Privacy Policy

Effective date: 11 October 2024

Aerolink L.L.C-FZ, operating as Aerolink (www.getaerolink.com) (“Aerolink,” “we,” “us,” or “our”), values your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information. It also informs you of your rights and options regarding your personal information and how to contact us with questions.

By registering an account or using any Aerolink website, application, product, software, tool, data feed, or service (collectively the “Service”), you consent to the terms of this policy.

 

 

Table of Contents:

  1. Applicability of this Privacy Policy

  2. How We Collect, Disclose, and Use Personal Information

  3. Information We Collect

  4. Data Retention

  5. How We Use Information

  6. How We Share Personal Information

  7. Your Rights

  8. Data Transfer & International Data Transfer

  9. Security

  10. Changes to This Policy

  11. Children

  12. Contact Information

  13. Additional Information for California Residents

 

 

1. Applicability of this Privacy Policy

This Privacy Policy applies to users globally, including Aerolink’s mobile applications, Partner Platform, websites, features, and other services or interactions (both online and offline) with Aerolink. It describes how Aerolink collects and uses data for all users unless covered by a separate privacy notice. Specifically, it applies to:

  • End Users: Individuals who use Aerolink services for personal purposes.

  • Business Users: Entities that use Aerolink’s services and may provide us with End Customers’ personal information.

  • End Customers: Individuals who receive services ordered by other Aerolink account owners.

  • Job Applicants: Individuals applying for roles at Aerolink.

2. How We Collect, Disclose, and Use Personal Information

We collect information in various ways depending on your interactions with our Services, including:

  • Directly from you: When you create an account, sign up to receive communications, place orders, make purchases, or contact us.

  • Automatically: Through cookies, server logs, and similar technologies when you interact with our Services.

  • From other sources: Such as business partners, service providers, online social media networks, and other third parties. For example, if you submit a job application, we may conduct a background check.

Aerolink classifies data and information systems in accordance with legal requirements, sensitivity, and business criticality to ensure appropriate protection. The “data controller” determines the purposes and means of data processing. The “data processor” acts on behalf of a controller in processing personal information.

Aerolink as a Data Controller

Aerolink assumes the role of data controller when it determines the purposes and means of processing personal data. As a data controller, Aerolink is responsible for ensuring that personal data is processed in compliance with applicable data protection laws. Activities under Aerolink's data controller capacity include:

  • Direct Sign-ups: Aerolink is the data controller when users sign up directly with the service, covering:

    • B2C Context: End users who register directly for Aerolink's services.

    • B2B Context: Business Users or End Customers who sign up directly.

Key activities:

  • Service Delivery: Using data to provide Aerolink's products and services.

  • Fraud Prevention: Monitoring and detecting fraudulent transactions and activities.

  • Legal Compliance: Adhering to applicable financial, legal, and regulatory obligations.

  • Service Enhancement: Developing and improving products and services based on data analysis.

  • Job Application Processing: Handling personal data from job applications.

Aerolink as a Data Processor

When providing services on behalf of a Business User, Aerolink functions as a data processor, such as:

  • B2B Context for End Customers: Acting as a data processor for data related to End Customers of Business Users.

  • Service Execution for Business Users: Following instructions from Business Users, like creating accounts and distributing eSIMs.

When acting as a data processor, Aerolink advises users to consult the privacy policy of the respective data controller (the Business User) for data handling details. Aerolink strictly adheres to data controllers' instructions to ensure data confidentiality and security in line with applicable laws and contractual obligations.

3. Information We Collect

The following table provides examples of the type of information we collect and how we use it.

Context

Types of Data

Primary Purpose for Collection and Use

Account Registration

Name, contact information (email), and account-related activity.

Legitimate interest in providing account functionalities, easy checkout, and preference saving.

Biometric Information

Biometric identifiers from photo IDs and selfies.

Used with consent for identity confirmation through eKYC where legally required.

Business Users

Name, contact information (email, phone number, physical address) of Business User employees.

Legitimate interest in business communications, project, service, and billing management.

Necessary Online Tracking

Browser type, OS, IP address, domain, click-activity, referring website, date/time stamp.

Legitimate interest in website functionality.

Non-Essential Tracking

Tracking technologies for analytics, user interaction, and behavior-based advertising.

Used with consent where required by law.

Demographic Information

Age, location.

Legitimate interest in understanding users for service customization.

Job Applicants

Contact details, education, job history.

Legitimate interest in evaluating applicants and legal compliance where required.

Feedback/Support

Name, email address, content of feedback/support requests.

Legitimate interest in responding to feedback and issues.

Mobile Devices

Unique identifiers from mobile devices visiting our website.

Legitimate interest in identifying unique visitors and monitoring visits.

Order Placement

Name, billing address, shipping address, email, phone number, payment details.

Contract performance for order processing.

Partner Promotion

Information from co-branded promotions with third parties.

Legitimate interest in promotion fulfillment.

Surveys

Information provided in surveys.

Legitimate interest in collecting feedback and opinions relevant to Aerolink.

4. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy or as required by law. Retention periods consider the data’s sensitivity, potential harm from unauthorized use, and applicable legal requirements.

5. How We Use Personal Information

In addition to the purposes described above, we use information to:

  • Identify you when visiting our websites.

  • Provide products and services.

  • Conduct analytics and improve offerings.

  • Communicate with you and respond to inquiries.

  • Send marketing and promotional materials.

  • Detect and prevent fraudulent or illegal activity.

  • Comply with legal or regulatory obligations.

6. How We Share Personal Information

We may share information in the following situations:

  • Affiliates and Acquisitions: With corporate affiliates or acquiring entities.

  • Legal Requirements: In response to subpoenas, legal processes, or to exercise rights or investigate illegal activities.

  • Partner Promotions: With third parties during co-branded promotions.

  • Service Providers: For website administration, payment processing, technical support, and order fulfillment.

  • With Consent: With other third parties when authorized by you.

7. Your Rights

Depending on your location and applicable laws, you may have rights to:

  • Access and correct personal data.

  • Request deletion of data.

  • Withdraw consent for data processing.

  • Object to data processing.

Please contact us using the information below to exercise your rights. Verification of identity is required.

8. Data Transfer & International Data Transfer

Since Aerolink’s services are accessible globally, your data may be transferred internationally. By submitting your personal information, you agree to its transfer, storage, and processing outside your country of residence.

9. Security

We follow industry standards to protect personal information. However, transmission over the internet is not completely secure, and users are responsible for safeguarding their credentials.

10. Changes to This Policy

We may modify this policy. Material changes will be communicated through notices on our website or via email. We encourage you to review this policy periodically.

11. Children

Aerolink’s services are not intended for children under 13, and we do not knowingly collect personal information from minors under 16 without parental consent.

12. Contact Information

For privacy-related questions, please contact us:

Email: support@getaerolink.com
US Toll-Free: +1 (888) 870-2848


 

 

13. Additional Information for California Residents

California law requires certain additional disclosures:

Category of Personal Information

Category of Recipients

Disclosures for a Business Purpose

Identifiers (name, email, online identifier)

Affiliates, Business Partners, Service Providers

Disclosed for account management, order processing, and communication.

Government Issued Identification

Network operators, Professional services (e.g., auditors, law firms)

Disclosed for eKYC and legal compliance.

Financial Information

Operating systems, Payment processors, Professional services

Disclosed for payment and billing.

Protected Classifications (e.g., age, sex, race)

Professional services, network operators

Disclosed where required for eKYC and legal compliance.

Commercial Information

Affiliates, Data analytics providers, Payment processors, Professional services

Disclosed for transaction tracking and order history.


 

 

California Sensitive Information Disclosure
We collect the following categories of sensitive personal information, as defined under California law: biometric information, geolocation, social security number or other government-issued ID information, account log-in details, and payment information. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. We do not use such information for any purposes not identified within the California Privacy Rights Act Section 1798.121.

 

 

2024 Aerolink L.L.C-FZ. All rights reserved.

 

Questions?

If you have any questions about this policy, please contact us at support@aerolink.com