Privacy Policy

At AirSuite Limited (“AirSuite”, “we”, “us”,“our”), we are committed to protecting your Personal Information and ensuring compliance with the New Zealand Privacy Act 2020 (Privacy Act) (if you are in New Zealand) and the European Union’s General Data Protection Regulation (GDPR) (if you are in a Member State of the European Union.

This Privacy Policy applies to anyone who has dealings with AirSuite and it gives details of the Personal Information that we collect via the following sources:

• our website at www.airsuite.com (“Website”);
• our online web application for analysing data collected by our sensors at portal.airsuite.com (“AirSuite Monitor Portal”), and any other online platform(s) used for trading (collectively, “Site”);
• our mobile applications for interacting with and monitoring our sensors, published for Android and iOS (“AirSuite Monitor App”);
• any associated software components, media, printed materials, online or electronic documentation;
• and when you interact with us or buy our products and use our services.

This Privacy Policy also covers how and why Personal Information is collected, used, disclosed, and processed; and the lawful basis on which your Personal Information will be processed by us; how you can request access to or correction of your Personal Information, and how you can manage receiving communications from us.

If you are in the Member State of the European Union, then you have additional rights under the applicable privacy laws which are outlined in the ‘GDPR’ sections of this Privacy Policy.

This Privacy Policy should be read in conjunction with our Website Terms of Service and our Platform Terms and Conditions. Unless defined in this Privacy Policy, all capitalised terms have the same meaning given to it in our Website Terms of Service and our Platform Terms and Conditions.

What is Personal Information

Personal Information means any information relating to an identified or identifiable natural person.

Your informed consent

Please read this Privacy Policy carefully. Based on our Privacy Policy, you can then make an informed decision on whether you wish (and continue) to visit our Site, buy our products and use our services or interact with us. You can withdraw your consent at any time for any reason by notifying us at privacy@airsuite.com that you no longer wish your Personal Information to be used for the purposes outlined in this Privacy Policy. If you no longer agree with our Privacy Policy or do not agree with the changes that we make to our Privacy Policy from time to time, please discontinue your use of our Site. If you withdraw your consent, we will stop collecting your Personal Information, but we may not be able to continue providing some or all of our services to you.

If you wish to ‘opt-out’ of receiving certain communications from us or your Personal Information being provided to third parties for direct marketing purposes, then you should notify us or unsubscribe from our mailing list by clicking ‘unsubscribe’ at the bottom of our communications to you. If you decide to do so, then we will only communicate with you to the extent necessary to perform our obligations to you, such as to complete our transaction with you or where we are required to do so by law.

You can otherwise contact us at any time by clicking “Contact Us” on our Website.

For the purpose of:

• The GDPR, the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
• The Privacy Act, your Personal Information will only be used for the purpose for which it was collected in accordance with this Privacy Policy and the law. If that purpose no longer exists or your Personal Information is no longer needed for the purpose in which it was collected, then we will no longer use your Personal Information.

Data controller

The “data controller” (for the purpose of the GDPR) and the “agency” (for the purpose of the Privacy Act 2020) that is responsible for your information is AirSuite Limited (NZCN 7087710), based in New Zealand.

Information that is collected and processed

The table below outlines the 4 general categories of information that we collect for processing and the legal basis on which that information is processed:

Category		Types of Personal Information collected	Legal Basis for Processing
Information you provide us You may choose to provide us with Personal Information when you communicate with us.	Example: when you make request for our products and or make enquiries, or when you opt-in to receive our marketing and promotional materials.	Contact details (name, postal address, email, phone number). Your preferences. Your account information. Your payment information. Any other information you choose to give us.	We collect and process this information based on our legitimate interest to respond to your requests or queries, to provide you with a high level of customer service, to market and promote our products and services to you, and to fulfil our contractual obligations to you.
Information that is necessary for your use of our Site We ask for and collect Personal Information when you use our Site.	Example: when you sign up or register as a user of the AirSuite Monitor Portal and use our Site, when you use our online platform.	Your account history. Any additional information we request and that you provide in connection with the performance of our services to you.	We collect and process this information based on our legitimate interest to respond to your requests or queries, for assessment and acceptance purposes, for example, to confirm and verify your identity,administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists, to provide you with a high level of customer service, and to fulfil our contractual obligations to you. Without the information, we may not be able to provide you with our products and services.
Information we automatically collect from your use of our Site When you use the Site, we automatically collect Personal Information about the services you use and how you use them, products you trade on our online platform.	Example: when you use certain features within our Site, when you visit or when you browse the content on our Site, when you accept our ‘Cookies’ (see ‘How we use cookies’ below).	Your user information (content, webpages, other actions performed on our Site). Your payment, credit. arrangements and transaction history.	We collect and process this information based on our legitimate interest to conduct system administration and report aggregate information to our affiliates, business partners and/or other parties to conduct Site analysis and Website performance review to ensure a positive user experience, performance of our contractual obligations to you, to provide and improve the functionalities of our Site and improve our products and services.
Information we collect from you when you buy our products or use our services When you buy our products or use our services, we collect Personal Information required to provide you with our products and services.	Example: We process your Personal Information to assess, analyse and improve our products and services.	Your product and service preferences. Your payment and credit information. Any other information you choose to give us.	We collect and process this information based on our legitimate interest to provide you with our services and providing you with insights.Enhancing the customer experience across AirSuite. Improving the quality of our products and services, processes and technology, and building new products and services.
Information we collect from third parties We may collect information that others provide about you or obtain information from other sources (including our third party service providers) and combine that information we collect through our Site.	Example: when you link, connect or login to our Site from a third party service (eg Google, Facebook etc), and when other parties provide us with information, including data to help improve user experience and to detect fraud and Site security issues.	Your Service preferences. Your profile information from third party sites. Your user information from third party sites. Other information from publicly available sources.	We collect and process this information based on legitimate interest in ensuring a positive user experience, ensuring the security of our Site and the safety of our customers and, where necessary, to communicate with you.

In addition to those that are outlined in the table, we will also collect and process information where you give us your informed consent.

How the information is used and disclosed

With your consent, we will collect, use and disclose your Personal Information for the following purposes:

• to provide you with our services, including to:
  • identify and verify your identity;
  • communicate with you, such as sending you promotional emails about new products and services, special offers, promotions;
  • update, secure, and troubleshoot our Site as well as providing support;
  • share information, when it is required to provide our products and service;
  • improve and develop our products and services;
  • personalise the services and make recommendations to you;
  • respond to your queries regarding the Site, or our products and services;
  • provide you with a positive user experience when you visit our Site, buy our products or use our services;
  • to bill you and to collect our money that you owe us, including authorising and processing credit card transactions or undertaking credit checks (if necessary);
  • develop new products and services, features and/or content; and
  • keep you updated on things that are happening at AirSuite;
• to run and maintain our Site such as ensuring our Site and network system are secure;
• for our internal record keeping purposes;
• to allow for the operation of our legitimate business activities and functions;
• the sale of all or substantially all of our business (whether by assets or shares);
• to comply with our legal obligations; and
• for any other purposes you consent to.

From time to time, we may disclose your Personal Information to third party service providers, in both New Zealand and overseas, whom we engage to assist us in our business functions and activities (for example providing maintenance services for our Site). We will require our third party service providers to comply with the terms of this Privacy Policy and the applicable privacy laws of the country in which they are located.

From time to time AirSuite may remove personal identifiers from your Personal Information and maintain it in an aggregate form. We may combine this information with other information that we hold to produce anonymous, aggregated statistical information to form part of our services or our marketing. Aggregate information may be shared with third parties and used in connection with our business function. Once your Personal Information is anonymised, it may no longer be capable of identifying, or being re-linked, to you.

How we use cookies

We use cookies to collect information when you use our Website or Site. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Cookies help us provide you with a better Site and user experience by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the information you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.

If you decline cookies, this may prevent you from taking full advantage of functionality and services available on our Site.

Transfer of information to other countries

In order for you to use our Site and to provide you with our products and services, we may need to disclose and transfer your Personal Information to third parties located outside New Zealand. We will take reasonable steps to ensure that the overseas recipient is required to protect your Personal Information in a way that, overall, provides comparable safeguards to those under New Zealand privacy laws. Examples of such steps include a written agreement between us and the recipient, or making reasonable enquiries regarding the data protection standards of the country in which the recipient is domiciled in.

If you are in a Member State of the European Union, your Personal Information may be transferred to or stored in a geographic region that imposes different privacy obligations than the country you are currently in. We will only transfer your Personal Information to a “secure third country”, such as New Zealand, or to a third country or international organisation where appropriate safeguards are provided in accordance with the GDPR.

Controlling your Personal Information

You can choose to restrict the collection or use of your Personal Information in the following ways:

• Indicate to us in writing that you do not wish to be contacted for direct marketing purposes. If you have told us, then you have opted-out of receiving electronic marketing communications from us.

• If you have previously agreed to us using your Personal Information for direct marketing purposes, you can change your mind at any time by letting us know you no longer wish for your Personal Information to be used for direct marketing purposes by contacting us using the contact details listed above or unsubscribing from our mailing list by clicking ‘unsubscribe’ at the bottom of our electronic communications.

We will not sell, distribute or lease your Personal Information to third parties unless we have your consent, or we are required by law to do so.

Links to other websites

Our Site may contain links to other websites of interest. However, once you have used these links to leave our Site, you should note that we do not have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting third party websites and such websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to those websites.

How you can request access or correction of your information

If you wish to request correction of your Personal Information that we hold, please login to your account on our Site to make changes. If you do not have an account with us, then contact us using the contact details listed above.

We will correct your Personal Information if it is necessary to ensure that your Personal Information is accurate, up to date, complete and not misleading. If we decide that it is unnecessary to correct your Personal Information, we will let you know the legal reasons for our decision. If you are not happy with those reasons, then you have the right to complain to the New Zealand Privacy Commissioner: www.privacy.org.nz/your-rights/how-to-complain/.

If you wish to request access to your Personal Information that we hold, contact us using the contact details listed above.You have the right to request access to Personal Information that we hold about you. If we do not give you access to the Personal Information that you have requested, then we will let you know the legal reasons for not disclosing your Personal Information. If you are not happy with the legal reasons provided, then you have the right to complain to the New Zealand Privacy Commissioner: www.privacy.org.nz/your-rights/how-to-complain/.

Security

We are committed to ensuring that your Personal Information is secure. To prevent unauthorised access, use, modification, disclosure, loss or destruction, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information that we collect. We will also take reasonable steps to ensure that our third parties whom we disclose your Personal Information to also take reasonable steps to protect your Personal Information in accordance with this Privacy Policy and the applicable privacy laws.

Privacy complaints

If you are in New Zealand and you think that your privacy rights have been interfered with, you can make a written complaint to our Privacy Officer by email to privacy@airsuite.com, or otherwise contact the NZ Privacy Commissioner at www.privacy.org.nz/your-rights/making-a-complaint/complaint-form/.

GDPR

If you are in a Member State of the European Union, you have the following rights with respect to your Personal Information:

• Lodging complaints: You have the right to lodge a complaint with a ‘supervisory authority’ established by a Member State under Article 51 of the GDPR.
• Right of rectification: You have the right to obtain from us without undue delay the rectification of inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before correcting it.
• Right to restrict processing: You have the right to limit the ways in which we use your Personal Information, in particular where:
  • you contest the accuracy of your Personal Information;
  • the processing is unlawful and you oppose the erasure of your Personal Information;
  • we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or
  • you have objected to the processing of your Personal Information pending the verification by a supervisory authority of whether our legitimate grounds to process override your own.
• Right of access and portability: You have the right to request certain copies of your Personal Information held by us. You may also be entitled to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider nominated by you (where technically feasible).
• Right to be forgotten: You have the right to request the erasure of your Personal Information without undue delay where one of the grounds set out in Article 17(1) of the GDPR apply. Please note that:
  • we may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety;
  • we may retain and use your Personal Information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, auditing and regulatory compliance obligations; and
  • because we maintain our Site to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be able to be removed from our backup systems.