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
