Privacy Policy
Aptaero respects and protects the privacy of the users of our Cloud-based platform, products and services (the “Service”). This Privacy Policy (“Policy”) explains how we collect and use customers private information, including any biometric information in connection with its services related to mobile apps and on-line services for security screening based on personal information, facial recognition and other biometric data submitted in connection with such services . If You have questions or complaints regarding our Policy or practices, please contact us at privacy@aptaero.com. Your only remedy, if You do not accept the terms of this Policy, is to discontinue use of the Site and Service.
Customer Information
In this Policy, “Personal Information” means a data or an information set that identifies or could be used by or on behalf of Aptaero in the performance of its services to identify an individual. Personal information includes your name, mailing address, phone number, email address, contact preferences, occupation, and may include biometric data which is typically a photo, facial scan, fingerprint scan or other such biometric data used in connection with a security scan. Facial scans and other biometric data stored on behalf of our customer are stored for a period of two (2) years. This time period is selected by our customer, a regional airport for the purpose of complying with applicable TSA and FAA record keeping requirements. The customer does not store or retain the biometric data. Aptaero is the data processor and its customer controls the length of time the data is to be retained in its files with Aptaero.
The information Aptaero collects and uses is limited to the purposes for which customers engage Aptaero. Aptaero does not disclose this Personal Information to third parties, with the exception of the following: a. Information that must be transmitted to and via other parties, as determined by our customers in order for our customers to provide receive the airport security screening services they have contracted for. For example, and not in limitation, facial scans will be submitted to GEMS to confirm whether the user is authorized. c. If Identification information is required by the law of countries or security screening in the airport, for access to gates or to screen passengers or luggage submitted for screening by the customer, this data is transmitted in accordance with those requirements. d. If data is sent through third party middleware systems in order to produce security clearance such as gate passes or passes into airport premises or to produce travel documentation, in electronic or printed form.
Log Files
As is true with most web sites, Aptaero gathers certain information automatically and stores it in log files. This information includes internet protocol addresses as well as browser, internet service provider, referring/exit pages, operating system, date/time stamp, and click stream data. We use this information with no connection to individual users, to administer the platform and audit usage.
Information Sharing
Although Aptaero owns all rights to the software, code, databases, and other Service applications, our customers retain all rights to their specific Personal Information, including all biometric data submitted. The customer is responsible for obtaining permission to use and retain the Personal Information, including biometric data from the data subjects. We only send information to third parties as part of processing of the services. We will never sell or trade data for the purposes of marketing. Aptaero will not give, sell, rent or loan, or otherwise provide access to any Personal Information to any third party except as necessary to provide the services. We may disclose such information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected terrorism, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by the legal jurisdiction in which our customer operates. Aptaero may also provide non-personal, summary or group statistics about our customers, sales, traffic patterns, and related Site information to our customers but these statistics will include no Personal Information. Aptaero only shares and uses such information in conformance with applicable data privacy laws.
Protection of Information
Aptaero is committed to ensuring the security of your Personal Information. We take every precaution to protect the confidentiality and security of the Personal Information placed on the Site or used within the Service, by employing technological, physical and administrative security safeguards, such as firewalls and carefully-developed security procedures.
Generally
We frequently enter agreements with our EU customers to provide them our Service, which includes the processing of information relating to our customers’ customers. In providing our Service, we do not own, control or direct the use of the information stored or processed on our platform at the direction of our customers, and in fact we are largely unaware of what information is actually being stored on our platform and only access such information as authorized by our customers or as required by law. Only You or your customers are entitled to access, retrieve and direct the use of such information. As such, We are only the “data processors” and not the “data controllers” of the information on our platform for purposes of the EU Directive on Data Protection (Directive 95/45/EC) and the Swiss Federal Act on Data Protection. Our EU or Swiss customers, who control their customer data and send it to Aptaero for processing, are the “controllers” of that data and are responsible for compliance with the Directive. As the processors of Personal Information on behalf of our European customers, we follow their instructions with respect to the information they control. In doing so we implement appropriate technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to Personal Information. Your only remedy, if You do not accept the terms of this Policy, is to discontinue use of the Site and Service.
Notice
Aptaero has no direct relationship with our customers’ customers whose Personal Information we process. Aptaero’s customers are responsible for complying with the Directive and relevant data protection in the jurisdiction where our customer operates, before sending Personal Information to Aptaero for processing.
Choice
We process and store information on behalf of our customers. If You are a customer of one of our customers and would no longer like to be contacted by one of our customers that uses our Service, please contact that customer directly.
Onwards Transfer
We may transfer Personal Information to our third-party vendors that help us provide the Service, subject to appropriate confidentiality restrictions. Such transfers are limited to the purposes for which Personal Information has been transferred to us from our customers. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice, and the service agreements with our customers. Otherwise we may also share Personal Information as is required or permitted by law.
Access and Review of Data
Aptaero is committed to taking reasonable steps to ensure that any Personal Information requests to be forgotten or for amendment or deletion of data that can be implemented with our existing technology will be done so within a reasonable time of the request, in accordance with applicable law of the jurisdiction where You are based, including, without limitation, residents of the EU and Switzerland. If You are our customer and would like to gain access to, or request deletion of information We have collected as “data controllers” please contact us at privacy@aptaero.com.. We will respond to such queries within 30 business days. Aptaero has no direct relationship with its customers’ customers whose Personal Information it processes. An individual seeking access, or who would like to correct, amend, or delete inaccurate data should direct his query to the Aptaero customer with whom such individual interacts (the data controller). At the request of our customers, We generally remove data within 30 business days. With respect to the Personal Data of our customers, Aptaero, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to the Privacy Shield. Under certain conditions you may invoke binding arbitration before the Privacy Shield Panel. Notwithstanding any language to the contrary in this Privacy Policy, in cases of onward transfer to third parties of Personal Information of individuals received pursuant to the EU-US Privacy Shield, Aptaero, Inc. is potentially liable.
Data Retention
Aptaero will retain Personal Information We process on behalf of our customers for as long as needed to provide Service to our customers, subject to our compliance with this Policy. We retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Aptaero continuously monitors its privacy practices and continued compliance with applicable laws and regulations and this Policy.
Business Transactions
Aptaero may assign or transfer this Policy, and your user account and related information and data, to any person or entity that acquires or is merged with Aptaero.
Changes to this Privacy Policy
As a technology company, our systems and the legal environment will mature and change as will this Data Privacy Policy. Changes to this Data Privacy Policy with the most recent revision date will be posted at www.aptaero.com. You are responsible for checking for the latest version on our website.
Questions
Aptaero is committed to responding to reasonable requests to review any of your Personal Information we may have and to amend, correct, or delete any inaccuracies, and to explain any questions you may have about this Privacy Policy. To have your information amended, corrected, or deleted, or if you have any questions that weren’t answered in this Data Privacy Policy, you can contact us at Aptaero Inc., 300 N Martingale Rd Suite 250, Schaumburg, IL 60173 or email us at privacy@aptaero.com.