Airside Privacy Policy

2. HOW DO WE USE THIS INFORMATION?

We do not sell, lease, trade, or otherwise profit from your personal information and we do not share your personal information with third parties for marketing purposes. We will only use your personal information for the purposes described below.

If you are a user of our Services and resident in the EEA or UK, we will only use your personal information for a particular purpose if we have a “legal basis” for this. We have set out below the legal bases we rely upon for each purpose.

a) To create your App account and send you important service information in connection with your account.

To use the App, you need to create an account using your email address. We may send important information regarding our Services (for example, notice of changes to our terms, policies, and/or other administrative information) to this email address.

• Information used for this purpose: email address, Unique IDs associated with your account.
  
• Legal basis relied upon: The processing described above is necessary for us to perform our obligations under the contract in place between you and Airside.

b) To enable you to use the App.

We use your personal information to enable you to use the App. This includes allowing you to: upload a Selfie; ask us to verify your identity or share information about your verified identity with a third party (each as explained further below); see a record of your in-App activities; and delete your information from the App.

• Information used for this purpose: information that you provide or that we create to enable you to use the App.
• Legal basis relied upon: The processing described above is necessary for us to perform our obligations under the contract in place between you and Airside.

c) To verify your identity at your request.

You may choose to use the App to verify your identity. To do this, you will need to provide us with a Selfie and with images and scans of your government-issued identity document (e.g. a passport or driving license). With the help of our service providers (Thales, Inc., Thales DIS USA, Inc., Onfido Limited, and Acuant, Inc.), we will conduct various checks to ensure that your identity document is genuine and to confirm that it belongs to you. Some of these checks require us to create “Facial Scans” – which are scans of your face as it appears in your Selfie and in the portrait image of you contained in your identity document. We compare these two Facial Scans to one another to confirm that the person who appears in the Selfie is also the owner of the identity document. This helps us verify your identity. The information we collect, share, and use may be considered biometric information under applicable privacy laws, including US biometric privacy laws. If you are an App user in the US, please read Airside’s Biometric Information Policy for more information.

• Information used for this purpose: images and scans of your government-issued identity document and information we extract from these images and scans; Selfie; Facial Scans.
  
  
• Legal basis relied upon: The processing described above is necessary for us to perform our obligations under the contract in place between you and Airside. Where we need to use Facial Scans to uniquely identify you, we will also ask for your explicit consent. The consent screen we display to you within the App will make clear how your information will be used if you consent, and you may revoke your consent at any time (see the section below headed “Your Rights” for more information).

d) To share information about your verified identity, and details of people traveling with you, with third-party partners at your request.

You may ask the App to share information about your verified identity with our third-party partners. (Depending on the service you choose to use, you may also ask the App to provide our partners with personal information you provide to us about other people who are traveling with you on the same booking.)

The information that we share will vary depending on the specific service you choose to use (further details of the services available in the App are on the Airside App section of our website). However, we will only share information about your verified identity (or personal information you have given to us about someone traveling with you) with one of our partners at your request, and we will always tell you what information will be shared. At any time, you can review your active and expired share requests within the App and you may revoke any active requests unless we are required by law to limit your ability to do so.

Please be mindful that if you ask us to share personal information with a third-party partner, Airside cannot control how that partner will use this information. Before you ask us to share any personal information you should review the partner’s privacy policy to ensure you understand what will happen to your information after we have shared it.

• Information used for this purpose: images and scans of your government-issued identity document and information we extract from these images and scans; Selfie; such other information as you instruct us to share. If you are an App user in the US, the information we share may be considered biometric information under US privacy laws; please read Airside’s Biometric Information Policy for more information.
• Legal basis relied upon:
  • If you ask us to share your personal information with a partner, we will do so on the basis that this processing is necessary in order for us to perform our obligations under the contract in place between you and Airside.
  • If you ask us to share information which constitutes a “special category” of data under European/UK privacy laws (including Facial Scans if the third party will use them to uniquely identify you), we will also ask for your explicit consent. The consent screen we display to you within the App will make clear how your information will be used if you consent and you may revoke your consent at any time (see the section below headed “Your Rights” for more information).
  • If you ask us to share personal information about someone else who is traveling with you on the same booking (and with whom Airside may not have entered into a contract), we will do so on the basis that this is necessary for the legitimate interest of providing a Family and Group Travel service.

e) To customize content within our App.

We use your device’s language preference setting to set the language of the App for you.

• Information used for this purpose: Device language.
• Legal basis relied upon: The processing described above is necessary for us to perform our obligations under the contract in place between you and Airside.

f) To handle and respond to your requests, complaints, or other queries.

If you contact us via the App, website or otherwise, with a request (for example, if you subscribe to one of our email newsletters), a complaint, or a query, we will need to use certain personal information about you in order to handle and respond to your communication.

• Information used for this purpose: The information processed for these purposes will depend upon the nature of your query but will include your contact details, details of your request, complaint, or query, and any of the personal information we hold that is necessary to handle and respond to your query.
• Legal basis relied upon: This will depend upon the nature of your query and our relationship with you, but we will typically rely on the fact that this processing is necessary:
  • for us to perform our contract with you (for example, if you are an App user with a question about the App);
  • for compliance with a legal obligation (for example, if you contact us seeking to exercise your legal rights in respect of your personal information); or
  • for a legitimate interest (for example, Airside has a legitimate interest in responding to website queries about our products and services, and in providing email newsletters to people on request. Please note that you may unsubscribe from our newsletters at any time by clicking the unsubscribe link in the email sent to you).

g) To enforce our terms and policies.

We use the personal information we have about you to enforce our terms and policies. This may include suspending or banning your account if we decide that you are violating the terms that govern your use of our Website(s) or the App (for example, if we learn that you are using the App and are younger than 16 years old). We process personal information for this purpose on the basis that it is necessary for us to perform our obligations under the contract in place between you and Airside.

h) To analyze the use of our Services so we can review and improve our Services.

We use your personal information to analyze and better understand how people are using our Services so that we can improve them. For example, if you ask us to verify your identity, but our technology is unable to scan your government-issued identity document, we may record this error and associate it with limited information about your identity document (such as the country that issued it and the year it was issued) so we can improve our technology’s ability to scan those types of document.

• Information used for this purpose: Information collected using cookies and similar technologies (such as Google Analytics and Firebase Performance Monitoring). For example, the fact that you created or deleted your account, captured a Selfie, or uploaded an identity document plus associated metadata (for example, the date on which you did these things, your user ID (as set by Airside), and your device operating system). See our Cookie Policy for more information, and click on this link to learn more about Google Analytics. Please note:
• Legal basis relied upon: We rely on consent where this is required by law to collect your information using cookies or similar technology (as explained further in our Cookie Policy). Otherwise we process your information on the basis that we have a legitimate interest in reviewing and improving our Services.

i) To keep our Services stable and secure.

We use your personal information to identify technical and security issues (such as App crashes or technical bugs) so we can keep our Services functioning and secure.

• Information used for this purpose: Information collected using cookies and similar technologies (such as Firebase Crashlytics). See our Cookie Policy for more information.
• Legal basis relied upon: We rely on consent where this is required by law to collect your information using cookies or similar technology (as explained further in our Cookie Policy). Otherwise we process your information on the basis that we have a legitimate interest in identifying and tackling any technical or security issues to ensure the Services are continuously available and functioning securely.

j) In connection with a business transaction or to obtain professional advice.

We may use the personal information we have about you in connection with an actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, or to obtain professional advice. We use personal information for these purposes on the basis that it is necessary for Airside’s legitimate interest in running its business in a commercial and compliant manner.

k) For compliance with a legal obligation, to exercise, establish or defend legal rights, or to protect someone’s vital interests.

In exceptional cases, we may need to use the personal information we have about you where this is necessary for compliance with a legal obligation, to exercise, establish or defend legal rights, or to protect someone’s vital interests. For example, we may be required by law to disclose information in response to a request from a government or law enforcement body. The legal basis we rely upon will depend upon the specific purpose for which it is necessary to use your personal information, but we will only process your information where it is necessary for compliance with a legal obligation; necessary to protect your or another person’s vital interests; or necessary for the purpose of a legitimate interest.

Note for users who are not old enough to enter into an enforceable contract.

As explained in a) – g) above, we use your personal information for certain purposes because this is necessary in order for us to perform our contract with you. However, if you are under the age of majority (which is 18 years old in most countries) with a limited ability to enter into an enforceable contract, we may not be able to rely upon this legal basis. If this is the case, we will instead use your personal information for the purposes described in a) – g) above on the basis that our use of your information is for the purpose of a legitimate interest. In particular, we have a legitimate interest in using your personal information to: create your account and send you important service information; enable you to use the App; verify your identity at your request; share information about your verified identity with third-party partners at your request; customize content within the App; handle and respond to your requests, complaints or other queries; and enforce our terms and policies.

• Information used for this purpose: the information described under a) – g) above.
• Legal basis relied upon: The processing described above is necessary for our legitimate interests as described above.