US Application Privacy Policy

US Application Privacy Policy

Effective Date: 2020-09-18

Aire Labs Inc. (Aire) is a Delaware corporation and wholly-owned subsidiary of Aire Labs Ltd., a United Kingdom company organized under the laws of England and Wales. 

Aire operates as a consumer reporting agency. Our primary business is to provide lenders information and insights to support consumer lending decisions based on information collected directly from consumers (also known as “first party data”). When a lender submits an inquiry to Aire, Aire contacts consumers and collects information via a web application (“Application”). The Application asks the consumer a series of focused questions about their current financial situation such as their income, housing costs, current debts, and job status. Aire generates insights from these consumer inputs and provides them to the lender to support its lending decisions. 

This Privacy Policy applies to the information collected about users from the United States by Aire through its Application. Here at Aire your privacy is important to us. Our collection, management, and use of consumer data is subject to the federal Fair Credit Reporting Act (FCRA) and companion state laws.  We also comply with other various laws and industry standards.

If there’s anything you’re unsure about this Privacy Policy, feel free to contact our privacy officer [email protected]

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We have set out in the table below the categories of personal data we collect from you via  Aire’s Application or from our lending partners to support our provision of services to you.

Categories of personal data Description of category
Contact details This is the personal data that is provided by you or collected by us to enable you to use our service. This may include your email address, contact number and best times to contact you.
Financial information This includes details like your income, the types of financial products you hold (e.g., credit card, mortgage, car loan), how up-to-date you are with your payments, and other debts and personal expenses.
Employment This includes your job title, employer, employment history and length of time at your employer.
Education This includes details of your qualifications and highest level of education attained.
Personal circumstances This includes personal information such as  your housing status, financial dependents, household bills and future plans.
Financial behavior This is the personal data that is provided by you describing your attitude to financial situations and how you would handle them.
Details of your use of our Application This is information collected by us about your use of our service. This could include information about your computer, device, browser, or IP address as well as information about how you answer questions on the Application.  

Cookies and other tracking technologies may be used.

Technical data This is information that is provided to us by our third party data providers. This may include your IP address, the type of browser you use and operating system you use.
Publicly available records This is information that is available from public data sources such as  property records.

We have set out in the table below the categories of personal data that Aire may receive from our lending partners:

Categories of personal  data Description of category
Contact details Information provided to us by our lending partner for the purpose of enabling us to contact you to invite you to complete the Application. This may include your name, email address,  phone number, as well as other identification information.
Account data Information that includes details about the product, payments and outstanding balance including account status that we get from our partners.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes.

  • To help us better understand your financial circumstances and behavior so we can create a credit report which will be shared with a  financial services provider to review and support its lending decision about you; 
  • To provide our products and services;
  • For testing, research, analysis and product development;
  • Detecting  and prevent financial crime, including fraud;
  • To manage complaints and support in dispute resolution;
  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal data in order to dispute information in your consumer report, we may use the information to update your consumer report;
  • For staff training purposes; 
  • To communicate with you; and
  • For any purpose subject to the limitations set forth in this Privacy Notice and applicable law.

SHARING YOUR PERSONAL INFORMATION

We will only share your personal data with those persons who need to handle it for the purposes described above. These may include technology partners, regulatory authorities for compliance purposes, and you and your financial service provider.  Most typically, our purpose for sharing your information will be to a prospective lender who is considering extending credit to you or to a current lender servicing your account.  As a consumer reporting agency, our sharing of consumer reporting data is subject to the requirements of the FCRA.

ACCESS AND CORRECTION OF INFORMATION IN YOUR CREDIT FILE

You have a right under the FCRA to request from Aire the information in your credit file. You can also dispute the completeness or accuracy of any information in your file, and we will investigate your dispute.  If you would like to obtain a  copy of your credit file, you can follow the instructions in our Consumer File Request Form.

We need certain minimum identification information to retrieve your credit file.  If you do not provide us the information or give us the incorrect information, we  cannot deliver you your personal credit report. We take these precautions for your privacy and security protection.  

The personal information you provide to us in connection with ordering your credit report will not be shared with any third parties, except as permitted by law. Your information may be shared with an Aire affiliate for fulfillment of your request and will not be used for any other purpose except as permitted by law. Non-personal data may be used to develop enhancements to our products. 

SECURITY

We take our obligation to protect your data seriously and comply with applicable industry data security standards and legal requirements.  Further, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  We require them to only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will store all the personal information you provide on securely protected servers.

Your information may be accessed outside of the USA by processors based in the European Economic Area (EEA). We will only do so where the processor meets the requirements of the General Data Protection Regulation (GDPR).

HOW LONG WILL DATA BE RETAINED FOR

Our policy is to retain your personal data only as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We generally retain data for no longer than six years following the end of our relationship with you.  However, there may be instances where we may retain information for longer or shorter periods  due to legal or regulatory reporting requirements.

LOCATION

For U.S. consumers, we operate the web application and store the personal information collected from the application in the United States. Our use of the web application for US consumers is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

CONTACTING US

If you have any questions regarding this Privacy Policy, please contact us via the means below. Please note that email communications will not necessarily be secure; accordingly, you should not include your Social Security number,  bank account information, or other sensitive information in your email correspondence with us.

Email: [email protected]

Mailing address:

Privacy Officer
Aire
1300 | Street NW, Suite 400E
Washington, DC 20005

COOKIES

We use cookies to provide basic website functionality and also to assist with monitoring and track your interaction with the Application.

We issue first party cookies to associate the usage of the Application to a given session. These cookies are fundamental to the usage of the Application, if you disable these you will not be able to continue with your application. In addition we use third party applications to monitor and track your interaction with the Application. This helps us to continuously improve our services. Your use of the Application confirms your acceptance to allow us to use such third party analytics applications. The recording of this data is facilitated through the use of cookies.

The third party applications we use are:

  • Google Analytics: How Google uses data when you use the Application: https://google.com/policies/privacy/partners/
  • Mixpanel: To opt out of Mixpanel cookies across all websites visit: https://mixpanel.com/optout

If you don’t want us to track and monitor your interaction with the 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.

CHANGES TO OUR POLICY

We undertake regular reviews of our Privacy Policy. If we make major changes to how we handle your personal data or how we use cookies we will update this privacy policy and publish it on our website.