The security and proper use of Airlief users’ personal data are of utmost importance to us. We, therefore, take a number of procedural and technical measures to protect the personal data of users, while endeavoring to process as little personal data as possible, in accordance with the principle of data minimization as set out in the General Data Protection Regulation or ” GDPR “.
Basic principles for the processing of personal data
We process personal data in a lawful, conscientious and transparent manner;
We process personal data collected for specific, explicit, and legitimate purposes and are not processed further in a manner inconsistent with these purposes;
The processed personal data is appropriate, relevant and limited to what is necessary for relation to the purposes for which it is being processed (“data mining”);
The processed personal data may be kept up to date at any time by taking all reasonable measures to ensure the timely erasure or correction of inaccurate personal data, taking into account the purposes for which they are processed (“accuracy”).
In most cases, the data we process is not able to identify the subject. Airlief does not exchange information from other applications of the mobile phone of the user and Air Solutions Ltd does not aim at acquiring any personal data that could directly or indirectly identify the data subject. However, even in the rare cases in which the data provided by indirect identification could result in the data subject being identified, they are stored in a form that allows for a period no longer than is necessary for the purposes for which they are being processed personal data (“storage limitation”) and no further action is taken to link them to an entity;
The personal data processed by us are stored in a way that ensures an appropriate level of security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage by applying appropriate technical or organizational measures (“integrity and confidentiality” );
Personal Data Administrator
Personal data administrator is Air Solutions Ltd., with UIC 204693956, with headquarters and address of management in Sofia 1326, Vrabnitsa district, Obelya 2, bl. 236, ent. A, floor 2, ap. 3 (Air Solutions).
If you have questions about Air Security privacy or would like to contact us in connection with a privacy issue, you may contact us at firstname.lastname@example.org.
What personal data we process
We collect only personal data that could indirectly identify the data subject and, in very rare cases, those who could do so by the direct method. The same happens only after your prior consent.
Here are the types of information we collect:
The information you provide to us: We obtain the information you provide about your use of the Airlief application, such as an e-mail address and GPS location, information about your health. You may provide this information on a voluntary basis, and it is not up to us to provide our service, but it is necessary to personalize the application to make it more useful for you.
Automatic Information: We automatically receive certain types of information when using the Airlief application, such as information about your use, including your interaction with the content. Like many applications, in order to optimize and run the app itself, we get information about your device, the Internet protocol address (IP) used to connect your device to the Internet; content interaction information such as content downloads, streams, and playback details, including duration and downloads; Device metrics, such as when using a device, using the application, connectivity data, and any errors or unsuccessful events; Airlief application metrics (for example, technical errors, interactions with features and service content, setup preferences, and so on.
On what basis do we collect and process your personal data
We collect and process your personal data lawfully and in accordance with this Policy and the General Terms and Conditions. We only process data when you have explicitly agreed to the processing of personal data. The processing of certain types of data, such as automatic information above, is also necessary for the purposes of our legitimate interest, namely: when we can not provide our services without the processing of a particular type of data. Also, collecting information about using the app is our legitimate interest because it is a basic method for determining the quality of the service we provide.
We collect the location, e-mail, and health data you provide only when you have given your explicit consent.
Due to the above grounds for collecting and processing personal data, if you do not wish to provide the Airlief application with a location, e-mail, and health information, this will not restrict you from using the application. In this case, however, you will not be able to use its additional personalization features that allow you to get air quality data in your area, customized tips according to your completed questionnaire and the risk group, in which you are.
Purposes of processing of personal data
We process your personal data solely for the purpose of providing you with a service that is better informed about air quality, possible risks and protection measures that you can take. When providing you with health and location information, we process this data to inform you of the air quality in your area to provide personalized advice to you based on the responses to your completed questionnaire and to determine the risk group you are in. We also use your data for:
Provide, troubleshoot, and improve the Airlief application. We use data from your device to provide functionality, analyze performance, correct errors, and improve the usability and performance of the Airlief application.
To communicate with you. We use your personal information to communicate with you via email in connection with the services we provide. Only if you have given your consent, we send you project development information, a monthly newsletter, and we can contact you about the use of the app and issues concerning air quality. You can withdraw the same consent at any time via a link in each of our newsletters.
Goals for which we seek your consent. We may also request your consent to process your personal data for a specific purpose that we are reporting to you. When you agree to process your personal data for a particular purpose, you may withdraw your consent at any time and we will terminate the processing of your personal data for that purpose. If processing is necessary for another legitimate purpose, however, we can continue to process it.
Categories of persons to whom we disclose user privacy
Air Solutions may share the personal information of users of the Airlief application (or part of it) only as described below and with third parties who comply with practices that comply with the General Data Protection Regulation or also called “GDPR”.
Air Solutions may share personal information with application users with third parties who process personal data. Personal data processors are persons who process personal data in the name and assignment of Air Solutions on the basis of a written agreement. They may not process the personal data they have provided for purposes other than the performance of the work entrusted to them by Air Solutions. Processors are required to comply with all Air Solutions instructions.
Air Solutions takes the necessary measures to ensure that the engaged processors strictly adhere to the Airworthiness Personal Data Protection and Airworthiness legislation and that they have taken appropriate technical and organizational measures to protect personal data.
Examples of personal data processing are:
Providers of deployment and/or maintenance services for information systems that are sometimes required to access personal data processed in the relevant systems for the purpose of providing the services;
Providers of hosting and mail services;
Air Solutions uses, for the purpose of gathering information about the application’s need, Google Analytics, Google Play Services, Firebase. Thus, the information provided by the mobile device to the user can also be provided to Google analytics, who may not process it for their own purposes.
What methods we use to protect your personal information
We work hard to protect the security of your information. We maintain physical, electronic and procedural guarantees in relation to the collection, storage, and disclosure of your personal data.
Devices on which your personal data is stored offer security features to protect them from unauthorized access and loss of data.
Please note that in order to minimize the data we process to use our application, there is no need to fill out a registration form.
How long do we store your personal data?
Upon the expiration of the deadlines for the processing of personal data, they are anonymized or deleted/destroyed unless:
• necessary for a pending court, arbitration, administrative or enforcement proceedings, or upon appeal by the relevant consumer, to be considered by Air Solutions; or
Air Solutions strives to ensure that processed user data for users is updated (and corrected if necessary) and that no data is not stored that is not necessary to achieve the objectives described above.
General information on the rights of individuals
Air Solutions takes action at the request of an individual to exercise the right under this section only if he is able to identify the person concerned.
Only persons who can be identified by Air Solutions have the ability to exercise their rights under this section. If the purposes for which Air Solutions processes personal data do not require or no longer require the identification of an individual, Air Solutions shall not be obliged to maintain, acquire or process additional information to identify the person for the sole purpose of taking action on the basis of at the request of that person.
Air Software shall notify individuals of the action taken within one month of receiving a request under this section, and in certain cases, this period may be extended by up to two months.
Air Solutions shall provide natural persons with information on the action taken in relation to their claims for the exercise of rights under this Section without undue delay and in any case within one month of receipt of the request. If necessary, this period may be extended by a further two months, taking into account the complexity and the number of requests. Air Solutions shall inform the person concerned of any such extension within one month of receipt of the request, indicating the reasons for the delay.
Upon refusal to execute a request, Air Solutions shall notify the individuals concerned of their rights.
If Air Solutions fails to act upon the request of an individual, it shall notify it without delay and at the latest within one month of receipt of the request for reasons not to act and of the possibility of filing a complaint to the Commission personal data and seeking legal protection.
In some cases, Air Solutions may request additional information to verify the identity of individuals
In the event that Air Solutions has reasonable concerns about the identity of the individual submitting a claim under this section, Air Solutions may request the provision of additional information necessary to verify the identity of the individual.
The actions taken by Air Solutions in relation to and in connection with claims for exercising rights under this section are entirely free of charge to individuals unless their claims are manifestly unfounded or excessive. Where a person’s request is manifestly unfounded or excessive (for example because of its repeatability), Air Solutions may, in its sole discretion: (a) refuse to execute the request; or (b) require the payment of a reasonable fee, determined on the basis of the administrative costs necessary to provide the requested information or to take the requested action.
Users have the right to access personal data relating to them
Users are entitled to obtain from Air Solutions information on whether personal data relating to them is being processed. If so, users have the right to access the relevant data.
Correction of inaccurate or outdated personal data
In the event that personal data processed by Air Solutions is inaccurate or out of date, users are entitled to require Air Solutions to correct them.
Deleting My Personal Data (“Being forgotten”)
Users have the right to request from Air Solutions deletion of personal data related to them in the following cases:
• personal data are no longer needed for the purposes for which they were collected or processed;
• the consumer has withdrawn his / her consent on which the processing of personal data is based and no other legal basis for the processing of the data;
• the consumer has objected to the processing of personal data based on the legitimate interest of Air Solutions unless there are other legitimate grounds for the processing that take precedence over the interests, rights, and freedoms of the consumer or the processing of data is necessary for the establishment, exercise or protection of legal claims;
• the user has objected to the processing of personal data for the purposes of direct marketing and there are no other legitimate reasons for the processing of such data;
• the personal data relating to the user concerned have been tampered with;
• personal data must be erased by Air Solutions in order to comply with a legal obligation under the law of the Republic of Bulgaria or European Union law.
Restrict the processing of my personal data
As of 25.05.2018, users have the right to request Air Solutions to restrict the processing of personal data related to them in the following cases:
• the accuracy of personal data is disputed by the user for a period that allows Air Solutions to verify the accuracy of personal data;
• the processing is illegal, but the user does not want the personal data to be deleted but instead requires a limitation of their use;
• Air Solutions no longer requires personal data for the purposes of processing, but the user requires them to identify, exercise or protect legal claims;
• the user has objected to the processing of personal data based on Air Solutions’ legitimate interest, pending verification that the consumer’s legitimate grounds prevail over the interests of Air Solutions.
Portability of my personal data
As of May 25, 2018, users have the right to obtain from Air Solutions the personal data they provide in a structured, widely used and machine-readable format, as well as transfer these data to another administrator without hindering Air Solutions, in so far as:
• Air Solutions processes these data on the basis of user consent; and
• the processing of relevant data is done in an automated manner.
Users have the right to request Air Solutions to transfer their personal data directly to another administrator when it is technically feasible.
Opposition to the processing of personal data
Users are entitled, at any time and on grounds relating to their particular situation, to object to the processing of personal data relating to them when Air Solutions processes their data to protect their legitimate interests ([link to legitimate interest information ]).
In certain cases, this right is unconditional and Air Solutions will always discontinue the processing of data upon objection by users. These are the cases in which Air Solutions processes personal data for the purposes of direct marketing.
In other cases, depending on the nature of the objection and the circumstances exposed by the respective user, Air Solutions will conduct an internal review of the objection and will rule thereon in accordance with this section by: (a) informing the consumer that it will cease processing of his or her personal data; or (b) reasonably refuses to discontinue the processing of his / her personal data, provided there is a legal basis for doing so.
You have the right to access, correct, delete, restrict, limit, and restrict your access to your personal information by contacting us by e-mail: email@example.com
Right to appeal to a supervisor
Consumers have the right to file complaints or alerts with the Personal Data Protection Commission (CPDP) if they believe Air Solutions violates personal data protection law. Instructions for submitting complaints are posted on the CPDP web site https://www.cpdp.bg
After 25.05.2018, consumers may also submit complaints to other supervisory authorities within the European Union as provided for in Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data the processing of personal data and the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation) or also called “GDPR”.