Product and Services Privacy Notice

Product and Services Privacy Notice

Effective Date: 2021-06-02

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.

This Privacy Notice applies to the information collected about users from the United States by Aire in collaboration with our lender partners. 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.

This notice provides more information on our data privacy practices, including how we collect, use, disclose, store and otherwise process personal information in the course of providing services to our lender partners.

If there is anything you are unsure about in this Privacy Notice, feel free to contact our privacy officer [email protected]

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 that is both supplied directly by consumers (also known as “first-party data”) and information that has been passed on to us by the lender. An example of first-party data would be information that a consumer types directly into a credit application or credit line increase request such as stated income.

HOW AIRE COLLECTS FIRST-PARTY DATA

Aire collects first-party data with its lending partners via several methods.

  • A lender may collect first-party data directly from you as part of your application or other credit inquiry, and then share it with Aire for evaluation;
  • A lender, as part of a credit application or other credit inquiry, may use an Application Programming Interface (API) provided by Aire to collect your information. Aire may collect the information directly through a web user interface (“Pulse UI”). The Pulse UI asks you a series of focused questions about your current financial situation such as your income and job status. Aire generates insights from these inputs and provides them to the lender to support its lending decisions.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

Aire may collect personal information from you directly via Pulse UI or from our lending partners to support their provision of services to you.

We have set out in the table below the categories of personal data we may collect.

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, telephone number and best times to contact you.
Financial information This includes details like your income from employment or other sources.
 

Personal circumstances

 

This includes your place of residence.
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.
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 Pulse UI. 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.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes:

  • To help a lender better understand your financial circumstances and behavior as part of its review of your credit application or its ongoing review of your account such as for considering credit line increases;
  • To provide our products and services;
  • For testing, research, analysis and product development;
  • 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 incorrect information, we cannot deliver 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 computing infrastructure.

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 Notice, 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 to track your interaction with the Pulse UI.

We issue first-party cookies to associate the usage of the Pulse UI to a given session. These cookies are fundamental to the usage of the Pulse UI, 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 Pulse UI. This helps us to continuously improve our services. Your use of the Pulse UI 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:

If you do not want us to track and monitor your interaction with the Pulse UI 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 Notice. 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.