Airship in the course of doing business or contemplating a potential business relationship with us. This Privacy Statement also applies to our recruitment practices. However, for California job candidates and Airship employees, then Airship’s California Employee Privacy Notice applies to you and describes how we collect and use Personal Information about you during and after candidacy, job application, and your employment with us. In this Privacy Statement, the terms Sites and Airship Platform collectively are referred to as the “Services”. “You” refers to any individual who visits or uses the Services.

1.2 Controller for processing within the scope of this Privacy Statement

Airship is the data controller for the data processing within the scope of this Privacy Statement. This means that as a data controller we determine the purposes and means of the processing of Personal Information for our marketing and business purposes, as further described below in this Privacy Statement.

1.3 Out of Scope of this Privacy Statement

Except as provided with respect to Account Information as described in Section 1.1. (Scope of this Privacy Statement) above, this Privacy Statement does not apply to our security and privacy practices concerning the Personal Information we receive and process on behalf of our customers through the Airship Platform). In this capacity, Airship processes Personal Information of people who interact with customer applications or websites that are offered by Airship’s customers and that have incorporated the Airship Platform. As such, Airship acts in the role of a data processor or service provider on behalf of our customers, and our security and privacy commitments are detailed in and governed by our agreements with our customers, including the Terms of Subscription Service, the Airship Data Processing Addendum entered into with such customers,or such other applicable agreement entered into between our customer and Airship and that is related to our customer’s access to and use of the Airship Platform. This Privacy Statement does not cover any Personal Information that our customers choose to collect and share with Airship, where Airship is not the Data Controller, but is instead the Data Processor. For privacy information related to our customers’ uses of the Airship Platform in connection with their mobile applications, websites, emails, texts or other digital properties, please reach out to the respective customer directly.

In addition, the Services may contain links to other third party websites. The privacy statements and policies of such third party websites govern their respective privacy and security practices as provided in Section 12 of this Privacy Statement.

California residents and customers with business in the State of California may read our supplemental California Privacy Rights Notice here. Our California Privacy Notice applies to Personal Information we collect and process about California residents in operating our business in circumstances where Airship controls how and why the Personal Information is processed.

2. What Personal Information does Airship collect?

The Personal Information we collect will be determined by the type of interaction you have with Airship, as described in further detail in the following categories:

2.1 Personal Information we collect directly.

Site usage. When you use the Services or fill out forms on our Site, we may provide you with opportunities to sign up to receive specific information or Services, download content, register for an online or in-person event or webinar, or attend an online or in-person event or webinar for marketing purposes, and we ask for your contact information. Personal Information we collect is, is: name, title, company name, industry, company address, phone number,email address, country, downloads and engagement with Airship content and other publications, marketing subscription status, communications that we exchange with you including when you contact us with questions or feedback, through online web portals, emails, our chat features, social media, or online assessments or survey participation. Our sites use cookies and other technologies, and as a result we also collect information as described in Section 5 (What device and usage data does Airship process?) below as well as internet connection data transmitted by your browser, meaning your IP address or proxy server, your browser (type/version), your operating system, date and time of your inquiry, websites from which your system accesses our website (Referrer-URL) and hostname of the accessing computer, location, internet service provider and / or mobile carrier, pages and files viewed, exchanges through our chat features, searches, and date/ time stamps associated with your usage. When activating or installing updates to our mobile applications or mobile wallet passes, we collect information about your device (manufacturer, model, IP address), or information about the application such as the version, date of activation, successful or unsuccessful updates.

Registering for and attending a meeting or an event. If you register to attend a meeting (whether in person or virtually) in connection with entering into a contract with Airship or one of its third party partners or in the course of an already existing contractual relationship, we ask for your contact information (name and email address), job title, employer, and retain copies of meeting audio and video recording in accordance with our Corporate Data Retention Policy and based on your consent to participate in a recorded meeting. If you attend an event, we, with your consent, scan your attendee badge which will provide us with your information, such as name, title, company name, address, country, phone number, email address, industry, and record of event attendance.

Your communications with us. We collect your name, email address, phone number, mailing address, job title, marketing subscription status, and information regarding your engagement with Airship content and other publications, communications that we exchange with you through online web portals, emails, our chat features, or social media when you request information about our Services, register for our newsletter, download or otherwise engage with our content and publications, request customer or technical support, or otherwise communicate with us.

Account Information for Airship Platform. If you register to use the Airship Platform as an authorized user or sign up for a free account, we collect your name, email address, IP address, company name, job title, and website name or information.

Surveys. If we may contact you to participate in surveys and you decide to participate, you will be asked to provide your name, email address, employer, job title and other contact information..

Social media content. We maintain publicly accessible Airship social media sites (“Company Social Media Webpages”) on various social media platforms, i.e. Facebook, LinkedIn, Twitter, Soundcloud, Slideshare. We offer forums, blogs, and content on such Company Social Media Webpages. Any content you provide on these channels will be considered “public” and provided voluntarily.

The individual processing of Personal Information by the respective social media platform providers differ. It is likely that, in addition to the storage of Personal Information specifically provided by you on the Company Social Media Webpages, the social media platform provider will also process further information. Additional information as to data transfers for social media platform providers is available below in Section 6 (International data transfers) below. For details about the collection and storage of your Personal Information as well as the type, scope and purpose of their use by a social media platform providing the Company Social Media Webpage, please refer to the respective platform’s privacy policy:

• The privacy policy for Facebook, which is operated by Meta Platforms, Inc. can be found at https://www.facebook.com/privacy/policy.
• The privacy policy for LinkedIn, which is operated by LinkedIn Inc., can be found at https://www.linkedin.com/legal/privacy-policy.
• The privacy policy for Twitter, which is operated by Twitter, Inc. can be found at https://twitter.com/en/privacy.
• The privacy policy for SoundCloud, which is operated by SoundCloud Global Limited & Co. KG, can be found at https://soundcloud.com/pages/privacy.
• The privacy policy for Slideshare, which is operated by Scribd, Inc., can be found at https://support.scribd.com/hc/en-us/articles/210129366-Privacy-Policy.

In the following, we set out our own processing activities regarding your visit to the Company Social Media Webpages. Based on the type of Personal Information processed, we explain for which purposes and on which legal basis we process your Personal Information.

• Visiting our Company Social Media Webpages
  • When you visit our Company Social Media Webpages, your Personal Information is also collected, used and stored by the providers of the respective social media platform. This may happen even if you do not have a profile in the respective social media platform. If you are logged in with your personal user account of the respective social media platform while visiting this Company Social Media Webpage, the respective social media platform provider can link the visit to your account. If you do not wish such a linking to occur, you must log out of your account before visiting our Company Social Media Webpage and delete the cookies if necessary. You can find details in the privacy policies of the respective social media platform providers linked above.
  • As the owner of the Company Social Media Webpage, we can view the information stored in your respective public profile when you visit our Company Social Media Webpage. However, we can only do this if you have such a profile on the relevant social media platform and are logged in to it when you access our respective Company Social Media Webpage. Accordingly, you can also visit our Company Social Media Webpage without us having access to the aforementioned information. If we view the information stored in your public profile, we do so in order to be able to offer you and the rest of our target group the most interesting content possible related to the Services.
  • In addition, the social media platforms providers share with us anonymous usage statistics, which we use to improve the user experience for visitors to our Company Social Media Webpage. However, we do not have access to the usage data (Personal Information) that the social media platform providers collect to compile these statistics. The social media platform providers are therefore always to be considered as the data controller with regard to the processing of this data.
  • Our own data processing in connection with our social media profiles serves and is based on our (and your) legitimate interest (legal basis) in improving the user experience when visiting the respective Company Social Media Webpage.
• Contact via the messenger of a social media feature
  • If you communicate with us via a messenger functionality of a social media platform or contact us by linking in your own posts or by reacting (e.g. likes or comments) to one of our posts, we process the following Personal Information in connection with this:
    • your respective profile name
    • your first and last name, insofar as this is publicly visible
    • if applicable, further information stored as public in your profile
    • your message or the statement of your post or your reaction
    • the date and time of your interaction
    • information on whether you are already a customer or possibly interested in our Services.
  • Furthermore, when contacting us via messenger functionality of a social media platform, you can voluntarily provide additional information that you believe is necessary to process your request.
  • If your contact contains a request, we process the Personal Information listed here above to process your request and the associated technical administration and also store it in the event that follow-up questions arise. Otherwise, we only process the aforementioned Personal Information to understand whether visitors to our Company Social Media Webpage like our content.
  • The processing of the aforementioned Personal Information takes place if you express interest in our products on the basis of contractual necessity, i.e. in the initiation of a contractual relationship. Otherwise, it takes place on the basis of mutual interest in good support for visitors to our Company Social Media Webpage and is therefore based on our legitimate interest (legal basis).
  • There is no obligation to provide the aforementioned Personal Information, but it is not possible for us to process requests or for you to interact with us without it.

Registration for sweepstakes or contests. We may run sweepstakes and contests. Contact information you provide is used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

Visiting our offices. If you visit our offices, you are required to register as a visitor and provide your name, email address, phone number, company name and time and date of arrival.

Employment applications. We collect your Personal Information from you such as name, email address, phone number, mailing address, job title, CV/resume and work history, education, interests, professional references, and information regarding your engagement with Airship content and other publications, communications that we exchange with you through online web portals, emails, our chat features, or social media when you request information about our job posting, apply for a job or engage with a job posting, or otherwise communicate with us. For more information specific as to Personal Information we collect and process about California job candidates and Airship employees, please refer to our Job Applicant and Employee Privacy Notice for California Residents which applies to all California residents who are either job applicants, candidates, or current and former employees of Airship.

2.2 Personal Information collected from others.

Information from Other Sources. We may also receive other information including your Personal Information from service providers, from joint marketing partners, or from publicly available information such as public databases and social media platforms. In particular, we collect the following Personal Information from such other sources: contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), information regarding your business use case for our Services, IP addresses, social media profiles including LinkedIn URLs, and custom profiles for purposes of targeted advertising, delivering relevant email content regarding our Services, event promotion, determining eligibility and verifying contact information. When acquiring information from third parties, we will obtain contractual or other legally compliant commitments from the third parties that the information was acquired lawfully and with the appropriate level of consent.

Billing Information. Through our third-party billing and payment processors, and to the extent we charge you a fee for the Services, we may collect billing, payment, and contract related information from you if you are a business representative of one of our customers. Personal Information collected for billing, payment and contract related purposes is name, title, company name, company address, phone number or email address, country, and payment related information such as accounts.

Under certain circumstances, the credit or debit card or other payment method information you provide in this context may be transmitted by the payment processor. Our payment processor provider is Stripe, Inc. The purpose of this transmission is to process the payment made on an invoice due to us for our Services. The payment processor’s terms and conditions and data protection terms entered into by Airship with the payment processor as our data processor or service provider apply to such payment transactions..

3. How does Airship use Personal Information and what are the legal bases for these uses?

We use Personal Information that we collect about you or that you provide to us for a range of different business purposes. Depending on how you interact with us, we and our third-party service providers use Personal Information in a variety of ways, including:

3.1 Providing information and Services you requested. We use the Personal Information about you to fulfill requests for programs, Services, or information that you may request such as information about potential or future Services, namely to: (a) generally manage your information and accounts; (b) respond to questions, comments and requests; (c) provide access to certain areas and features of the Services; (d) link or combine information we get from others to help understand your needs and provide you with better Services; and (e) allow you to register for events, participate in a contest or promotion, post in a forum or participate in webinars, and provide related information and communications.

Legal bases for our use of your Personal Information under applicable data protection laws are:

• Performance of a contract, e.g. when we provide you with Services, or communicate with you about them. This includes when we use your Personal Information to process Orders or payments orders, or deliver the Services you requested;
• Our legitimate business interests and the interests of our customers to process your request, and further (to the extent our interests also prevail in this regard) to improve our Services, to detect and prevent fraud and abuse in order to protect the security of our customers, ourselves, or others, and partly to provide you with advertising based on the interests you indicate to us; or
• Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you via a link or by combining information we get from others. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.

3.2 To fulfill a contract or take steps linked to a contract. This is relevant when you register for or subscribe to the Airship Platform. We use the Personal Information about you to take steps to enter into a contract or to fulfill the obligations of a contract to which you are a party, namely: (a) to fulfill your and prospective customers’ requests related to the Airship Platform or other products that you have requested; (b) to provide you with the Airship Platform for which you have registered; (c) perform internal quality control; (d) to provide, maintain, and improve our Services; (e) verify identity; (f) send communications regarding the Services, your account, or any changes to any Airship policy or terms of use; (g) process payments; (h) provide technical and customer support; and (i) enforce our Terms of Use, Acceptable Use Policy or other agreement entered into with you.

Legal bases for our use of your Personal Information under applicable data protection laws are:

• Performance of a contract, e.g. when we provide you with Services, or communicate with you about them. This includes when we use your Personal Information to process orders, deliver Services, and process payments; or
• Our legitimate business interests and the interests of our customers to fulfill our contractual obligations, and further (to the extent our interests prevail in this regard) to improve our Services.

3.3 Marketing products and services. We use Personal Information about you, in most cases with your prior consent, to provide you with materials about offers, products and services offered by us, including new content or information about future services. We provide you with these materials by phone, postal mail, text or email, as permitted by applicable law. Such uses include: (a) to tailor content, advertisements, and offers; (b) to notify you about offers, products, and services that may be of interest to you; (c) measure interest in the Services; (d) process and deliver contest entries and rewards; (e) monitor and analyze trends, usage and activities in connection with our Services; or (f) for other purposes disclosed at the time that you provide Personal Information;. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below in Section 11 (Your Privacy Rights).

Legal bases for our use of your Personal Information under applicable data protection laws are:

• Our legitimate business interests (to the extent our interests prevail) to improve our Services, to detect and prevent fraud and abuse in order to protect the security of our customers, ourselves, or others, and partly to provide you with interest-based advertising; or
• Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you, e.g. link or combine information we get from others. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop the processing of your data for that purpose.

3.4 Research and development. We use your Personal Information to create de-identified information that we use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing Services,develop new products, processes and services, or develop content related to industry trends and market reports and analyses. De-identified or aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services, and usage trends for mobile applications and websites. After this process of de-identification, de-identified or aggregated information is not Personal Information, does not identify you or any individual, and we use such information in a number of ways, including research, internal analysis, analytics, benchmark or industry reports, and any other legally permissible purposes. We share this information internally within Airship and with our customers or partners for our or their purposes in a de-identified or aggregated form that is designed to prevent anyone from identifying you.

Legal bases for our use of your Personal Information under applicable data protection laws are:

• Our legitimate business interests (to the extent our interests prevail) to improve our Services; or
• Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you via a link, contract, or by combined information we get from others. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.

3.5 Recruitment and employment. Based on your interest in a role with Airship, we use Personal Information within the recruitment and job application process for the assessment of your application and, if an employment relationship is established, also for the execution of the employment relationship.

Legal bases for our use of your Personal Information under applicable data protection laws are:

• The performance of a contact (e.g. in entering in an employment agreement with you).
• Our legitimate business interests (to the extent our interests prevail) in recruiting, employment, and responding to any potential legal claims.
• Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you via a job application link or post, contract, or by combined information we get from others. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.
• Compliance with a legal obligation when we use your Personal Information to comply with laws, including local labor and employment laws.

For California residents, more information specific as to Personal Information we collect and process about California job candidates and Airship employees is available in our Job Applicant and Employee Privacy Notice for California Residents which applies to all California residents who are either job applicants, candidates, or current and former employees of Airship.

3.6 Public content. If you post any content to our website forums or social media accounts, we publish this content and make it generally available to any user or visitor of our website or Company Social Media Webpages.
Legal bases for our use of your Personal Information under applicable data protection laws are:

• Your consent to publish your content when you decide to post it on our website forums or Company Social Media Webpages. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose; or
• Our legitimate business interests and the interests of our customers to provide you with the requested information, when we detect and prevent fraud and abuse in order to protect the security of our customers, ourselves, or others, and partly when we provide you with interest-based advertising, and further (to the extent our interests also prevail in this regard) to improve our Services.

3.7 Complying with legal obligations. As permitted by local laws, we use your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligation under applicable laws to protect our rights or as necessary to protect against misuse or abuse of our Sites or Services, prevent potentially prohibited or illegal activities and fraud, promote safety and security of the Services and in protecting our rights and the rights of others, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
Legal bases for our use of your Personal Information under applicable data protection laws are:

• Compliance with a legal obligation when we use your Personal Information to comply with laws. For instance, we collect customer place of establishment and bank account information for identity verification purposes.

4. With whom does Airship share Personal Information?

We disclose your information to third parties only as necessary to carry out your request, for a variety of our professional or legitimate business purposes, including to provide our Services, to protect us or others, in the event of a major business transaction such as a merger, sale, or asset transfer, as described below, or as otherwise required or permitted by law. Where we do transfer your Personal Information to third parties or service providers, appropriate safeguards will be in place in order to ensure correct and secure data processing in compliance with applicable data protection law.

4.1 Disclosures to provide our Services.

Service Providers. Airship may share Personal Information with our service providers that we have retained to perform services on our behalf for business purposes and to support our internal operations including (i) provision of IT, hosting, backup, storage, and related services; (ii) provision of information and Services you have requested; (iii) payment processing and to collect amounts owed to Airship; (iv) customer service activities; (v) recruitment activities and job postings; and (vi) professional advisors including lawyers, bankers, auditors and insurers. These third-party service providers may have access to or process your Personal Information for the purpose of providing these services for us. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. Airship has executed appropriate contracts with our service providers that prohibit service providers from using or sharing your Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. We retain control over the Personal Information in question and remain the data controller.

Business Partners. From time to time, Airship may partner with other companies to jointly offer products, services or programs (such as webinars, events or downloadable content). If you purchase, specifically express interest in, or register for a jointly-offered product, service or program from or through Airship, we may share your Personal Information with our business partners. We also share your Personal Data with technology and solution partners in connection with customer or technical support, marketing, business development and account management. In such instances, our partner will process the relevant Personal Data as a separate data controller and the partner’s use and control over your Personal Data will be governed by their privacy policy. If you do not wish for your Personal Information to be shared in this manner, you may opt not to purchase or to specifically express interest in a jointly-offered product service, or program, or you may otherwise opt-out through any mechanism offered at the time the Personal Information is collected.

Affiliates. We may share Personal Information with our affiliated companies including from other countries in which the Airship Group has operations in connection with customer or technical support, marketing, business development, recruiting, operations, account management, events or webinars, for general business purposes, in order to protect, exercise, establish or defend legal rights, where we are legally required to do so and to receive professional advice. Unless there is an adequacy decision by the European Commission for the respective third country outside the European Economic Area, such sharing is carried out on the basis that the transfer is necessary for the performance of a contract.

Advertising Partners. Through our Sites, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device ( your IP address, mobile identifiers, page(s) visited, location, time of day). Subject to the legal bases described in Section 3 (How does Airship use Personal Information and what are the legal bases for these uses?) above, we may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements regarding our Services to you when you visit third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Sites to share information that may be useful, relevant, valuable or otherwise of interest to you based on the interest you indicated via our Sites. Please refer to Section 5 (What device and usage data does Airship process?) below for more information on how these technologies and tracking tools work. If you prefer not to share your Personal Information with third-party advertising partners, you may follow the instructions in Section 11 (Your privacy rights. ) below. For California Residents, additional information is available in our California Privacy Rights Notice.

4.2 Disclosures to protect us or others.

Protection of Airship and others. We may disclose Personal Information about you when we have a good faith belief that we are required to provide information: (a) if we are required to do so by law, court order or legal process; (b) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements (but only in accordance with Airship’s Policy on Response to Public Authority Requests for Personal Data); (c) under the discovery process in litigation; (d) to enforce Airship policies or contracts; (e) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (f) if we, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs and other systems may be reviewed for security purposes (e.g., to detect unauthorized activity on the Services). In such cases, records containing Personal Information may be shared with service providers, third parties and law enforcement bodies in order that they may prevent fraud or a security issue in accordance with the Airship Acceptable Use Policy and/or identify users in connection with their investigation of the unauthorized activities.

4.3 Disclosure in the event of merger, sale, or other asset transfers.

Business Transfers. We reserve the right to disclose or transfer any Personal Information in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding).

5. What device and usage data does Airship process?

Like many companies, Airship uses services that employ cookies and other technologies to collect Personal Information (including the identifiers and internet activity information described here) about your use of our Sites or Services, which helps us to deliver to you improved Services performance, relevant information, or targeted ads. As part of this process, we use common information-gathering tools for collecting usage data, cookies, web beacons and similar technologies to automatically collect information that may contain Personal Information from your computer or mobile device as you navigate our Sites or use our Services.

5.1 Cookies, web beacons and other tracking technologies in our Services.
As you navigate the Sites and use the Services, certain passive information is also collected through the use of cookies, web beacons and other tracking technologies to obtain certain information about your computer, device, browsing actions, and patterns. This includes IP addresses, cookie IDs, navigational data, content clicked, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, your browser settings, your device type and similar information, the date and time you access our Services and other device identifiers. This type of information is used for the purposes of gathering data to provide improved administration of our Services and to improve the quality of your experience when interacting with our Services (see Your Privacy Rights section below for more information). If you consent to the use of cookies and web beacons when you navigate and use the Services, we will collect information through those tools.

Where your Personal Information is collected through these technologies by Airship as Controller, it will be processed in accordance with the provisions of this Privacy Statement.

Where third party technologies allow our partners to collect and process your Personal Information, we encourage you to review their privacy policy to see the terms and conditions under which your Personal Information will be processed by them. A link to these privacy policies is included for each of our partners in the cookie providers table provided at the end of this Privacy Statement. For California residents, additional information is included in our California Privacy Rights Notice.

Cookies. A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, to develop a record of the user’s online activity. When you visit our Sites, we or an authorized third party may place a cookie on your browser and/or device which collects information, including Personal Information, about your online activities over time and across different sites. Cookies allow us to track usage, determine your browsing preferences and improve and customize your browsing experience. For more information about cookies and web beacons, please visit http://www.allaboutcookies.org/ (French version: https://www.allaboutcookies.org/fr/. German version: https://www.allaboutcookies.org/ge/).

We use both session-based and persistent cookies on our Sites. Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your computer or device. Persistent cookies remain on your computer or device after you close or turn off. You can control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our Services.

Types of cookies on our Sites:

• Essential Cookies. These cookies are necessary for the Sites to function and cannot be switched off. Some examples include: session cookies needed to transmit the Sites, authentication cookies, and security cookies. These cookies also support certain features on the Sites, such as the live chat feature. Further description of the purposes of the essential cookies used in our Sites is available in the Cookies Settings at the bottom of this web page. You can set your browser to block or alert you about these cookies, but some parts of the Sites will then not work.
  
  Through the use of some of these cookies, Airship collects and processes certain Personal Information about you in order to carry out the above purposes. This includes your IP address, session identifiers, browser and/or terminal information, browsing data and preferences (including your choice of cookies). The legal basis for the processing of this Personal Information is the legitimate interest of Airship in ensuring that the Sites function correctly to the preferences indicated by each user. Your Personal Information will be kept only for the time necessary to fulfill the above-mentioned purposes.
  
  The list of our partners authorized to deposit essential cookies is available in the cookie providers table provided at the end of this Privacy Statement and in the Cookies Setting at the bottom of this page.
• Functional and Analytics Cookies. Functional cookies enhance functions, performance and services on the Services. They enable us to count visits and traffic sources so we can measure and improve the performance of our Services. Functional cookies also enable us to improve how our Services function and to help us provide you with more relevant communications, including marketing communications. They help us to know which pages are the most and least popular and see how visitors move around and use the Services. We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications and to enable certain features on the Services. We also use Google Analytics and Google Analytics Demographics and Interest Reporting and other similar providers to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. Further description of the purposes of the functional and analytics cookies used in our Services is available in the Cookies Settings at the bottom of this web page.
  
  Through the use of some of these cookies, Airship collects and processes certain Personal Information about you in order to carry out the above purposes. This includes your IP address, browser and/or terminal information, navigational data and content clicked. The legal basis for processing this Personal Information is your prior consent when we ask for your consent to process your Personal Information for the specific purpose of each Functional and Analytics cookie. Your Personal Information will be kept only for the time necessary to fulfill the above-mentioned purposes.
  
  The list of our partners authorized to deposit functional and analytics cookies is available in the cookie providers table provided at the end of this Privacy Statement and in the Cookies Setting at the bottom of this page.
• Marketing Cookies. These cookies track activity across websites in order to understand a visitor’s interest, and to direct specific marketing to them. Targeting and advertising cookies may be set through our Sites by our service providers. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. Further description of the purposes of the targeting cookies used in our Sites is available in the Cookies Settings.
  
  Through the use of some of these cookies, Airship collects and processes certain Personal Information about you in order to carry out the above purposes. This includes your IP address, unique identifier, location information, information about your browser and/or terminal, your interests as identified through your browsing, the advertising content you have viewed and your interactions with that content. The legal basis for processing this Personal Information is your prior consent when we ask for your consent to process your Personal Information for the specific purpose of each Marketing cookie. Your Personal Information will be kept only for the time necessary to fulfill the above-mentioned purposes.
  
  The list of our service providers authorized to deposit targeting cookies is available in the cookie providers table provided at the end of this Privacy Statement and in the Cookies Setting at the bottom of this page.

For more information about cookies, and how to disable them, please see “Your Privacy Choices” below.

Web beacons. We also use web beacons (sometimes called “pixel tags” or “tracking pixels”). These are tiny graphics files that contain a unique identifier that is embedded in our Sites and in our emails or other communications that are sent through our Services. This enables us, for example, to monitor the traffic patterns of users from one page within our Site to another, to track access to the communications sent through our Services, to understand whether you have come to our Sites from an online advertisement displayed on a third-party website or whether you have viewed advertisements on our Sites or through the Services, or to improve our Sites’ performance.

Legal basis for our use of your Personal Information under applicable data protection laws in relation to Web beacons is your consent when we ask for your consent to process your Personal Information for the specific purpose of each of such Web beacons.

To change your cookie settings (including Web beacon settings) and preferences for the Sites you are visiting, use the Cookie Settings link at the bottom of the webpage.

For more information about Web beacons, and how to disable them, please see “Your Privacy Choices” below. SDKs. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties, including analytics and advertising partners, to collect your Personal Information for various purposes including to provide analytics services and content that is more relevant to you.

5.2 Social media features.

Airship collects Personal Information as described above in Section 2.1 in the Social Media Content to enable individuals to use online social media resources offered either by Airship or a third party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.

In addition, social media links such as Facebook, LinkedIn, Twitter, Instagram,YouTube, SoundCloud and Slideshare (that might include widgets such as the “share this” button or other interactive mini-programs) are on our Site. These features collect your IP address, which page you are visiting on our site, and set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features apart from your visit to our Site are governed by the privacy policy of the company providing it.

5.3 Chat Technologies

We use chat technologies provided by third-party service providers that employ cookies and software code to operate the chat features you can use to communicate with us through our Sites. We and such third-party vendors may monitor, record and use information from your interactions with our Sites. This information includes details you have shared through online chats, data on sections of the Sites you have visited, your IP address and your general geographic information (e.g., city, state). This Personal Information may be processed for the purposes outlined in Sections 3.1 (Providing information and Services you requested.) and 3.4 (Research and development.) of this Privacy Statement.

6. International data transfers.

We store Personal Information sent or collected via or by us in the United States or the European Economic Area, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. To facilitate our global operations, we may transfer, store and access such information from the locations where Airship has operations – specifically the United States, France, Germany, the United Kingdom, Singapore, or India. Your Personal Information may be processed in any of these countries, and they may have data protection laws that are different or that may not provide the same level of data protection as your country. In the event of data transfers outside of the European Economic Area among Airship affiliates, and with our service providers and data processors , we rely on international transfer mechanisms such as the European Commission approved Standard Contractual Clauses, adequacy decisions about certain countries, or we will ask you for your prior consent for the transfer of your Personal Information, as applicable. In addition, we ensure the recipient of your Personal Information has in place adequate levels of protection for your Personal Information.

When you visit one of our Company Social Media Webpages on a social media platform as described in Section 2.1 (2.1 Personal Information we collect directly. Social Media Content.) above, Personal Information may be transferred to providers in countries outside the European Economic Area, which, from the perspective of the European Union (“EU”), do not ensure an “adequate level of protection” for the processing of Personal Information in line with EU standards. Please bear this in mind before clicking on a link or visiting directly a Company Social Media Webpage and thereby triggering a transfer of your data.

For more information about the protections in place and a sample copy of the model contractual clauses, please contact us at privacy@airship.com.

7. EU-US Data Privacy Framework (“EU-U.S. DPF”), UK Extension to the EU-U.S. DPF, and Swiss-US Data Privacy Framework (“Swiss-U.S. DPF”)*

Airship complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Airship has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Information received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Airship has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the relevant Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. 

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Airship commits to resolve DPF Principles-related complaints about our collection and use of your Personal Information.  EU, UK, or Swiss individuals with inquiries or complaints regarding our handling of Personal Information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Airship at: privacy@airship.com. 

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Airship commits to refer unresolved complaints concerning our handling of Personal Information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint.  The services of JAMS are provided at no cost to you. Under certain conditions, an individual may invoke binding arbitration for complaints regarding DPF compliance not resolved by JAMS as described here above.  More information is available at: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2 .

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Airship commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

Airship remains liable for the processing of Personal Information received under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and subsequently transferred to a third party acting on our behalf if this entity processes such Personal Information in a manner inconsistent with the DPF Principles.

The Federal Trade Commission has jurisdiction over Airship’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, we may be required to disclose Personal Information  in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and we will do so in accordance with the Airship’s Policy on Response to Public Authority Requests for Personal Data.

*The EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF  do not apply to Airship Group, Inc.’s affiliate, Apptimize, LLC, and the Apptimize Service.

8. What security measures does Airship have in place?

The security of Personal Information provided to us is of utmost importance to us. We have implemented industry-standard technical, administrative, and physical safeguards to help protect information on our servers against unauthorized access, alteration, disclosure or destruction. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify us at privacy@airship.com.

9. How long does Airship retain Personal Information?

We retain the Personal Information we receive as described in this Privacy Statement for a period consistent with the original purpose of collection (see Section 3 (How does Airship use Personal Information and what are the legal bases for these uses?) above) or as long as necessary to fulfill our legal obligations. We determine the appropriate retention period for Personal Information on the basis of the amount, nature, and sensitivity of the Personal Information being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation). The Airship corporate Data Retention Policy sets forth the period for Personal Information described in Section 2 (What Personal Information does Airship collect?) of this Privacy Statement. The corporate Data Retention Policy does not apply to customer data collected via the Services, which is subject to data agreements entered into between Airship and the customer. For information specific to data retention periods related to the Airship corporate Data Retention Policy, which is Airship confidential information, please email privacy@airship.com. The Data Retention Schedule available here specifies the default data retention settings for the Airship Platform.

After expiry of the applicable retention periods set forth in the Airship corporate Data Retention Policy, your Personal Information will be deleted. If there is any Personal Information that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such Personal Information.

For more information on data retention periods, please contact us by emailing privacy@airship.com.

10. Are Airship’s Sites intended for children?

Due to the nature of our business, Services are not marketed to or intended for minors under the age of 18. Airship does not knowingly solicit or collect Personal Information from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the Contact Us information below, and we will take steps to delete such Personal Information from our Services.

11. Your privacy rights.

You have certain choices available to you when it comes to your Personal Information. Below is a summary of those choices, how to exercise them and any limitations.

California residents and customers with business in the State of California may read our supplemental California Privacy Rights Notice.

Opt-out. Where you have consented to our processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section 11. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt in to the new purpose. Where your consent for the processing of Personal Information is otherwise required by law or contract, we will comply with the applicable law or contract. Note that, due to the nature of the Services you may have to log in to your account or provide the email and/or other identifying value or information that is associated with your Personal Information in order for us to be able to complete your request. Note that if you withdraw your consent to processing, some features of the Services may not be available.

Email unsubscribe. An “Unsubscribe” link will be provided in each email communication sent by us so that you can opt out. However, we may continue to send non-promotional, transaction-related emails in response to your request regarding any products or services of the Airship Platform you have requested. We may also need to send you certain important business communications related to your current relationship with us, such as communications regarding updates to our Terms of Use or this Privacy Statement, service announcements or security information, and you will not be able to opt out of those communications.

Opt-out of cookies and ads. We will only use cookies with your permission in compliance with applicable laws. You may stop or restrict the placement of technologies on your device or remove them by selecting “Reject All” in the cookie consent manager banner, by adjusting your preferences as your browser or device permits, or for this Site using the Cookies Settings link at the bottom of the webpage in the cookie consent manager banner. You may also opt out by enabling Global Privacy Control (“GPC”) in your web browser or browser extension, which we recognize to the extent required by applicable law as further described below in the Do Not Track subsection. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. You may opt out by enabling Global Privacy Control (“GPC”) in your web browser or browser extension, which we recognize to the extent required by applicable law. Enabling GPC will automatically set your cookie settings to opt out of the sharing of Personal Information for behavioral advertising. If you choose to use GPC, you will need to turn it on for each supported browser or browser extension you use. Other than GPC, Airship does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. For information about “do-not-track”, visit http://www.allaboutdnt.org.

Access, correct, amend, port, restrict processing, or delete Personal Information. You have the right to control or change certain uses and disclosures of your Personal Information, as set out in this Privacy Statement. Subject to any exemptions provided by law, you have the right to: seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request to know more details about the categories or specific pieces of Personal Information we collect; to ask that we correct, update, amend or delete your Personal Information; to ask that we do not sell your Personal Information (where “sale” is defined according to the local regulations in your state of residency); and to not be discriminated against for exercising these rights. Please note that we do not currently sell your Personal Information as “sales” are defined under the laws of Nevada or California, as further detailed below in the sections dedicated to those locations. We will respond to such requests within a reasonable timeframe. California residents and customers with business in the State of California may read our supplemental California Privacy Rights Notice for information in addition to and as a complement to the rights listed here as to your rights under the California privacy laws.

You may email privacy@airship.com to exercise one of the individual rights outlined above with regard to Personal Information held about you by us. Such requests will be processed in accordance with local laws. We will respond to such requests within a reasonable timeframe. Although we make good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. In addition, please note that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations. We will not discriminate against you for exercising your rights under the GDPR, CCPA or other applicable data privacy laws or regulations.

EU residents. If you are located in the European Economic Area or the UK, in addition and as a complement to the rights mentioned above, you also have the following rights:

• The right of access means that you may, at any time, request to be informed as to whether we are processing any Personal Information concerning you, and, where that is the case, what Personal Information we are processing, as well as the characteristics of the processing activities carried out.
• The right of rectification means that you may request rectification of your Personal Information where it is incorrect. You may also request, where your Personal Information is incomplete, that it be completed insofar as it is relevant to the purpose of the processing activity in question.
• The right to erasure means that you may request erasure of your Personal Information, particularly where: (i) they are no longer necessary in relation to the purposes for which they were collected (ii) your Personal Information are processed on the basis of your consent, you wish to withdraw consent and there is no other legal ground for the processing of your data (iii) you object to the processing of your Personal Information and wish therefore to have them deleted (iv) your Personal Information have been unlawfully processed; (v) your Personal Information must be deleted to meet a legal obligation provided either under European Union law.
• The right of limitation means that you may request that we limit the processing of your Personal Information (i) where you challenge the accuracy of your Personal Information, for a period of time enabling us to verify the accuracy of said Personal Information, (ii) where, processing has been proved to be non-compliant and you prefer that we limit the processing of your Personal Information instead of full erasure, (iii) we no longer need your Personal Information for the purposes of processing but you still need them for the establishment, exercise or defense of a legal claim; (iv) where you have objected to the processing of your Personal Information and you wish to limit processing for the period of time required to verify whether the legitimate reason you present is indeed justified. Limited processing means that processing of your Personal Information will be limited to the mere storage of the corresponding personal data. We will not carry out any other operation involving the Personal Information in question.
• The right of objection means that you may object to the processing of your Personal Information, where such processing is based on the pursuit of our legitimate interests (or those of a third party). The right of objection may be exercised where a legitimate reason concerning your particular situation can be proven. In particular, you have a right to object if we process your data for direct marketing purposes. We will cease the processing of your Personal Information unless there is an imperative and legitimate reason for us to keep carrying out this processing activity in accordance with the applicable regulations.
• The right to define guidelines regarding what happens to your Personal Information after your death allows you to indicate your instructions concerning your Personal Information and how they are kept, deleted and communicated after your death.
• The right to portability means that you may receive, on your request, and according to the applicable legislation, your Personal Information in a structured, commonly used and machine-readable format, or, on your request, have them communicated directly to a third-party of your choice, where this is legally and technically possible.
• The right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

In addition, you have the right to be informed whether you are subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”) or not. Automated Decision-Making currently does not take place on our Sites or Services.

Special Consent Terms for German Residents: If you are located in Germany, the following consent terms apply to Personal Information shared by you with Airship via the Sites:

You hereby consent to Airship Group, Inc. (“Airship”) processing your voluntarily provided Personal Information in order to occasionally receive the latest resources, reports and events information from Airship about its mobile marketing and engagement services. Except as otherwise described in this Privacy Statement, your Personal Information will not be forwarded to third parties.

You can withdraw your consent to receive information from Airship about its mobile marketing and engagement services at any time (without any cost) by clicking at the unsubscribe link at the bottom of each of our emails (if applicable, also with regard to the use of your telephone number) or by sending an email to privacy@airship.com. The withdrawal of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

By submitting your Personal Information via the form on the Sites, you confirm that you agree to the processing of your Personal Information by Airship as described above in this Privacy Statement, which also informs you about your other data subject rights. 

California residents. Please refer to the California Privacy Rights Notice here.

Colorado residents. If you are a resident of Colorado, you have the right to: opt out of the processing of Personal Information; seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request deletion of Personal Information; request correction of inaccuracies in your Personal Information; opt out of processing of your Personal Information for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer; or obtain and transfer your Personal Information. You can exercise these rights by contacting us at privacy@airship.com with the subject line “Colorado Data Rights Request” and providing us with your name and the email address associated with your account.

Nevada residents. If you are a resident of Nevada, you have the right to: opt out of the processing of Personal Information; opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information; or request correction of inaccuracies in your Personal Information. You can exercise these rights by contacting us at privacy@airship.com with the subject line “Nevada Data Rights Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

Virginia residents. If you are a resident of Virginia, you have the right to: seek confirmation regarding whether we are processing Personal Information about you; request access to Personal Information; request corrections of inaccuracies in your Personal Information; request deletion of Personal Information; or to opt out of processing of your Personal Information for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. Please note that we do not currently sell your Personal Information or engage in profiling as those terms are defined in the Virginia Data Consumer Protection Act. You can exercise these rights by contacting us at privacy@airship.com with the subject line “Virginia Data Rights Request” and providing us with your name and the email address associated with your account.

Customer Data. If you are an individual seeking to exercise your data protection rights (including to seek access to, or to correct, amend, delete, port or restrict processing) in respect of Personal Information stored or processed by us on behalf of one of our customers within the Airship Platform, then you should direct your request to our customer (the data controller). Upon receipt of a request from one of our customers for us to remove the personal data, we will respond to their request within provided in our agreements with the customer. We will retain Personal Information that we process and store on behalf of our customers for as long as needed to provide the services to our customers.

Redress, compliance and accountability. If, after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact: privacy@airship.com or use the contact information in Section 14 (Contact Us) below.

Airship will address your concerns and attempt to resolve any privacy issues in a timely manner.

If you are an EU, Swiss or UK citizen and feel that Airship is not abiding by the terms of this Privacy Statement, please contact us at the contact information provided below. If any request remains unresolved, you may contact the national data protection authority for your EU Member State, Switzerland or United Kingdom.

EU Representative:

Airship France S.A.S has been appointed as Airship’s representative in the EU for data protection matters, pursuant to Article 27 of the EU GDPR. To make an inquiry on matters related to the processing of Personal Information under the EU GDPR, please contact Airship France S.A.S at:

Airship France S.A.S
5, rue des italiens
75009
Paris, France

AirshipLegalEU@airship.com

UK Representative:

Urban Airship UK Ltd. has been appointed as Airship’s representative in the UK for data protection matters, pursuant to Article 27 of the UK GDPR. To make an inquiry on matters related to the processing of Personal Information under the EU GDPR, please contact Airship France S.A.S at:

Urban Airship UK Ltd.
WeWork
c/o Urban Airship UK
1 St Katharine’s Way
LondonE1W 1UN, United Kingdom

AirshipLegalUK@airship.com

12. Third party sites

Please note that our Services may contain links to other websites or digital properties for your convenience and information. We do not control third-party websites, digital properties or their privacy practices, which may differ from those set out in this Privacy Statement. We do not endorse or make any representations about partner or third-party websites or digital properties. Any Personal Information you choose to give to an unrelated third party is not covered by this Privacy Statement. We encourage you to review the privacy policy of any company, website or digital property before submitting your Personal Information. Some third parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Statement.

13. Changes to this Privacy Statement

We may update this Privacy Statement from time to time as deemed necessary in our sole discretion. We will provide notification of any material changes to this Privacy Statement through our Sites or as otherwise required by applicable law. We encourage you to review this Privacy Statement periodically to be informed regarding how we are using and protecting your Personal Information and to be aware of any policy changes. Your continued relationship with us after the posting or notice of any amended Privacy Statement shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Statement take effect immediately after being posted or otherwise provided by us.

14. Contact Us

If you have any questions about our privacy practices or this Privacy Statement, or if you wish to submit a request to exercise your rights, please contact us at:

Airship Group, Inc.
1225 West Burnside, Suite 401
Portland, OR 97209
privacy@airship.com
1-855-391-5311

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