1. Introduction
1.1 We are committed to safeguarding the privacy of all individuals whose personal data we store and process; in this notice, we explain how we will handle your personal data.
1.2 This notice applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this notice, “we”, “us” and “our” refer to Airacom Limited. For more information about us, see section 9.
2. How we use your personal data
2.1 In this section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships OR effective account management.
2.3 We may process information relating to transactions, including purchases of goods and services, that you enter into with us (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters OR for the purpose of using our Push-to-Talk and Workforce Management applications to notify users on geographic locations, user status identifications, emergency alerts and man-down notifications (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters and/or updating users within your and/our organisation on the status of your users. The legal basis for this processing is consent OR our legitimate interests, namely communications with our customers OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and provide critical services.
2.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your first name, your last name, your position or job title, and your email address. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services, ensuring the security of our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6 We may process personnel photographic identification data that are provided in the course of the use of our services (“identification data”). This data may include a valid driving licence OR a valid passport. The source of the customer relationship data is you or your employer. This data may be processed for the purposes of identification of people or persons within an organisation. The legal basis for this processing is consent OR our legitimate interests, namely proper management of our customer relationships OR effective account management OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.8 We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.9 In addition to the specific purposes for which we may process your personal data set out in this section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.
2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our team or group of companies this means our subsidiaries insofar as reasonably necessary for the purposes, and on the legal basis, set out in this notice. Information about our group of companies can be found at airacom.com/contact.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose, specify personal data category or categories to our suppliers or subcontractors identified at airacom.com/contact insofar as reasonably necessary for the supply or provision of services.
3.4 Financial transactions relating to our goods and services may be handled by our payment services provider, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at stripe.com/gb/privacy.
3.5 In addition to the specific disclosures of personal data set out in this section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this section 4, we provide information about the circumstances in which your personal data may be transferred to [countries outside the European Economic Area (EEA)].
4.2 We have offices and facilities in the United Arab Emirates, Dubai, Nigeria. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the European Commission .
4.3 EU citizens in branches or locations which are situated in countries outside of the European Union. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from The European Commission.
5. Retaining and deleting personal data
5.1 This section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) Personal data will be retained for a minimum period of three months following the cessation of all our services.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data category will be determined based on advice from Regulatory Authorities to which we belong.
5.5 Notwithstanding the other provisions of this section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
