What Kinds of Information Does AireSpring Receive, Collect and/or Use?
Visiting AireSpring’s Web Site – Except as otherwise provided in this policy or in other written documentation or policies that may be provided to you regarding the services or the AireSpring web site, the only personally identifiable information that we collect about visitors to our web site is that which is provided to us voluntarily by you. “Personally identifiable information,” also referred to as “personal information,” is information that tells us specifically who you are, such as your name, street address, email address, cell phone number, landline telephone number, billing address, social security number, credit card number, other service account information, and certain other financial information. In general, you can visit our web site without telling us who you are or revealing any personally identifiable information about yourself.
For the convenience of our visitors and customers, the AireSpring web site may contain links to other sites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies before disclosing information to third parties on these independent sites.
Webinars – AireSpring hosts occasional webinars. If you register for an AireSpring webinar, AireSpring may gather your name, title, and contact information and business name. AireSpring does not share this information with outside companies or individuals.
Feedback – At times we may ask you for contact information or conduct on-line surveys in order to better understand your needs in order to provide you with a customized experience. If we wish to use this information other than as set forth in this policy, we will let you know at the time of collection. We will take commercially reasonable steps to safeguard this information from unauthorized access. However, any aggregate data that you send to us such as your questions, suggestions, ideas or other creative material (“Feedback”) belongs to us and will not be treated as confidential. We may use, reproduce, adapt, distribute, display, disclose or create derivative works from Feedback without acknowledgement or compensation to you.
Information Received in the Course of Providing Services – In the process of providing telecommunications services, AireSpring automatically records call detail records, namely record records that indicate the start and stop times of a call the number from which a telephone call originated, the telephone number of the called person or entity, and information concerning how the call was routed. Also in connection with some of AireSpring’s services, AireSpring receives and or assigns Internet protocol (“IP”) addresses, types of equipment ordered or used, and configurations of such equipment. In the course of ordering AireSpring’s services, you may provide contracts or documents to AireSpring that contain personal information such as a Service Order form, credit application, technical specification, or letter of authorization.
AireSpring monitors the equipment on its network, including any customer premises managed services equipment supplied by AireSpring. AireSpring performs such monitoring for the purposes of error detection, traffic flow, delay, lag time, jitter, latency, speed, and network capacity. AireSpring does not believe such information is capable of being used to identify any particular individual.
Information Received from Third Parties – AireSpring may receive certain information about you from third parties such as credit information from outside agencies, information from social media websites or platforms when interacting with an AireSpring posting or website, and marketing or lead information from third party agents, employment placement services, channel partners, or marketing lead companies. AireSpring receives business cards and contact information from potential customers or vendors in the course of its business operations, including appearances at trade shows. When a customer applies for AireSpring’s services, AireSpring may check credit or due diligence information from an outside credit agency or business evaluation agency. AireSpring may obtain information about a customer by checking customer–supplied business references and/or invoices from a prior provider.
Employment Information Received – Personal information AireSpring receives can also include information you provide to AireSpring in a job application/Curriculum Vitae (“CV”)/resume or an employment-related document such as an IRS W-4 form.
Use of Received Information
Summary of Information Usage – Your information received by AireSpring is used to i) determine credit worthiness, ii) set up a customer account, iii) provision service and/or equipment, iv) maintain service, v) provide technical support, vi) manage and protect AireSpring’s service and equipment, vi) detect and prevent fraud or abuse, v) authenticate authorized contacts for a customer, vi) suggest new products or services, vii) suggest updates to existing equipment or services, viii) develop new products or services, ix) respond to lawful subpoenas and/or Investigative Demands from government agencies, x) verify your identity, as deemed necessary, when you contact AireSpring, xi) assist in establishing a connection to emergency services, xii) assist credit and collection agencies in collecting past due amounts, xiii) assist outside auditors and regulators as needed, xiv) protect you or others from fraud or other illegal activities, xv) comply with the law, xvi) use in connection with a merger, acquisition, or sale, xvii) allow a third party payroll service to issue paychecks and withhold taxes, xviii) allow third party accountants to audit or prepare financial reports, xix) allow third party auditors to perform their audits; xx) notify you in an emergency situation, or xxi) upon your request. In the case of an individual applying for work at AireSpring, information on an employment application may be used to conduct a background check and/or credit check.
Provisioning and Troubleshooting Service Issues. As needed, AireSpring may provide needed information to third parties in support of provisioning or troubleshooting services.
Use of Aggregated Information. Aggregate information may be provided to AireSpring’s outside accountants and auditors. Aggregate information is used for AireSpring’s network planning. Also, aggregate information may be supplied in response to United States Census Bureau requests, United States Department of Labor Requests, or other governmental agencies that request statistical information from AireSpring. Aggregate information excludes information that could be used to identify any particular individual.
In Response to Lawful Government Demands. Certain federal, state and local laws or government regulations may require us to disclose personally identifiable information about you. In these circumstances, we will use reasonable efforts to disclose only the information required by law, subpoena or court order to be disclosed.
Customer Proprietary Network Information (“CPNI”) – Certain information related to your telecommunications services account with AireSpring such as to whom, where and when you make calls is considered Customer Proprietary Network Information (“CPNI”). CPNI is protected by specific federal laws and regulations and as such we are fully committed to comply with such laws and regulations, both through our web site and in all other respects. Without your consent, we will only share or disclose your CPNI (i) to market to you services or products among the categories of services or products you currently subscribe, (ii) to initiate, render, bill and collect fees for our telecommunications services, (ii) to protect you or other carriers from illegal or fraudulent use of, or subscription to, our services or to protect our rights or property, (iii) to provide your call location information in certain specified emergency situations, (iv) to comply with industry traceback requests, including those from USTelecom, to help identify the source of illegal robocalls or other unlawful calls, (v) to comply with rural call completion investigations in compliance with Federal Communication Commission (“FCC”) guidance and rules, (vi) to comply with subpoenas and civil investigative demands, (vii) to troubleshoot issues with your service, and (viii) for other legally permissible purposes.
Transfer of Information Outside of the EU – AireSpring may transfer your information to countries outside the EU using appropriate safeguards when necessary. In such instances, we will obtain your consent before using your data for these purposes, as required by applicable law.
Security and Protection of Personally Identifying Information
Security – AireSpring maintains physical, electronic and procedural safeguards designed to protect the confidentiality of personally identifiable information provided by you on and through our web site. For example, unique passwords or user identifications are required to access a number of our web site services. In addition to requiring the use of a unique password or user identification, all payments processed through our web site require certain personally identifiable information provided by you to be sent in a “Secure Session” using Secure Socket Layer encryption technology. This technology is designed to encrypt – or scramble – your financial or credit card account information to help prevent unauthorized parties from reading it. We seek to regularly test and update our technology to help protect your personally identifiable information. However, such precautions do not guarantee that our web site is invulnerable to all security breaches. AireSpring makes no warranty, guarantee, or representation that use of our web site is protected from all viruses, security threats or other vulnerabilities or that your information will always be secure. When doing business with others, such as advertisers to whom you can link from our site, you should consider the separate security and privacy policies of those other sites.
Children’s Privacy. AireSpring does not intend for AireSpring’s web site to be used by children under the age of 13, nor does AireSpring seek to collect information about children under the age of 13. If you are under the age of 13, please do not provide us with information and promptly exit this site. We encourage parents or legal guardians to talk with their children about the potential risks of providing information over the Internet.
Reviewing and Modifying Your Personally Identifying Information
Updating Your Personally Identifying Information Online. Your use of certain of AireSpring’s online services may permit you to update personally identifiable information from our database by accessing our web site. If you remove certain information from your account, we will only retain copies of such information as are necessary for us to comply with governmental orders, resolve disputes, troubleshoot problems, enforce any agreement you have entered into with us, and as otherwise reasonably necessary. In accessing AireSpring’s web portal, you will be required to enter a unique password, which is to be kept private at all times.
Qualified Consumer Report Request. If you are a “Qualified Consumer”, defined as i) a California resident, ii) a resident of any other state in the Unites States that provides for enhanced rights pertaining to your personal identifying information, or iii) a natural person who is a citizen or resident of a European Union (“EU”) Member State, you may request AireSpring provide you with a report concerting your personal information (“Report”). Based on what you request, the Report may include among other information a) the categories of your personal information (“Consumer Personal Information” or “CPI”) AireSpring collected, b) the categories of sources from which the CPI was collected, c) the business purpose for collecting the CPI, d) the categories of third parties with whom AireSpring shares CPI, and e) the specific pieces of CPI AireSpring collected from you. Upon AireSpring’s verification that you are a Qualified Consumer, AireSpring shall respond to your request. You may not request a Report more than twice in a twelve (12) month period. If you are not a California resident, AireSpring shall conform its response, as reasonable and/or necessary, to applicable law.
Qualified Consumer Deletion Request. If you are a Qualified Consumer, you may request AireSpring delete your personal information provided by you to AireSpring. There are several reasons for which AireSpring may not be required to delete your personal information, including if AireSpring uses your personal information i) in support of completing or performing a transaction for goods or services, ii) internally, in a lawful manner that is compatible with the context in which you supplied the information, iii) to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with AireSpring, iv) to detect any security incidents, or protect against fraudulent, deceptive or illegal activity, v) for debugging to detect and repair errors that impair existing intended functionality, vi) pursuant to a response to a government-issued warrant, order, or other legal process, or to comply with any legal obligation, or vii) for the exercise of free speech, or ensure the right of another consumer is allowed to exercise his/her right to free speech, or exercise another right provided for by law. If the above exceptions do not apply and upon AireSpring’s verification you are a Qualified Consumer, AireSpring shall delete as applicable your personal information from AireSpring records and direct any service providers to delete your personal information from their records.
Additional Qualified Consumer Requests Under the GDPR. If you are a Qualified Consumer from the EU you also have a right to request rectification of your personal information. You also have the right to request restrictions on the processing of your personal information in certain cases such as inaccurate personal information, unlawful processing of your personal information, or no further need of AireSpring for your personal information. At any time you have the right to withdraw your consent to any use of your personal information to which you previously consented. You have the right to request your personal information to be transferred to a third party. Please be aware that i) under certain circumstances the GDPR may limit your exercise of these rights and ii) without the use of your personal information, AireSpring may not be able to provide you the services or the same quality of services you request.
No Discrimination. AireSpring shall not discriminate against you for exercising your legal rights as a Qualified Consumer with respect to service or price, except if the difference is reasonably related to the value provided by your data. AireSpring may charge for administrative costs if AireSpring determines a Qualified Consumer’s request(s) are unfounded or excessive, or alternately in such situations AireSpring may refuse such unfounded or excessive request(s) and notify the Qualified Consumer.
Submitting Requests, Questions, Comments, and Complaints
|(Option 2) to reach AireSpring Customer Service;|
|AireSpring Web Page:||www.airespring.com (click on “Support”);|
|U.S. Mail or Courier Service:||AireSpring, Inc.
Attn: Customer Service Department
7800 Woodley Avenue
Van Nuys, California 91406
Reporting fraud or abuse. If you believe you have been the victim of any abusive practice or service, such as but not limited to unlawful content, you may report such abuse via email to firstname.lastname@example.org.
Lodging a Complaint Under the GDPA. If you are a Qualified Consumer from the EU and think your data protection rights have been breached, or you otherwise have a complaint with AireSpring’s privacy practices, you have the right to lodge a complaint with your national Data Protection Authority (“DPA”), which can be located through web site https://edpb.europa.eu/about-edpb/board/members_en.