Here at Aire Labs Ltd, your privacy is important to us. When handling and using your personal information we are subject to the General Data Protection Regulation (“GDPR”).
This notice sets out how we use and process your personal information when you use our product for the purposes of providing a credit reference to a Partner. If you do not provide your personal information to us, we will be unable to provide services to you.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We may collect, use and process any of the following items:
We are data controller for:
- Information you enter into our forms on the Aire Web Application.
- Financial information
- Personal circumstances
- Financial behaviour
- Details of your use of our Web Application
- Any special category data that you share.
We are data processor for:
- Information provided to us by the Partner for the purpose of providing a Credit Reference (which is defined below). Such information may include, but is not limited to, details of financial products that the Partner has provided to or arranged for you, as well as your repayment behaviour in relation to those products.
- Information provided to us by our third party data providers.
- Information available from public data sources.
SPECIAL CATEGORY DATA
Special category data, previously known as sensitive personal data, as defined by GDPR means personal data consisting of information as to –
The racial or ethnic origin of data subjects, their political opinions, their religious beliefs or other beliefs of a similar nature, whether they are a member of a trade union (within the meaning of the Trade Union and Labour Relations (Consolidation) Act 1992), their physical or mental health or condition, their sexual life, the commission or alleged commission by therm of any offence, or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.
On occasions we may ask you to provide special category data. We will only do this with your explicit consent. We will only process this type of information if it is relevant to the understanding of your circumstances. We might also share it with our Partner to ensure you are being treated fairly and according to your needs. Please note that this special category data is not used in generating your Credit Reference (which is defined in the next section).
HOW WILL WE USE YOUR INFORMATION?
We use the information you provide to us to carry out the provision of our service. This includes the creation of a credit reference, which is information relevant to your financial standing that we have collected for this purpose (the “Credit Reference”). In creating the Credit Reference, we may use the information you provide to search for related information to be used in your Credit Reference. This includes, but is not limited to, information about job roles, education, personal circumstances and accommodation.
The Credit Reference that we create will be shared with the Partner for the Partner to review in support of your product application or management with the Partner. As part of this process it will be possible for the Partner to connect the Credit Reference to personally identifiable data about you. The provision of the Credit Reference will not affect your credit history as recorded by Credit Reference Agencies such as Experian, Equifax and Callcredit.
We will also use your data in order to improve the provision of our service. This includes the retention of your data for historical statistical purposes.
The Credit Reference will never be shared with anyone other than our Partner.
We will use and store your personal data for as long as it is necessary to provide our service for the Partner and for the purpose of satisfying any legal, accounting or reporting requirements. Thereafter we will only keep data in anonymised form so that it can no longer be associated with you to help improve our products and services.
We may use processors to help provide our services. Where this is done, any data processed will be in compliance with GDPR.
Our legal basis for processing the information we are data controller for is the consent that you provide before submitting your data. In some circumstances, we may also process on the basis of our legitimate interest in providing a service to a partner or improving our service.
We may also process data supplied to us (as a data processor) on the basis of the legitimate interests of you, our Partner and Aire in requesting the services of our Partners.
Aire does not make automated decisions in relation to the processing of your data.
ACCESS TO YOUR INFORMATION, AND HOW TO CORRECT.
Under the GDPR you have a right to request access to the personal data we hold about you. You may make this request via the Partner who referred you to us. If you request details of the data that we hold directly, we may need to contact the Partner in order to verify your identity.
In addition to your right of access to your personal information, the GDPR provides rights which you may be able to rely on. Subject to certain limitations on certain rights, you have the following rights in relation to your information:
- The right to be informed — you have the right to request a copy of the information that we hold about you.
- The right of access — you have the right to access your personal data that we hold.
- The right to rectification — you have the right to have inaccurate personal data rectified, or completed if it is incomplete.
- The right to erasure — you have the right to have personal data erased, also known as ‘the right to be forgotten’.
- The right to restrict processing — you have the right to request the restriction or suppression of your personal data.
- The right to data portability — you have the right to have the data we hold about you transferred to another organisation and reuse your personal data for your own purposes across different services
- The right to object — you have the right to object to the processing of their your personal data in certain circumstances for e.g. direct marketing
- Rights in relation to automated decision making and profiling — you have the right not to be subject to a decision in respect to automated decision making and profiling.
- Right to withdraw consent — you have the right to withdraw your consent at anytime. Should you wish to exercise this right please contact us using the contact details below.
For more information please see: https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/indWebduals-rights/
If you would like to request to exercise any of your rights or if you have any queries related to accessing your personal information, correction, or your rights under GDPR including requiring a copy of the information we hold on you, we will provide free of charge and within one month. Please contact our Data Protection Officer if you wish to exercise any of your rights by:
Email: [email protected]
Data Protection Officer
Aire Labs Ltd.
First Floor, 11a Curtain Road
If you are not satisfied with our response to your query, you can contact your local data protection authority who will be able to advise you on next steps. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our supervisory authority. Details of their contact information can be found at https://ico.org.uk/global/contact-us/
WHERE YOUR INFORMATION IS STORED?
Your information is stored in the European Economic Area (EEA), but may be transferred outside of the EEA, and processed by staff and organisations outside of the EEA in order to provide our services. Any transfers will be conducted in accordance with GDPR, including the use of processors based in the United States who are participant in the EU-US Privacy Shield programme: https://www.privacyshield.gov/welcome. By submitting your data to us, you agree to this handling.
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on securely protected servers.
We will store your information for as long as reasonably necessary to provide our services.
We use third party applications to monitor and track your interaction with the Web Application. This helps us to continuously improve our services. Your use of the Web Application confirms your acceptance to allow us to use such third party analytics applications. These third party applications are referred to as “Cookies”.
The third party applications we use are:
Google Analytics: How Google uses data when you use the Web Application: https://google.com/policies/privacy/partners/
Mixpanel: To opt out of Mixpanel cookies across all websites visit: https://mixpanel.com/optout
Aire: We use a cookie to manage the sessions between your browser and our servers.
If you don’t want us to track and monitor your interaction with the Web Application using such Cookies you can switch them off by adjusting your browser settings. Most web browsers allow you to do this via your browser’s settings.
Aire is a trading name of Aire Labs Ltd.
Aire Labs Ltd. Is a company registered in England and Wales (Company Number 08844341). Registered address: 1st Floor, 11A Curtain Road, London, England EC2A 3LT
ICO registration number: ZA046116
Last updated 2018-06-05