Legal - Privacy Policy

Revision Date October 7, 2014

This Privacy Policy sets out how Aeris Communications, Inc. and its affiliates (“we”, “us” or “our”) collect, use and protect information. We want the person or legal entity (“you” or “your”) visiting or using http://www.aeris.com, https://aerport.aeris.com, our online store at http://neo.aeris.com or other ecommerce site or any related Aeris site (the “Aeris Sites”) and/or using any of our products or services to understand what information we collect from you or your devices and how we use that information. By visiting any Aeris Sites and/or using any of our products or services, you are accepting the practices described in this Privacy Policy.

What information do we collect or process, and why? We collect and process different types of data and information for different purposes:

Contact information. If you express an interest in our products and services, we may collect personal information that you provide to us, such as your name and job title, company, contact information including email address, demographic information such as postcode, preferences and interests, and other information relevant to providing you with information about us and our products and services. We use this information principally to respond to your inquiries but also to send you information about new products or services, special offers or other information that we think you may find interesting or to contact you for customer service or market research purposes.
Registration, payment and device information. In addition to the information described above, if you sign up for our products or services, we may ask you to provide additional information for setting up and maintaining your account. This may include personally identifiable information such as address, phone numbers and payment information, and other information relevant to the products or services you receive from us, including information about your devices and applications that will use our services. We use this information principally to provide products and services to you.
Log data. We also log and store certain types of information (for convenience called “log data”) whenever you or your devices interact with us through the Aeris Sites or use our services. Information collected during your visits to the Aeris Sites can include your login information, IP address, information you search for or pages you visit, choices that you make (such as accepting terms of use or other legal agreements and actions you take on our customer portal relating to your account or your devices), and time and length of access. Information collected while providing service to you and your devices can include device IDs, time stamps, authentication records, location information, carrier service used, signal strength, the origin, destination, type and quantity of traffic passed and other operational data. We use the log data from your visits to the Aeris Sites to verify that you meet the criteria for access to certain pages and services, to comply with any requests or instructions that you give, to monitor and analyze usage information concerning our site so that we can improve how we respond to your requests and improve your interactions with the Aeris Sites and to communicate with you. We use the data collected from the use of our services by you and your devices to provide services to you, diagnose problems with your devices or our services and provide customer support, maintain and improve our network operations, help prevent fraud and otherwise to operate our business. See “Analytics and Data Aggregation” below for additional information about uses of your data.

What is our policy regarding cookies?

Cookies. Like many web sites, we use different kinds of “cookies” to collect information about your visits to the Aeris Sites. We use “persistent” cookies, small files stored on your hard drive, to remember your login information and your preferences to make your future visits to the Aeris Sites more productive. We also use “session-based” cookies that collect certain types of information, such as IP address and browser type, and statistical information such as pages visited and length of time spent on pages, to help us analyze data about webpage traffic and to improve the Aeris Sites. We remove the data from our systems when we no longer need it. It is removed from your system when you have logged out of your account and closed your browser. You can adjust how your browser handles cookies, although blocking cookies may interfere with your use of some features of the Aeris Sites.

What do we do with the information we gather? In addition to uses described above, we use this information for the following reasons:

Marketing. We use contact and registration information and log data about your visits to Aeris Sites for several purposes, including customizing your interaction with the Aeris Sites according to your customer status and your interests. We may periodically send promotional emails about new products, special offers or other information that we think you may find interesting using the email address that you have provided. From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.

Operating, maintaining and improving our products and services. We use all of the information we collect to operate our business, provide products and services to you and our other customers and to maintain and improve our products and services.

Analytics and Data Aggregation. We analyze all log data as described above to understand how our services are operating, how to maintain and improve them, and to determine if there is information about patterns, correlations and trends that may be useful to us or to our customers or partners. If we aggregate information and move that information outside of your secure account environment or our secure servers, we do so in a form that is intended not to permit personally identifiable information to be viewed or extracted (called, for convenience, “de-identified information”). In addition to our internal use, we may share results of our analysis or aggregated data containing de-identified information with third parties who use it for such purposes as industry analysis and demographic profiling. We may also sell products or services that incorporate or are based on results of our analysis or this aggregated information that has been de-identified.

Law Enforcement. We may disclose any of your information to government officials as necessary to comply with applicable laws and orders. If we receive a request to disclose any such information, we may do so if we believe in our reasonable discretion that such request is lawful and required and is reasonably necessary to comply with a court order, to protect our property rights or rights of a third party, to protect the safety of any person or of the public or to prevent any activity that we believe is harmful, illegal or unethical.

How secure is your personally-identifiable information, and where is it stored?

Security. We use industry-standard measures to safeguard the personally identifiable information you give to us, but you need to follow prudent measures to protect against unauthorized access to your account information, including logging out of your account when finished, not sharing your login information and taking other customary security precautions appropriate for the situation. We may use different security measures depending on the type of information and whether it consists of personally identifiable information. By collecting or storing any of your information, we do not undertake to be bound by any additional information security measures that may apply to you or your information under other laws, including, without limitation, the Health Insurance Portability and Accountability Act (HIPAA) or regulations pertaining to payment card data (other than payment card information we collect from you for processing your payments to us) unless we have agreed in a separate services agreement to do so. If we become aware that there has been a breach in security of any of the information that we store or that is stored by our third party service providers, we will promptly notify you as required by law and consistent with our need to determine the scope of the breach and to safeguard our systems.

Data Storage. We keep the information you give us or that is sent to our systems through your use of our services on our own systems in the United States or other jurisdictions where we maintain data centers or on the systems of our third party service providers as described below. If you are located outside the United States, you consent to the transfer of all such information here. We may establish a capability for our customers to direct that their information be stored outside of the United States; when we offer this, we will update this Privacy Policy or our agreements with our customers. If you would like us to delete any of your personally identifiable information, please contact us at privacy@aeris.net, and we will use reasonable efforts to delete it from our databases, although we may retain an archived copy to comply with law or for our legitimate business purposes.

Phishing. We are aware that there are people who may pose as legitimate businesses and try to trick you into disclosing personal information that can be used to steal your identity. We will not request your account login or password, your credit card information or any national identifying numbers in an unsolicited or non-secure email or telephone call. If you believe that someone representing themselves as being associated with Aeris has requested this information in a contact that you did not request or initiate, please contact us immediately at security@aeris.net so that we may verify the identity of the person contacting you and the validity of the request.

Who has access to your personally-identifiable information?

What access do you have? If you have established an account with us, you can always access your account and review the information you have provided, including name, address, email address, phone number, payment information and other relevant account information. You can update this information directly or contact us for assistance. If you delete some or all of this information, then you may be prevented from accessing your account or using any services. Data relating to your device activity and to actions you have taken regarding those devices that can be viewed by customers may be accessed at our customer portal. If your customer relationship with us terminates, we may archive your information for a period in accordance with our record management procedures and then delete it.

What access does Aeris staff have? We allow access to those of our employees and consultants who have a need to access your information in order to provide products or services to you or to improve or maintain our products, services and facilities.

What access do other third parties have? We may store your information with or allow access to your information to third parties who provide us with certain services, including website maintenance services, database services, customer services or other services. Our contracts with these third party providers only allow use of your information to provide these services and require that they not disclose it. We review the security policies and practices of our third party service providers as appropriate as part of our own efforts to maintain the security of your information. In addition, if you participate in any promotional programs, such as by entering a vendor code when you purchase products or services, we may share information about your purchases and your usage with that vendor.

Do we participate in the Safe Harbor Program? We are actively reviewing the steps necessary to permit us to participate in the Safe Harbor program developed by the U.S. Department of Commerce and the European Union.

Links to other websites. The Aeris Sites may contain links to websites operated by third parties that we believe may be of interest. If you use these links, you will leave our site, and you should note that we do not have any control over that other website and cannot be responsible for the protection and privacy of any information that you provide while visiting such sites. Providing a link to third party websites does not mean that we endorse or warrant the products or services provided by any third parties and this Privacy Policy does not govern such sites. You should exercise caution and look at the privacy policy applicable to the website in question.

Additional terms. The following terms apply to this Privacy Policy:

Concerns and Disputes. If you have any concerns about our privacy practices, please contact us at privacy@aeris.net, describe your concern, and we will try to resolve the issues. You agree that any dispute with us over privacy will be governed by this Privacy Policy and, unless we have mutually agreed otherwise in another binding contract, will be governed by the internal laws of the State of California, U.S.A. and subject to the exclusive jurisdiction and venue of the state and federal courts in Santa Clara County, California. You agree that the United Nations Convention of Contracts for the International Sale of Goods does not apply to this Privacy Policy.

Modification. We may modify this Privacy Policy at any time by posting an amended version on the Web Portal or at our home page at http://www.aeris.com. You should check from time to time to see if we have updated this Privacy Policy. We will not materially change our privacy policies and practices to make them less protective of your information without posting a conspicuous notice in advance on the Web Portal or at our home page at http://www.aeris.com.