Privacy Policy

Aeris Communications, Inc. (“Aeris”), along with our affiliates and subsidiaries under common ownership and control (the “Aeris Group“), are committed to protecting the personal information that we hold about you. This privacy policy (“Privacy Policy”) outlines what personal information we collect via our website (www.aeris.com) (“Website“), and how we use, store or share your personal information as a controller of such personal information.

Aeris Communications, Inc., located at 2099 Gateway Place, Suite 600, San Jose, CA 95110, is the data controller of your information.

In this Privacy Policy “we”, “us” and “our” refers to Aeris and “you” refers to any individual about whom we collect personal information via our Website. By “personal information” we mean any information about you, that you or third parties provide to us, including “personal data” for the purposes of data protection laws. For the purposes of data protection laws, personal data includes any information which identifies you, directly or indirectly, in isolation or when paired with other information. We do not process your sensitive personal information (such as data relating to your health, ethnic origin, sexual orientation among other things) for any of the activities within the scope of this Privacy Policy.

You can contact us in relation to this Privacy Policy at: privacy@aeris.net.

The table below sets out what we use your personal information for and our legal basis for doing so:

What we use your personal information for	Lawful basis
To purchase our products and services.	Legitimate Interests
To improve user experience.	Legitimate Interests
For marketing purposes, to keep you informed of our latest offerings and products.	Your Consent/Legitimate Interests
To conduct analytics.	Legitimate Interests
To communicate with you.	Legitimate Interests
As required by applicable law.	Compliance with Legal Obligations

 

We will keep your personal information confidential but may disclose it to:

Third party	Activity
Affiliates and subsidiaries of the Aeris Group	We may share the information we collect within the Aeris Group.
Service providers	We may store information with or allow access to your information to service providers that support our business, including with website maintenance, database and cloud, customer support, or other services.
Commercial partners	We may share your information with commercial partners to assist in them providing services to you.
Third-party advertising providers	We may allow third-party advertising providers to collect information on our Website for advertising purposes.
Law enforcement and government officials	We may disclose any of your information to government officials as necessary to comply with applicable laws and orders. If we receive a request to disclose any such information, we may do so if we believe in good faith that such request is lawful and that disclosure is reasonably necessary to comply. We may also disclose your information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
Other disclosures	We may disclose your information to third parties (such as law firms, insurers and accountants) if we believe it is necessary in order to protect our property rights or rights of a third party, to protect the safety of any person or of the public, or to prevent any activity that we believe is harmful, illegal or unethical. Also, we may share your information in the context of mergers, acquisitions, divestitures and sales of all or some of our assets, in accordance with applicable law.

 

Depending on your location, your local laws may provide you with rights relating to your personal information. These include the right:

• To access, rectify or delete of your personal information.
• To object to the processing of your personal information.
• To request that such processing be restricted.
• To withdraw your consent, where we are relying on it to use your personal information (for example, for marketing purposes).
• To have the communication of your personal information provided in a structured, commonly used and machine-readable format, and have the right to require us to transfer this personal information to another organisation, at your request.
• Not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.

To exercise any applicable rights, contact us using the information under the “Contact Us” section of this Privacy Policy.

Some of the parties we share your personal information with (as outlined in Section 4 of this Privacy Policy) may be based in a country other than your country of residence. These countries may not have the same level of protection for your personal information as the country in which you initially provided the information. We will ensure that any such international transfer of your personal information is done in compliance with our obligations under applicable law, including using the appropriate legal mechanism to cover such transfer.

If you live in the EEA or the United Kingdom, to the extent we provide any of your personal information to any member of the Aeris Group or a third-party that is based outside of the EEA or UK (“Third Countries”), we may rely on a decision from the European Commission / UK Government determining that the Third Country provides an adequate level of protection with regard to its data protection laws. Alternatively, we may rely on appropriate legal mechanisms, in force at the time, in respect of transfers of your personal information to a Third Country, for example, by using the European Commission’s “standard contractual clauses”, as modified by the UK Government.

Subject to the exercise of your rights as outlined under this Privacy Policy, we shall retain your personal information for no longer than is necessary, having regard for the purpose(s) for which it was collected initially, as well as any applicable legal requirements. Therefore, retention periods may vary depending on the purpose(s) of the processing and applicable law.

Our Website may have links to other websites run by third parties. We are not responsible for the protection and privacy of any information that you provide while visiting such sites. Providing a link to third party websites does not mean that we endorse or warrant the products or services provided by any third parties and this Privacy Policy does not relate to such websites. Please consult the respective privacy policies of third party websites that will outline how they handle personal information.

Cookies are small text files made up of letters and numbers that are saved onto your computer, smartphone, tablet or other device when you visit our site. Cookies store small amounts of information. For example, when you visit and then later return to our site, our site will recognise a certain type of cookie stored on your device and will know that you have visited our site before. Cookies help us to improve your visit and experience when browsing our site by, for example, storing certain information so that you don’t have to re-enter it on subsequent visits and enabling you to navigate between pages efficiently. Cookies also assist us with tracking which pages of the site you have visited. We use both persistent cookies (which stay on your device and will work until their expiry date, unless detected and disabled by you beforehand) and session cookies (which expire when you close your browser).

When you first use our Website, a banner will be displayed, informing you about the cookies we use on our Website, and providing you with control over the cookies you wish to use during your use of the Website. You can change your cookie preferences at any time by clicking on the “Cookie Preferences” link at the bottom of the Website.

It is possible to disable and remove cookies from your computer or device by activating the setting on your browser that allows you to do so. You will need to know what browser you are using and what version you have. You can refer to your browser’s help section or visit the aboutcookies.org website for further information and assistance with cookies. Please be aware that if you use your browser settings to block or amend certain cookies, our site may not be able to function properly, and your browsing experience may change for the worse.

Where you have received marketing emails from us you can adjust your preferences by accessing the email preferences portal using the “Manage Preferences” link in the email.

We may modify this Privacy Policy at any time to accurately reflect how we gather and manage your personal information. All changes to this Privacy Notice will become effective immediately.

If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

The personal information we collect. The types of personal information we collected and disclosed in the past 12 months (which we may also collect in the future) are summarized in the following chart.

Category	Examples
Identifiers	A real name, unique personal identifier, online identifier, postal address, email address, account name, job title, company, professional contact information or other similar identifiers.
Recordkeeping information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))	Signature, or telephone number. Some personal information included in this category may overlap with other categories.
Internet or other similar network activity information	Browsing history, search history, information on a individual’s interaction with our websites, emails, or online services.
Sensitive personal information	Account credentials for AerPort, IoT Accelerator and our Partners page, which are classified as sensitive under the CCPA. As noted above, we do not collect other sensitive personal information about you.
Other information about you that is linked to the above categories of information	For example, interests in Aeris products and services.

 

Categories of sources. We collect personal information from the following categories of sources: you, others at your company, service providers, commercial data resellers.

Why we collect, use, and disclose personal information. We use and disclose the personal information we collect for our business and commercial purposes. For detailed information about how we use and share such personal information, please see the “For what purposes do we use your information,” and “With whom do we share your information” sections above in this Privacy Policy. Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information for money to third parties. We do not engage in such activity and have not engaged in such activity in the twelve months prior to the effective date of this Privacy Policy.

We also may use and disclose deidentified information as permitted by law. We maintain and use this information only in deidentified form, and we do not attempt to reidentify such information except as needed to determine that the information is appropriately deidentified.

Recipients of personal information. We may disclose each category of personal information we collect to the following categories of third parties for our business and commercial purposes: affiliates and subsidiaries of the Aeris group, service providers, commercial partners, law enforcement and government officials, or other third parties if required by law (such as in response to a subpoena or court order). While we do not sell the personal information we collect for money, we may share identifiers and Internet or other network activity information for interest-based advertising purposes (also known as “cross-context behavioral advertising”) by allowing third-party advertising providers to collect data on our Website.

California Rights. If you are a California resident, the CCPA allows you to make certain requests about your personal information, subject to certain exceptions and limitations. Specifically, the CCPA allows you to request us to:

• Inform you about the categories of personal information we collect, use, disclose, or share for interest-based advertising; the categories of sources of such information; the business or commercial purpose for collecting, disclosing, or sharing your personal information; the categories of personal information we have either shared or disclosed for a business purpose; and the categories of third parties to whom we have shared or disclosed personal information.
• Provide access to and/or a copy of personal information we hold about you.
• Delete personal information we have collected from you.
• Correct personal information we hold about you.

Opt you out of our sharing of personal information for interest-based advertising purposes (also known as “cross-context behavioral advertising”). The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. While the CCPA also provides an opt-out opportunity related to sensitive personal information, Aeris uses and discloses sensitive personal information, as defined under the CCPA, only for purposes that do not require an opt-out opportunity.

We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. To exercise your privacy rights described above other than the right to opt out of “sharing,” please submit a request to us via email using the contact information provided above or call us at 1-888-462-3747. You may designate an authorized agent to submit a request on your behalf by submitting written, signed permission to the contact information provided above.

We process requests to opt out of “sharing” in a frictionless manner. To exercise the right to opt out of “sharing,” please visit our Website with Global Privacy Control (“GPC”) enabled. Our Website recognizes GPC signals as a way to opt out of sharing personal information for interest-based advertising purposes. You can activate GPC by implementing a browser or extension that offers this control. GPC is a third-party tool. More information and instructions on implementing this tool are available here. You must implement GPC on each browser or device where you want to opt out.