Last Updated: May 23, 2022
AIR Group, (“AIR”, “we”, “our” or “us”) provides automated retail stores and related services to our customers and partners (collectively, the “Services”), as well as an informational public website (the “Site”).
This Privacy Notice (this “Notice”) describes the types of information we may collect from you or that you may provide to us when you use the Services, submit an inquiry to us, participate in one of our surveys or promotions, browse the Site or otherwise interact with us.
This Notice also describes how we use and share information about you, as well as certain rights and choices you have regarding your information.
By using the Services, submitting an inquiry to us, participating in an AIR survey or promotion, browsing the Site or otherwise interacting with us, you represent to AIR that you have read, understand and agree to the policies and practices described in this Notice. If you do not agree, please do not use the Services or browse the Site.
If you have questions or concerns about this Notice or our collection and use of your information, please contact us at the email address listed below, and we will be happy to address them.
In this Notice, “Personal Information” means information in our possession or control that can be used to identify you (such as your name, email address, or other contact information) and other information that is linked to your personal identifiers (such as brand preferences or purchase history).
This Notice applies only to information that is Personal Information collected by or provided to us through your use of the Services or the Site. For example, if we create aggregated anonymous data that cannot be used by someone else to identify you, that data is not covered by this Notice. This Notice also does not apply to information we may obtain from other sources to other applications or websites that do not link to this Notice, or to the practices of any third parties.
Changes. We may update this Notice from time to time. Whenever we do so, we will include the applicable effective date at the top of the page. Whenever you use the Services, browse the Site or otherwise provide us with information, you are indicating that you agree to the most recent version of this Notice, and you are consenting to our collection and use of information as described in this Notice.
Information We Collect
We collect limited categories of Personal Information from and about users of the Services and the Site. We collect this information directly from you when you chose to provide it to us and automatically when you use your device in connection with a purchase or promotion at one of our smart vending machines or browse the Site. In the following sections, we explain how and why we collect various types of information.
Information You Provide to Us
We collect Personal Information when you chose to provide it to us. For example, if you scan a QR code and provide information to us to take advantage of a promotional offer, or fill out a request for information on our Site, we collect your contact information, such as your phone number or email address, and any other information you provide, which we use to fulfill your request (such as to send you a promotional code to use at one of our smart vending machines). In some cases, you may be asked to verify your identity or your email address.
We use this information to deliver the product or the feature of the Services that you have requested or for such other purpose for which you have provided that information (such as to respond to your inquiries, or provide customer support), or to verify your identity. We also use this information to evaluate and improve the Services and the Site, customize your customer experience, manage our promotions, personalize our communications to you, and for other reasons that you request or that we make known to you at the time you choose to provide the information.
Information We Collect Automatically
When you fill out and submit a form, interact with us using your smartphone or other device, or use the Site, we may collect information from or about you automatically using standard technologies, such as cookies and third-party analytics services.
A cookie is a small file that is stored on your device when you download an application or visit a website. It allows the application or website to recognize your device or recall your settings. You can block cookies or delete them by following the instructions for your device or browser, but not all of the features of the Services or the Site may work as intended if you block our cookies.
Analytics services are provided by third parties to measure various uses of an application or webpage, including general geographic location, browsing actions, and similar information for compiling and analyzing statistical data. These third parties may also use automatic technologies. For example, we may use Google Analytics to help us analyze the Site and how it is used. You can read more about how Google Analytics handles Personal Information here, and you learn how to opt-out of Google Analytics here.
The information we and our third-party service providers may automatically collect includes:
- IP address and general location (such as region or city);
- Device, operating system, and browser types and versions;
- Date, time, and duration of visits to the Site;
- Frequency and number of visits to the Site from a particular IP address; and
- Navigation actions in the Site.
We use automatically-collected information to make the Services and the Site available to you, evaluate and improve the Services and the Site, customize your customer experience, and perform market research. We may use this information to invite you to participate in surveys or to present selected products or promotions to you based on your interests and activities using the Services or the Site.
Information We Share
We share Personal Information with non-affiliated third parties only as described in this Notice unless we obtain your specific consent otherwise.
We may share limited Personal Information with our partners whose products are or may be made available in our smart vending machines or with service providers who provide products or services that help us develop, operate, maintain, and improve the Services and the Site. These service providers include payment processors, email or other communications service providers, and providers of platforms for surveys, customer support, promotions, database management, hosting, cyber security, customer-relations management, and interactive features of the Services and the Site.
Some third parties may collect your Personal Information directly from you in the course of your interaction with them. For example, when you make a payment for a purchase at one of our smart vending machines, your payment is processed directly by a third-party service provider, who may collect Personal Information directly from you in order to process your payment. Where that is the case, your Personal Information will be subject to the privacy policies and other applicable terms of those third parties.
We may disclose certain information for the purpose for which you provided it. For example, if you choose to redeem a promotional code offered by one of our partners for a particular product, we will share information about that redemption with that partner.
We may also use your Personal Information to help protect against fraudulent or unauthorized activities (including unauthorized use of our promotions), improve security, comply with applicable law or legal obligations, cooperate with law enforcement or other governmental authorities, investigate complaints, defend against legal claims, protect the rights and safety of our organization and our employees and customers.
If we are acquired by or merge with another company or go through a similar major corporate event involving a detailed review of our business and operations by third parties, we may disclose your Personal Information as part of such a review. Any such review will be subject to a confidentiality agreement that will limit the use of your Personal Information to the purpose of the review.
Security and Data Retention
We have implemented commercially reasonable and appropriate measures to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your Personal Information, however, also depends on you. Unfortunately, the electronic transmission of confidential information cannot be guaranteed.
We store Personal Information as long as necessary for the purpose for which we originally collected it, or for other legitimate business purposes, including for backup and archival purposes, to analyze and improve the Services and the Site, and to meet our legal, regulatory, or other compliance obligations.
Your Choices and Rights
You may update, correct, or ask that we delete information about you or otherwise exercise your rights under applicable data protection laws by contacting us at the address listed below.
You may elect not to receive promotional communications from us by following the opt-out or unsubscribe instructions included in any such communication or by sending your request to us. If you subsequently make a purchase at one of our smart vending machines or otherwise communicate with us, however, we or our applicable partner may contact you about your purchase or respond to your communication.
We do not track our Site users over time and across third-party applications or websites, and therefore we do not recognize or respond to browser-initiated “Do Not Track” signals.
We respect the data privacy rights of all of our customers, regardless of their location, and we do not discriminate against any of our customers for exercising their rights under data protection laws. If you are a California resident, for example, you may have specific rights under the California Consumer Privacy Act (“CCPA”) and related laws and regulations. We do not sell Personal Information (including as the term “sell” is defined under the CCPA), and have not done so in the last twelve months.
You may have additional rights under applicable law. For example, you may have the right to obtain a copy of your Personal Information or to request the deletion of certain Personal Information. We will make reasonable efforts to comply with such requests where applicable, but we may take reasonable steps to verify your identity before responding to such requests, and we may refuse such requests where we are otherwise legally required to retain the information, where we are exempt from such requests under applicable law, or where the requests are unreasonably repetitive, require disproportionate technical effort, or create privacy risks for others.
Notice to Non-U.S. Residents
We are based in the United States, and our data processing activities occur in the United States. Accordingly, except as otherwise expressly agreed by AIR, the information we collect is governed by United States law, which may be different from the laws applicable to Personal Information in your country of residence. Any Personal Information you provide to us will be processed and stored in the United States. By providing us your Personal Information or using the Services or the Site, you consent to our collection, transfer, processing, and storage of your Personal Information in the United States in accordance with this Notice.
The Services and the Site are intended for adults and are not directed to minors. We do not knowingly collect any information, including Personal Information, from or about minors. If you become aware that your minor child has provided us with Personal Information, please contact us. If we become aware that a minor has provided us with Personal Information, we will take steps to remove such information.
AIR Group, Inc.
50 California Street
San Francisco 94111