Privacy Policy

Your privacy is important to us. It is Aircast LLP’s policy to respect your privacy
regarding any information we may collect from you across our websites, and, and other sites we own and operate.

1. Information we collect

Log data

When you visit our website, our servers may automatically log the standard data provided by
your web browser. It may include your computer’s Internet Protocol (IP) address, your
browser type and version, the pages you visit, the time and date of your visit, the time
spent on each page, and other details.

Personal information

We may ask for personal information, such as your:

  • Name
  • Email
  • Social media profiles
  • Home/Mailing address
  • Payment information

Business data

Business data refers to data that accumulates over the normal course of operation on our
platform. This may include transaction records, stored files, user profiles, analytics data
and other metrics, as well as other types of information, created or generated, as users
interact with our services.

2. Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We
collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect
and use your information only where:

  • it’s necessary for the performance of a contract to which you are a party or to take
    steps at your request before entering into such a contract (for example, when we provide
    a service you request from us);
  • it satisfies a legitimate interest (which is not overridden by your data protection
    interests), such as for research and development, to market and promote our services,
    and to protect our legal rights and interests;
  • you give us consent to do so for a specific purpose (for example, you might consent to
    us sending you our newsletter); or
  • we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the
right to change your mind at any time (but this will not affect any processing that has
already taken place).

We don’t keep personal information for longer than is necessary. While we retain this
information, we will protect it within commercially acceptable means to prevent loss and
theft, as well as unauthorised access, disclosure, copying, use or modification. That said,
we advise that no method of electronic transmission or storage is 100% secure and cannot
guarantee absolute data security. If necessary, we may retain your personal information for
our compliance with a legal obligation or in order to protect your vital interests or the
vital interests of another natural person.

3. Collection and use of information

We may collect, hold, use and disclose information for the following purposes and personal
information will not be further processed in a manner that is incompatible with these

  • to provide you with our platform’s core features;
  • to process any transactional or ongoing payments;
  • to enable you to access and use our website, associated applications and associated
    social media platforms;
  • to contact and communicate with you; and
  • for analytics, market research and business development, including to operate and
    improve our website, associated applications and associated social media platforms.

4. Disclosure of personal information to third parties

We may disclose personal information to:

  • third party service providers for the purpose of enabling them to provide their
    services, including (without limitation) IT service providers, data storage, web-hosting
    and server providers, debt collectors, maintenance or problem-solving providers,
    marketing or advertising providers, professional advisors and payment systems operators;
  • our employees, contractors and/or related entities; and
  • third parties to collect and process data.

5. International transfers of personal information

The personal information we collect is stored and processed in Germany, United Kingdom and
Finland, or where we or our partners, affiliates and third-party providers maintain
facilities. By providing us with your personal information, you consent to the disclosure to
these overseas third parties.

We will ensure that any transfer of personal information from countries in the European
Economic Area (EEA) to countries outside the EEA will be protected by appropriate
safeguards, for example by using standard data protection clauses approved by the European
Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you
acknowledge that third parties in other jurisdictions may not be subject to similar data
protection laws to the ones in our jurisdiction. There are risks if any such third party
engages in any act or practice that would contravene the data privacy laws in our
jurisdiction and this might mean that you will not be able to seek redress under our
jurisdiction’s privacy laws.

6. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to
us collecting, holding, using and disclosing your personal information in accordance with
this privacy policy. If you are under 16 years of age, you must have, and warrant to the
extent permitted by law to us, that you have your parent or legal guardian’s permission to
access and use the website and they (your parents or guardian) have consented to you
providing us with your personal information. You do not have to provide personal information
to us, however, if you do not, it may affect your use of this website or the products and/or
services offered on or through it.

Information from third parties: If we receive personal information about
you from a third party, we will protect it as set out in this privacy policy. If you are a
third party providing personal information about somebody else, you represent and warrant
that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal
information. If you have previously agreed to us using your personal information for direct
marketing purposes, you may change your mind at any time by contacting us using the details
below. If you ask us to restrict or limit how we process your personal information, we will
let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal
information that we hold about you. You may request a copy of the personal information we
hold about you. Where possible, we will provide this information in CSV format or other
easily readable machine format. You may request that we erase the personal information we
hold about you at any time. You may also request that we transfer this personal information
to another third party.

Correction: If you believe that any information we hold about you is
inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the
details below. We will take reasonable steps to correct any information found to be
inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply laws applicable to us in
respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection
law and wish to make a complaint, please contact us using the details below and provide us
with full details of the alleged breach. We will promptly investigate your complaint and
respond to you, in writing, setting out the outcome of our investigation and the steps we
will take to deal with your complaint. You also have the right to contact a regulatory body
or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of
communications (including marketing communications), please contact us using the details
below or opt-out using the opt-out facilities provided in the communication.

7. Cookies

We use “cookies” to collect information about you and your activity across our site. A
cookie is a small piece of data that our website stores on your computer, and accesses each
time you visit, so we can understand how you use our site. This helps us serve you content
based on preferences you have specified. Please refer to our
Cookie Policy for more information.

8. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or
enter bankruptcy, we would include data among the assets transferred to any parties who
acquire us. You acknowledge that such transfers may occur, and that any parties who acquire
us may continue to use your personal information according to this policy.

9. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we
have no control over the content and policies of those sites, and cannot accept
responsibility or liability for their respective privacy practices.

10. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices.
We will take reasonable steps to let users know about changes via our website. Your
continued use of this site after any changes to this policy will be regarded as acceptance
of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis
on which we process your personal information, we will ask you to re-consent to the amended
privacy policy.

Aircast LLP Data Controller
James Causon
[email protected]

This policy is effective as of 7 August 2018.