Airside Biometric Information Policy

1. What is Biometric Information?

Biometric Information is a form of Personal Information related to biometric characteristics which may be used to identify an individual. Common examples include fingerprints, voiceprints, scans of a hand, facial geometry recognition, and iris or retina recognition. As used in this policy, Biometric Information includes any “biometric identifiers”, or “biometric information” as defined under applicable law.

2. What Biometric Information Do We Collect?

Airside collects, with the App, your selfie, and facial scans of your face geometry using the selfies, photographs, and/or portrait images from your passport, driver’s license, or other permitted government identification that you upload to the App to verify and confirm your identity.

3. How Do We Use Your Biometric Information?

We use your Biometric Information only as follows:

• To verify your identity when you are using the App;
• To share your Biometric Information with third parties for the limited purpose(s) to which you consent;
• To prevent fraudulent uses of the App; and
• To comply with legal obligations or comply with a request from law enforcement or government entities where not prohibited by law.

4. Opportunity to Consent

When you use the App and in certain other circumstances, you are provided the opportunity to upload and share a selfie or photograph of yourself and portrait images from documents you upload to the App, such as your passport or driver’s license. To create a mobile identity and to share your personal information and Biometric Information with third parties with whom we partner, you are first asked to review our Privacy Policy, Biometric Information Policy, and Terms of Use. Consent for the creation of a mobile identity can be declined or revoked at any time. Any third party sharing of your Biometric Information for which you have provided consent may be revoked, however, if it is revoked before the transaction is completed the service cannot be provided. However, any decline or revocation of your consent may affect your ability to use the App, our services, and third-party services.

5. How Do We Share or Disclose Your Biometric Information?

Airside will only share your Biometric Information with third parties in the following circumstances:

• As required by third parties for the purpose of verifying your Identity or to perform transactions or functions you request;
• Where permitted by law to enforce our Terms of Use; and
• To comply with legal obligations or to cooperate with law enforcement agencies concerning conduct or activity that we reasonably believe may violate federal, state, or local law when required by law.

The third parties we partner with are service providers whose access to your Biometric Information is secured and limited for the purposes we identify when we seek your consent and as described above and below. These third parties include:

Thales, Inc.
Thales DIS USA, Inc.
ID R&D, Inc.
Acuant, Inc.

5. Do We Sell Your Biometric Information?

No, Airside does not sell, lease, trade, or otherwise profit from your Biometric Information.

6. How Long Does Airside Retain My Biometric Information?

Your Biometric Information is stored only until the initial purpose for collection or obtaining such Biometric Information has been satisfied or if we state otherwise when we seek your consent. Since your biometric data is stored on your mobile device, we are not able to delete such data without you doing so directly. We will send a communication to the e-mail address you provide within three years of having your biometric data collected, to remind you of your ability to delete your data and/or request that you renew your consent to having your data stored on your mobile device.

7. How Do I Delete My Biometric Information?

You may delete the Biometric Information directly on the Airside App.

You may request the deletion of any selfie or photograph of your face, including any portrait image provided and Biometric Information submitted during your verification by opening the IDs tab on your device, and scrolling to the bottom to delete. Deleting your IDs will remove your IDs and revoke any active consents. If you uninstall the App, all active consents expire automatically at the expiration date listed when you provided your consent.

Pursuant to the California Consumer Privacy Act of 2018 (CCPA), residents of California are entitled to additional rights and disclosures regarding their Personal information, including Biometric Information.

8. What Kind of Storage and Security Do You Use With My Biometric Information?

We are committed to protecting your information. Using the Airside Digital Identity App, the authenticity of your ID(s) will be verified and protected by robust encryption and security technology. Your information will be encrypted at rest on your device and during transit. Airside does not use a central database and cannot access, does not own, and will not sell information. Your IDs are only located on your encrypted device and are only shared with the identified relying party when you give consent.

Please note that no data transmission or storage can be guaranteed to be 100% secure.

9. Release of Claims

When you provide consent via the Airside App to us for any collection, sharing, or use of your Biometric Information, such consent is at your sole risk.

THE APP IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. AIRSIDE RESERVES THE RIGHT TO RESTRICT OR TERMINATE YOUR ACCESS TO THE APP OR ANY FEATURE OR PART THEREOF AT ANY TIME. AIRSIDE EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, NONINFRINGEMENT, TITLE AND FITNESS FOR A PARTICULAR PURPOSE, AS WELL AS WARRANTIES IMPLIED FROM A COURSE OF PERFORMANCE OR COURSE OF DEALING; THAT ACCESS TO THE APP WILL BE UNINTERRUPTED OR ERROR-FREE; THAT THE APP WILL BE SECURE; THAT THE APP OR THE SERVER THAT MAKES THE APP AVAILABLE WILL BE VIRUS-FREE; OR THAT INFORMATION ON THE APP WILL BE COMPLETE, ACCURATE OR TIMELY. IF YOU DOWNLOAD THE APP OR ANY INFORMATION FROM THE APP, YOU DO SO AT YOUR OWN DISCRETION AND RISK. YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR MOBILE DEVICE OR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE USE OF ANY SUCH MATERIALS. NO ADVICE OR INFORMATION OBTAINED BY YOU FROM THE APP SHALL CREATE ANY WARRANTY OF ANY KIND. AIRSIDE DOES NOT MAKE ANY WARRANTIES OR REPRESENTATIONS REGARDING THE USE OF THE APP IN TERMS OF COMPLETENESS, CORRECTNESS, ACCURACY, ADEQUACY, USEFULNESS, TIMELINESS, RELIABILITY OR OTHERWISE.

AIRSIDE FURTHER DOES NOT MAKE ANY REPRESENTATIONS OR WARRANTIES THAT THE APP WILL BE COMPATIBLE WITH YOUR MOBILE DEVICE OR COMPUTER SYSTEM. YOU MAY USE MOBILE DATA IN CONNECTION WITH THE APP AND MAY INCUR ADDITIONAL CHARGES FROM YOUR WIRELESS PROVIDER FOR THESE SERVICES. YOU AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR ANY SUCH CHARGES. YOU FURTHER ACKNOWLEDGE THAT AIRSIDE MAY FROM TIME-TO-TIME ISSUE UPGRADED VERSIONS OF APP AND MAY AUTOMATICALLY ELECTRONICALLY UPGRADE THE VERSION OF ANY APP THAT YOU ARE USING ON YOUR MOBILE DEVICE. YOU CONSENT TO SUCH AUTOMATIC UPGRADING ON YOUR MOBILE DEVICE AND AGREE TO TIMELY UPGRADE THE APP IN THE EVENT THERE IS NO AUTOMATIC UPDATE. YOU FURTHER AGREE THAT THIS BIOMETRIC INFORMATION POLICY WILL APPLY TO ALL UPGRADES TO THE APP. ANY THIRD-PARTY CODE THAT MAY BE INCORPORATED IN THE APP IS COVERED BY THE APPLICABLE OPEN SOURCE OR THIRD-PARTY LICENSE EULA, IF ANY, AUTHORIZING USE OF SUCH CODE.

IN CERTAIN JURISDICTIONS, THE LAW MAY NOT PERMIT THE DISCLAIMER OF WARRANTIES, SO THE ABOVE DISCLAIMER MAY NOT APPLY TO YOU.

BY USING THE APP, YOU AGREE THAT YOU HAVE READ, UNDERSTAND, AND VOLUNTARILY CONSENT TO THIS AIRSIDE BIOMETRIC INFORMATION POLICY, AIRSIDES TERMS OF USE, AND AIRSIDES PRIVACY POLICY, THAT YOU RELEASE IN FAVOUR OF THE COMPANY, AIRSIDE AND EACH OF OUR PARTNER FEATURES WITHIN THE APP ANY CLAIMS RELATED TO YOUR BIOMETRIC INFORMATION, INCLUDING YOUR FACIAL SCAN DATA, AND THAT YOU CONFIRM THAT YOU ARE NOT ACCESSING THE SERVICES IN ANY JURISDICTION WHERE THE SERVICES ARE NOT PERMITTED BY APPLICABLE LAW.