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Privacy Policy

Last updated:
Jun 2022

Aeropay’s Privacy Policy

Privacy is important to Aeropay Payments, Inc. (“Aeropay” or “we” or “us”), and we want you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with the information collected through the Aeropay platform (the “Platform”). By using the Platform, you agree to the following terms of this Privacy Policy.

Data We May Collect

Personal Information Provided by You: The Platform may collect information you choose to provide, including, but not limited to, your name, date of birth, address, phone number, and e-mail address. It may also collect or reflect information about the activities for which you are using the Platform (e.g., gaming, purchasing cryptocurrency or cannabis) (the “Activities”). Not everyone accepts each of the Activities as appropriate. Certain of the Activities – specifically, the purchase and/or use of cannabis – may also violate federal and/or other law. You acknowledge that (i) interacting with the Platform, providing your information to Aeropay, allowing Aeropay to collect information about you, and/or permitting Aeropay to send you communications could demonstrate or suggest to law enforcement, employers, friends, family members, and/or others that you are engaged in one or more of the Activities, which could have unwanted social, legal, employment, economic, or other impacts that could negatively and significantly affect you, including, but not limited to, your loss of employment, and (ii) Aeropay shall not be held liable for damages arising out of or connected with the foregoing because your use of the Platform is solely at your own risk.

Note that in order to function properly – and in some cases, in order to meet regulatory requirements – the Platform requires the collection, use, and/or sharing of at least certain information provided by you; so, Aeropay’s services may not be available for your use if you opt out of sharing your information under this Policy. 

Information Collected Automatically: Information collected automatically includes any information that does not reveal your specific identity or directly relate to an identifiable individual, also known as de-identified data. This information will not be used in a way that can re-identify you or be connected to personal information. We may use cookies and other technologies to recognize you as you use or return to the Platform so that we can understand how the Platform is used to personalize and enhance your experience. These technologies collect certain information automatically, such as information about your device, which is used to ensure the Platform functions properly, and information about your use of the Platform, which is used to understand Platform usage and to improve the Platform. We may collect your device’s location through GPS, WiFi, satellite, or cell-phone tower signals. We may use your device’s physical location to provide you with location-based services and content. You may be able to control such collection and/or use through your device settings.

 

Information Collected from Third Parties: We may combine the information we receive automatically and that you provide with information we receive about you from other sources, such as (by way of example only) public databases, joint-marketing partners, providers of demographic information, social-media platforms, people with whom you are connected on social-media platforms, and other third parties. This information may negatively affect, restrict, or prevent you from using the Platform. If you do not want Aeropay to use or have access to third-party information, please review your privacy settings with other third parties to disable the sharing of information with us.  

Note that in order to function properly –  and in some cases, in order to meet regulatory requirements – the Platform requires the collection, use, and/or sharing of at least certain information provided by third parties, so Aeropay’s services may not be available for your use if you opt out of third parties sharing your information under this Policy. 

Information on our Collection of Cookies: We use cookies, or similar technologies like single-pixel gifs and web beacons, to record and log data on our website. A cookie is a text file that is placed on your local storage by a Web page server. Cookies are useful to personalize your online experience. We use both session-based and persistent cookies. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. They are unique and allow us to do site analytics and customization, among other similar things. If you access our website through your browser, you can manage your cookie settings.

Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit and manage your browser options to block them in the future. The “Help” portion of the toolbar on most browsers will tell you how to disable and manage your cookies settings. If you disable cookies you may still browse public areas of the website, but some features and services may not function.

 

How We Use Data

How We May Use Information You Provide: We may use the information you provide to, among other purposes, (i) enhance the Platform’s functionality; (ii) respond to your inquiries and fulfill your requests; (iii) provide you with customer service; (iv) send administrative information to you; and (v) share information with third parties whose products or services you request or as required by law (for example, as required by a subpoena, government agency inquiry or investigation, or court order). Our third-party providers supply or may supply services including, but not limited to, payment-processing, data analysis, security, account verification, fraud prevention, customer screening, IRS TIN screening, OFAC watchlist screenings, state and federal license screening (if applicable), corporate formation verification, information technology and related infrastructure provisioning, customer service, user experience, e-mail marketing and solicitations, e-mail delivery, text-message marketing and solicitations, text-message delivery, and auditing. For example, we use Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using Aeropay’s Platform, you grant us, Plaid, and anyone acting for or on our behalf the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal). We may also provide your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

How We May Use De-Identified Data: We may combine the information you provide with information we receive about you from other sources. We may also use the information you provide for certain business purposes, including, but not limited to, data analysis; audits; fraud-monitoring and prevention; developing new products; enhancing, improving, or modifying our products and services; marketing; identifying usage trends; determining the effectiveness of our promotional campaigns; and operating and expanding our business activities.


Use of Artificial Intelligence and Third Party Machine Learning; Right to Opt Out:

Subject to applicable law, we use artificial intelligence and third-party automated machine learning software (collectively, “ML”) to assess whether each transaction performed on the Aeropay Platform is likely to be  successfully processed based on certain data points, like, for example, whether the amount of money in the bank account attached to the transaction is sufficient to cover the costs of the transaction. This helps Aeropay prevent fraud and other inappropriate use of the Aeropay Platform and may negatively affect, restrict, or prevent a user from using the Platform to process a transaction. Applicable data-privacy laws may afford you the right to opt out of having your data  used for purposes of ML. If you believe that applicable law provides such a right and you wish to exercise that right, please email us your request to support@aeropay.com.

Note that the Platform requires the use of at least certain artificial intelligence and/or automated decision-making software in order to function properly – and in some cases, in order to meet regulatory requirements – so Aeropay’s services may not be available for your use if you opt out of such artificial intelligence or automate decision-making under this Policy.

 

When We Share Data: Subject to applicable laws, we may use, disclose, and share the information you provide for, among other purposes, to (a) respond to requests from (i) public and government authorities, including courts and authorities outside your country of residence and (ii) law enforcement, if requested or mandated; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property; and (e) allow us to pursue available remedies or limit the damages that we may sustain.

We may aggregate the information that you and other Platform users provide. If we do, we may use and disclose such aggregated information for any purpose. All aggregated information is de-identified or pseudonymized.

If we are required to treat this information as “personal information” or “personally identifiable information” as defined under any applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy

 

The Platform is not intended for users outside of the United States. You agree to not use the Platform if you reside in a country other than the United States. 

Identify Verification: Many jurisdictions require careful verification of identity before allowing you to purchase services and products in certain industries. When you use Aeropay at a physical location, your government-issued identification card may be physically examined and electronically scanned in order to verify your identity, age, and/or your identification’s validity. Once your data has been scanned, your name, address, identification number, photo, and other data may be retained by Aeropay for the purposes outlined in this Policy.  


Supplemental Privacy Notice for California Residents

This Supplemental Privacy Notice supplements the information in this Privacy Policy, and applies solely to California residents. It applies to “Personal Data” we collect as a business or data controller; it does not apply to Personal Data we collect or otherwise process as a service provider or data processor.

Aeropay as a “Business” and a “Service Provider”: California law makes a distinction between organizations that process Personal Data for their own purposes (known as "businesses") and organizations that process Personal Data on behalf of other organizations (known as "service providers"). Depending on the circumstances, Aeropay may act as either a business or service provider with respect to your Personal Data. 

For example, if you visit our site and contact us through an online web form, Aeropay will be a “business” with respect to the Personal Data that you provide about yourself. We will also be a “business” as to the Personal Data that we have obtained from you as a customer/user of our services. We use this information to provide you with, among other items, requested services and marketing materials, as well as all of the items set forth above. If you have a question or a complaint about how your Personal Data is handled, please contact us at support@aeropay.com.

Summary of Information We Collect: If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

We or our service providers may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):

  • our or our service provider’s operational purposes;
  • auditing consumer interactions on our site (e.g., measuring ad impressions);
  • detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
  • bug detection and error reporting;
  • customizing content that we or our service providers display on the Platform (e.g., contextual ads);
  • providing the Services (e.g., account servicing and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics, communication about the Services);
  • improving our existing Services and developing new services (e.g., by conducting consumer research to develop new products or features);
  • other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third-party partners; and
  • other uses about which we notify you, if and as required by applicable law.

We may also use the above categories of Personal Data for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

Rights: If you are a California resident, you may have certain rights. California law may permit you to request that we:

  • provide you the categories of Personal Data we have collected or disclosed about you in the last twelve (12) months; the categories of sources of such information; the business or commercial purpose for collecting or selling your Personal Data; and the categories of third parties with whom we shared Personal Data;
  • provide access to and/or a copy of certain information we hold about you; and/or
  • delete certain information we have about you.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Platform or our Services.

If you would like to exercise any of your California consumer rights, please submit a request to support@aeropay.com. You will be required to verify your identity and residency before we fulfill your request. To do so, you will need to provide us with certain account information, such as the full name and e-mail address you used to create your account and your account user id. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization for the agent to act on your behalf. You will still need to verify your identity directly with us.

The CCPA sets forth certain obligations for businesses that “sell” Personal Data. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity. We do disclose certain information as set forth in this Privacy Policy and allow third parties to collect certain information about your activity, for example through cookies, except as explained in our “Information on our Collection of Cookies” section of this Privacy Policy.

Your California Privacy Rights under the “Shine the Light Law”: California residents who have an established business relationship with Aeropay may submit a written inquiry to Aeropay about whether Aeropay has disclosed any Personal Information to any third parties for the third-parties’ direct marketing purposes during the prior calendar year. To make such a request, please send an email, call, or write us using the following methods:

Email:  support@aeropay.com  

Toll Free: 1 (855) 888-0025

Supplemental Notice to Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, e-mail address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not believe that we engage in such activity; however, if you are a Nevada resident who has used our Platform, you may submit a request to opt out of any potential future sales under Nevada law by e-mail to support@aeropay.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Third Parties: Our website includes links to other websites whose privacy practices may differ from ours. If you submit information to any of those sites, your information is governed by their privacy policies. We are not responsible for the use of that information by others or the privacy statements or other content on third party websites.

 

Security

Aeropay utilizes a third-party bank verification provider to link your preferred financial institution (e.g., your bank) to your Aeropay account. Additionally, Aeropay employs the latest third-party technical controls, such as encryption, to protect data while it resides on Aeropay’s system, and to further ensure the protection of consumer anonymity. We have built privacy protection into our technology, business processes, and operational procedures. All new users must go through 2-factor SMS verification to confirm that they are indeed the individual creating an account.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we use commercially reasonable efforts to protect your information, we cannot guarantee the security of your information transmitted to or through the Platform. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform. 

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at: support@aeropay.com.


Privacy Rights

Choices and Access: If you would like to review, correct, update, suppress, or delete  information that you have provided to us through the Platform, you may contact us at: support@aeropay.com. We will endeavor to comply with your request(s), as required by applicable law, as soon as reasonably commercially practicable. We may need to retain certain information pursuant to applicable law, for record-keeping purposes, and/or to complete any transactions that you began prior to requesting a change, deletion, etc. There may also be residual information that will remain within our databases and other records, which cannot and/or will not be removed.

Use of Services by Minors and Others: The Platform may not be accessed or used by anyone under the age of  18; anyone seeking to participate in one of the Activities who is under the minimum age set by applicable law to participate in that activity in the relevant jurisdiction; and/or anyone seeking to participate in one of the Activities in a jurisdiction where that activity is not permitted.

Jurisdiction: The Platform is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. In the event of a dispute of Aeropay’s Privacy Policy, the laws of the State of Illinois will apply, excluding the conflicts of law principles thereof. Any dispute coming or arising out of this Privacy Policy shall be brought and maintained exclusively in state court in Chicago, Cook County, Illinois.

Cross-Border Transfer: The information we collect through the Platform may be stored and processed in any country where we engage service providers, and by using the Platform, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.


Changes to Privacy Policy

We may revise this Privacy Policy from time to time and without notice. Any changes will become effective when we post the revised Privacy Policy on the Platform. Your use of the Platform following these changes means that you have reviewed and accepted the revised Privacy Policy.

Contact Us: If you have any questions about this Privacy Policy, please contact us at support@aeropay.com.