Air Publishing Limited ('APL') is a limited company
registered in England & Wales No. 5372166.
Effective: 23rd May, 2018
This Privacy Policy describes how Air Publishing collects, uses and discloses
information, and what choices you have with respect to the information.
Updates in this version of the Privacy Policy reflect changes in data protection
law. In addition, we have worked to make the Privacy Policy clearer and more
understandable by:
- organising it into the sections listed in the Table of Contents below,
- providing a series of examples that help illustrate how the policies may be
implemented by Air Publishing and
- defining and capitalising a few terms that are used more than once for
simplicity and brevity.
When we refer to “Air Publishing”, we mean the Air Publishing
entity that acts as the controller or processor of your information, as
explained in more detail in the “Identifying the Data Controller and Processor”
section below.
Table of Contents:
Applicability Of This Privacy Policy
This Privacy Policy applies to Air Publishing’s online e-commerce and workplace
productivity tools and platform, including the associated Air Publishing mobile
and desktop applications (collectively, the “Services”),
airpublishing.co.uk and other Air Publishing websites (collectively, the
“Websites”) and other interactions (e.g., customer service
inquiries, user conferences, etc.) you may have with Air Publishing. If you do
not agree with the terms, do not access or use the Services, Websites or any
other aspect of Air Publishing’s business.
This Privacy Policy does not apply to any third party applications or software
that integrate with the Services through the Air Publishing platform
(“Third Party Services”), or any other third party products,
services or businesses. In addition, a separate agreement governs delivery,
access and use of the Services (the “Customer Agreement”),
including the processing of any messages, files or other content submitted
through Services accounts (collectively, “Customer Data”). The
organisation (e.g., your employer or another entity or person) that entered into
the Customer Agreement (“Customer”) controls their instance of
the Services (their “Workspace”) and any associated Customer
Data. If you have any questions about specific Workspace settings and privacy
practices, please contact the Customer whose Workspace you use. If you have
received an invitation to join a Workspace but have not yet created an account,
you should request assistance from the Customer that sent the invitation.
Information We Collect And Receive
Air Publishing may collect and receive Customer Data and other information and
data (“Other Information”) in a variety of ways:
- Customer Data. Customers or individuals granted access to a
Workspace by a Customer (“Authorised Users”) routinely
submit Customer Data to Air Publishing when using the Services.
- Other Information. Air Publishing also collects, generates
and/or receives Other Information:
- Services Metadata. When an Authorised User interacts with the
Services, metadata is generated that provides additional context
about the way Authorised Users work. For example, Air Publishing
logs the Workspaces, accounts, people, features, content and links
you interact with, the types of files shared and what Third Party
Services are used (if any).
- Log data. As with most websites and technology services delivered
over the Internet, our servers automatically collect information
when you access or use our Websites or Services and record it in log
files. This log data may include the Internet Protocol (IP) address,
the address of the web page visited before using the Website or
Services, browser type and settings, the date and time the Services
were used, information about browser configuration and plugins,
language preferences and cookie data.
- Device information. Air Publishing collects information about
devices accessing the Services, including type of device, what
operating system is used, device settings, application IDs, unique
device identifiers and crash data. Whether we collect some or all of
this Other Information often depends on the type of device used and
its settings.
- Location information. We receive information from you, your Customer
and other third-parties that helps us approximate your location. We
may, for example, use a business address submitted by your employer,
or an IP address received from your browser or device to determine
approximate location. Air Publishing may also collect location
information from devices in accordance with the consent process
provided by your device.
- Workspace and Account Information. To create or update a Workspace
account, you or your Customer (e.g., your employer) supply Air
Publishing with an email address, phone number, password, domain and/or
similar account details.
- Usage Information.
- Cookie Information. Air Publishing uses cookies and similar
technologies in our Websites and Services that help us collect Other
Information. The Websites and Services may also include cookies and
similar tracking technologies of third parties, which may collect Other
Information about you via the Websites and Services and across other
websites and online services. For more details about how we use these
technologies, please see our Cookie Policy.
- Third Party Services. Customer can choose to permit or restrict Third
Party Services for their Workspace. Typically, Third Party Services are
software that integrate with our Services, and Customer can permit its
Authorised Users to enable and disable these integrations for their
Workspace. Once enabled, the provider of a Third Party Service may share
certain information with Air Publishing. For example, if a cloud storage
application is enabled to permit files to be imported to a Workspace, we
may receive user name and email address of Authorised Users, along with
additional information that the application has elected to make
available to Air Publishing to facilitate the integration. Authorised
Users should check the privacy settings and notices in these Third Party
Services to understand what data may be disclosed to Air Publishing.
When a Third Party Service is enabled, Air Publishing is authorised to
connect and access Other Information made available to Air Publishing in
accordance with our agreement with the Third Party Provider. We do not,
however, receive or store passwords for any of these Third Party
Services when connecting them to the Services. For more information on
Third Party Services, click here.
- Contact Information. In accordance with the consent process provided by
your device, any contact information that an Authorised User chooses to
import (such as an address book from a device) is collected when using
the Services.
- Third Party Data. Air Publishing may receive data about organisations,
industries, Website visitors, marketing campaigns and other matters
related to our business from parent corporation(s), affiliates and
subsidiaries, our partners or others that we use to make our own
information better or more useful. This data may be combined with Other
Information we collect and might include aggregate level data, such as
which IP addresses correspond to postcodes, zip codes or countries. Or
it might be more specific: for example, how well an online marketing or
email campaign performed.
- Additional Information Provided to Air Publishing. We receive Other
Information when submitted to our Websites or if you participate in a
focus group, contest, activity or event, apply for a job, request
support, interact with our social media accounts or otherwise
communicate with Air Publishing.
Generally, no one is under a statutory or contractual obligation to provide any
Customer Data or Other Information (collectively,
“Information”). However, certain Information is collected
automatically and, if some Information, such as Workspace setup details, is not
provided, we may be unable to provide the Services.
How We Use Information
Customer Data will be used by Air Publishing in accordance with Customer’s
instructions, including any applicable terms in the Customer Agreement and
Customer’s use of Services functionality, and as required by applicable law. Air
Publishing is a processor of Customer Data and Customer is the controller.
Customer may, for example, use the Services to grant and remove access to a
Workspace, assign roles and configure settings, access, modify, export, share
and remove Customer Data and otherwise apply its policies to the Services.
Air Publishing uses Other Information in furtherance of our legitimate interests
in operating our Services, Websites and business. More specifically, Air
Publishing uses Other Information:
- To provide, update, maintain and protect our Services, Websites and
business. This includes use of Other Information to support
delivery of the Services under a Customer Agreement, prevent or address
service errors, security or technical issues, analyse and monitor usage,
trends and other activities or at an Authorised User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and
questions. If you contact us, we may use your Other Information
to respond.
- To develop and provide search, learning and productivity tools and
additional features. Air Publishing tries to make the Services
as useful as possible for specific Workspaces and Authorised Users. For
example, we may improve search functionality by using Other Information to
help determine and rank the relevance of content, product and account data
or expertise to an Authorised User, make Services suggestions based on
historical use and predictive models, identify organisational trends and
insights, to customise a Services experience or create new productivity
features and products.
- To send emails and other communications. We may send you
service, technical and other administrative emails, messages and other types
of communications. We may also contact you to inform you about changes in
our Services, our Services offerings, and important Services-related
notices, such as security and fraud notices. These communications are
considered part of the Services and you may not opt out of them. In
addition, we sometimes send emails about new product features, promotional
communications or other news about Air Publishing. These are marketing
messages so you can control whether you receive them.
- For billing, account management and other administrative
matters. Air Publishing may need to contact you for invoicing,
account management and similar reasons and we use account data to administer
accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
If Information is aggregated or de-identified so it is no longer reasonably
associated with an identified or identifiable natural person, Air Publishing may
use it for any business purpose. To the extent Information is associated with an
identified or identifiable natural person and is protected as personal data
under applicable data protection law, it is referred to in this Privacy Policy
as “Personal Data”.
Data Retention
Air Publishing will retain Customer Data in accordance with a Customer’s
instructions, including any applicable terms in the Customer Agreement and
Customer’s use of Services functionality, and as required by applicable law.
Depending on the Services plan, Customer may be able to customise its retention
settings and apply those customised settings at the Workspace level, account
level or other level. Customer may also apply different settings to messages,
files or other types of Customer Data. The deletion of Customer Data and other
use of the Services by Customer may result in the deletion and/or
de-identification of certain associated Other Information. For more detail,
please contact Customer. Air Publishing may retain Other Information pertaining
to you for as long as necessary for the purposes described in this Privacy
Policy. This may include keeping your Other Information after you have
deactivated your account for the period of time needed for Air Publishing to
pursue legitimate business interests, conduct audits, comply with (and
demonstrate compliance with) legal obligations, resolve disputes and enforce our
agreements.
How We Share And Disclose Information
This section describes how Air Publishing may share and disclose Information.
Customers determine their own policies and practices for the sharing and
disclosure of Information, and Air Publishing does not control how they or any
other third parties choose to share or disclose Information.
- Customer’s Instructions. Air Publishing will solely share
and disclose Customer Data in accordance with a Customer’s instructions,
including any applicable terms in the Customer Agreement and Customer’s use
of Services functionality, and in compliance with applicable law and legal
process.
- Displaying the Services. When an Authorised User submits
Other Information, it may be displayed to other Authorised Users in the same
or connected Workspaces. For example, an Authorised User’s email address may
be displayed with their Workspace profile.
- Collaborating with Others. The Services provide different
ways for Authorised Users working in independent Workspaces to collaborate.
Other Information, such as an Authorised User’s profile Information, may be
shared, subject to the policies and practices of the other Workspace(s).
- Customer Access. Owners, administrators, Authorised Users
and other Customer representatives and personnel may be able to access,
modify or restrict access to Other Information. This may include, for
example, your employer using Service features to export logs of Workspace
activity, or accessing or modifying your profile details. For information
about your Workspace settings please contact your Workspace owner.
- Third Party Service Providers and Partners. We may engage
third party companies or individuals as service providers or business
partners to process Other Information and support our business. These third
parties may, for example, provide virtual computing and storage services.
Additional information about the subprocessors we use to support delivery of
our Services is set forth in the Air Publishing Subprocessors section below.
- Third Party Services. Customer may enable or permit
Authorised Users to enable Third Party Services. When enabled, Air
Publishing may share Other Information with Third Party Services. Third
Party Services are not owned or controlled by Air Publishing and third
parties that have been granted access to Other Information may have their
own policies and practices for its collection and use. Please check the
privacy settings and notices in these Third Party Services or contact the
provider for any questions.
- Corporate Affiliates. Air Publishing may share Other
Information with its corporate affiliates, parents and/or subsidiaries.
- During a Change to Air Publishing’s Business. If Air
Publishing engages in a merger, acquisition, bankruptcy, dissolution,
reorganisation, sale of some or all of Air Publishing’s assets or stock,
financing, public offering of securities, acquisition of all or a portion of
our business, a similar transaction or proceeding, or steps in contemplation
of such activities (e.g. due diligence), some or all Other Information may
be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use
aggregated or de-identified Other Information for any purpose. For example,
we may share aggregated or de-identified Other Information with prospects or
partners for business or research purposes, such as telling a prospective
Air Publishing customer the average amount of time spent within a typical
Workspace.
- To Comply with Laws. If we receive a request for
information, we may disclose Other Information if we reasonably believe
disclosure is in accordance with or required by any applicable law,
regulation or legal process. Please see the Data Request Policy to
understand how Air Publishing responds to requests to disclose data from
government agencies and other sources.
- To enforce our rights, prevent fraud, and for safety. To
protect and defend the rights, property or safety of Air Publishing or third
parties, including enforcing contracts or policies, or in connection with
investigating and preventing fraud or security issues.
- With Consent. Air Publishing may share Other Information
with third parties when we have consent to do so.
Air Publishing Subprocessors
To support delivery of our Services, Air Publishing may engage and use data
processors with access to certain Customer Data (each, a
"Subprocessor"). The list below provides important information
about the identity and role of each Subprocessor.
Air Publishing currently uses third party Subprocessors to provide infrastructure
services, and to help us provide customer support and email notifications. Prior
to engaging any third party Subprocessor, Air Publishing performs diligence to
evaluate their privacy, security and confidentiality practices, and executes an
agreement implementing its applicable obligations.
- Infrastructure Subprocessors
Air Publishing may use the following Subprocessors to host Customer Data or
provide other infrastructure that helps with delivery of our Services:
- Rackspace - Cloud Service Provider
- Amazon Web Services - Cloud Service Provider
- Google - Cloud Service Provider
- Other Subprocessors
Air Publishing may use the following Subprocessors to perform other Service
functions:
- Zendesk - Cloud-based Customer Support Services
- SendGrid - Cloud-based Email Notification Services
- PCA Predict – Cloud-based Address and Geolocation Services
- Dotmailer - Cloud-based Email Notification Services
- New Relic - Cloud Service Provider
- iTagg - Cloud-based SMS Notification Services
- AQL - Cloud-based SMS Notification Services
Air Publishing may engage further Subprocessors as required and these will be
added to this Privacy Policy in future updates.
Security
Air Publishing takes security of data very seriously. Air Publishing works hard
to protect Other Information you provide from loss, misuse, and unauthorised
access or disclosure. These steps take into account the sensitivity of the Other
Information we collect, process and store, and the current state of technology.
Given the nature of communications and information processing technology, Air
Publishing cannot guarantee that Information, during transmission through the
Internet or while stored on our systems or otherwise in our care, will be
absolutely safe from intrusion by others.
Age Limitations
To the extent prohibited by applicable law, Air Publishing does not allow use of
our Services and Websites by anyone younger than 16 years old. If you learn that
anyone younger than 16 has unlawfully provided us with personal data, please
contact us and we will take steps to delete such information.
Changes To This Privacy Policy
Air Publishing may change this Privacy Policy from time to time. Laws,
regulations and industry standards evolve, which may make those changes
necessary, or we may make changes to our business. We will post the changes to
this page and encourage you to review our Privacy Policy to stay informed. If we
make changes that materially alter your privacy rights, Air Publishing will
provide additional notice, such as via email or through the Services. If you
disagree with the changes to this Privacy Policy, you should deactivate your
Services account. Contact the Customer if you wish to request the removal of
Personal Data under their control.
International Data Transfers
Air Publishing process Personal Data originating from and sent to a country
located in the EU/EEA solely in countries situated in the EU/EEA and will not
cause any cross border transfer of Personal Data from a country situated in the
EU/EEA to any country situated outside the EU/EEA unless Personal Data is
transferred to a country approved by the European Commission as providing an
adequate level of protection for Personal Data, or the transfer is made using
frameworks such as Privacy Shield developed to enable companies to comply
with data protection requirements when transferring personal data from the
European Union and Switzerland to other countries situated outside the
EU/EEA.
Data Protection Officer
To communicate with our Data Protection Officer, please email
dpo@airpublishing.co.uk.
Identifying The Data Controller And
Processor
Data protection law in certain jurisdictions differentiates between the
“controller” and “processor” of information. In general, Customer is the
controller of Customer Data. In general, Air Publishing is the processor of
Customer Data and the controller of Other Information. Different Air Publishing
entities provide the Services in different parts of the world. Air Publishing
Technologies Limited, an Irish company based in Dublin, Ireland, is the
controller of Other Information and a processor of Customer Data relating to
Authorised Users who use Workspaces established for Customers outside of the
U.S. and Canada. Air Publishing Technologies, Inc., a US company based in San
Francisco, California is the controller of Other Information and a processor of
Customer Data relating to Authorised Users who use Workspaces established for
Customers in the US and Canada.
Your Rights
Individuals located in certain countries, including the European Economic Area,
have certain statutory rights in relation to their personal data. Subject to any
exemptions provided by law, you may have the right to request access to
Information, as well as to seek to update, delete or correct this Information.
You can usually do this using the settings and tools provided in your Services
account. If you cannot use the settings and tools, contact Customer for
additional access and assistance.
To the extent that Air Publishing’s processing of your Personal Data is subject
to the General Data Protection Regulation, Air Publishing relies on its
legitimate interests, described above, to process your data. Air Publishing may
also process Other Information that constitutes your Personal Data for direct
marketing purposes and you have a right to object to Air Publishing’s use of
your Personal Data for this purpose at any time.
Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Air
Publishing’s use of Other Information that constitutes your Personal Data and
(ii) lodge a complaint with your local data protection authority or the UK Data
Protection Commissioner. If you are a resident of the European Economic Area and
believe we maintain your Personal Data within the scope of the General Data
Protection Regulation (GDPR), you may direct questions or complaints to our
supervisory authority:
UK Information Commissioner
Information Commissioner's Office
Wycliffe
House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123
1113 or 01625 545745
Fax: 01625 524510
Contacting Air Publishing
Please also feel free to contact Air Publishing if you have any questions about
this Privacy Policy or Air Publishing’s practices, or if you are seeking to
exercise any of your statutory rights. You may contact us at feedback@airpublishing.co.uk or
at our mailing address below:
Air Publishing Limited
Williamson House
Claremont
Lane
Esher
Surrey
KT10 9DA
