Privacy Policy

At AireSpring, we are committed to honoring the privacy of your personal information.  We recognize the importance to you of maintaining an appropriate level of privacy and security for the personal information we receive from you or about you in the course of running AireSpring’s business.  This Privacy Policy is designed to inform you of AireSpring’s policies regarding any of your personal information received or used by AireSpring and your rights regarding your personal information.  All references to “AireSpring” throughout this Privacy Policy include, unless otherwise stated, all AireSpring affiliate companies, successors and assigns.  For purposes of compliance with the European Union (“EU”) General Data Protection Regulation (“GDPR”), with respect to your personal information AireSpring is both the “controller” (determines the purposes and means of processing your personal information) and the “processor” (the company that processes your personal information on behalf of AireSpring or AireSpring’s customer).

What Kinds of Information Does AireSpring Receive, Collect and/or Use?

Visiting AireSpring’s Web Site – Except as otherwise provided in this policy or in other written documentation or policies that may be provided to you regarding the services or the AireSpring web site, the only personally identifiable information that we collect about visitors to our web site is that which is provided to us voluntarily by you. “Personally identifiable information,” also referred to as “personal information,” is information that tells us specifically who you are, such as your name, street address, email address, cell phone number, landline telephone number, billing address, social security number, credit card number, other service account information, and certain other financial information.  In general, you can visit our web site without telling us who you are or revealing any personally identifiable information about yourself.  

AireSpring’s web servers may use “cookies” to collect information about visitors such as your domain name, host from which you access the Internet, the IP address of your computer, and your browser software and operating system.  This information may be aggregated to measure such things as the number of visits, average time spent on the site, number of pages viewed, and methods by which our site was found.  AireSpring may use such information to evaluate the use of our site and to continuously improve the content and services being provided

Online engagement – When you use our online services by accessing your account information, ordering a service or making a payment on-line, requesting a product or service information, or sending us e-mail, we may ask you to provide personally identifiable information to us.  Except as otherwise provided in this policy, when you supply information about yourself for such specific purposes, we use the information for that purpose and to manage the internal operations and security of our web site consistent with the terms of use and policies established from time to time governing this site.  Such purpose may involve the disclosure of such information to unaffiliated companies or vendors where necessary to and for the limited purpose of processing your request, processing a transaction authorized by you or providing you with products or services.  Furthermore, we may use, disclose or transfer certain personally identifiable information or other information about you (i) to provide you enhanced services; (ii) to market to you services or products among the categories of services or products you currently subscribe; (iii) to obtain a credit report; (iv) to protect the confidentiality or security of your records; (v) to comply with law enforcement, government mandate or other legal requirement if appropriate for your protection or in connection with an investigation or prosecution of possible unlawful activity; (vi) to our attorneys, accountants, and regulators; (vii) in connection with a sale, acquisition or merger of AireSpring or our assets or (viii) for other legally permissible purposes. We may also share aggregate anonymized data relating to the transactions on the site and use of our services for marketing, research and other purposes.

For the convenience of our visitors and customers, the AireSpring web site may contain links to other sites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies before disclosing information to third parties on these independent sites.

Webinars – AireSpring hosts occasional webinars. If you register for an AireSpring webinar, AireSpring may gather your name, title, contact information, and business name.  AireSpring does not share this information with outside companies or individuals.   

Feedback – At times we may ask you for contact information or conduct on-line surveys in order to better understand your needs in order to provide you with a customized experience. If we wish to use this information other than as set forth in this policy, we will let you know at the time of collection. We will take commercially reasonable steps to safeguard this information from unauthorized access. However, any aggregate data that you send to us such as your questions, suggestions, ideas or other creative material (“Feedback”) belongs to us and will not be treated as confidential. We may use, reproduce, adapt, distribute, display, disclose or create derivative works from Feedback without acknowledgement or compensation to you and without identification of you, except in circumstances where explicit approval has been previously received.

Information Received in the Course of Providing Services – In the process of providing telecommunications services, AireSpring automatically records call detail records, namely record records that indicate the start and stop times of a call the number from which a telephone call originated, the telephone number of the called person or entity, and information concerning how the call was routed.  Also in connection with some of AireSpring’s services, AireSpring receives and or assigns Internet protocol (“IP”) addresses, types of equipment ordered or used, and configurations of such equipment.  In the course of ordering AireSpring’s services, you may provide contracts or documents to AireSpring that contain personal information such as a Service Order form, credit application, technical specification, or letter of authorization.

AireSpring monitors the equipment on its network, including any customer premises managed services equipment supplied by AireSpring. AireSpring performs such monitoring for the purposes of error detection, traffic flow, delay, lag time, jitter, latency, speed, and network capacity.  AireSpring does not believe such information is capable of being used to identify any particular individual.

Information Received from Third Parties – AireSpring may receive certain information about you from third parties such as credit information from outside agencies, information from social media websites or platforms when interacting with an AireSpring posting or website, and marketing or lead information from third party agents, employment placement services, channel partners, or marketing lead companies.  AireSpring receives business cards and contact information from potential customers or vendors in the course of its business operations, including appearances at trade shows.  When a customer applies for AireSpring’s services, AireSpring may check credit or due diligence information from an outside credit agency or business evaluation agency.  AireSpring may obtain information about a customer by checking customer–supplied business references and/or invoices from a prior provider.

Employment Information Received – Personal information AireSpring receives can also include information you provide to AireSpring in a job application/Curriculum Vitae (“CV”)/resume or an employment-related document such as an IRS W-4 form.  

By voluntarily providing AireSpring with your personal information, you are consenting to AireSpring’s use of it in accordance with this Privacy Policy and all applicable laws.

Use of Received Information

Summary of Information Usage – Your information received by AireSpring is used to i) determine credit worthiness, ii) set up a customer account, iii) provision service and/or equipment, iv) maintain service, v) provide technical support, vi) manage and protect AireSpring’s service and equipment, vi) detect and prevent fraud or abuse, v) authenticate authorized contacts for a customer, vi) suggest new products or services, vii) suggest updates to existing equipment or services, viii) develop new products or services, ix) respond to lawful subpoenas and/or Investigative Demands from government agencies, x) verify your identity, as deemed necessary, when you contact AireSpring, xi) assist in establishing a connection to emergency services, xii) assist credit and collection agencies in collecting past due amounts, xiii) assist outside auditors and regulators as needed, xiv) protect you or others from fraud or other illegal activities, xv)  comply with the law, xvi) use in connection with a merger, acquisition, or sale, xvii) allow a third party payroll service to issue paychecks and withhold taxes, xviii) allow third party accountants to audit or prepare financial reports, xix) allow third party auditors to perform their audits; xx) notify you in an emergency situation, or xxi) upon your request.  In the case of an individual applying for work at AireSpring, information on an employment application may be used to conduct a background check and/or credit check. 

No Sale of Personal Information.  AireSpring does not sell your personal information.  AireSpring does not supply or use your personal information in connection with third-party marketing/advertising or in connection with AireSpring’s marketing or advertising.  Except as set forth in this Privacy Policy or unless we specifically disclose it to you at the time of collection or subsequently obtain your approval, we will not make any personally identifiable information that is gathered on our site available to unaffiliated organizations for commercial purposes unrelated to the business of AireSpring.

Provisioning and Troubleshooting Service Issues.  As needed, AireSpring may provide needed information to third parties in support of provisioning or troubleshooting services. 

Use of Aggregated Information.  Aggregate information may be provided to AireSpring’s outside accountants and auditors. Aggregate information is used for AireSpring’s network planning. Also, aggregate information may be supplied in response to United States Census Bureau requests, United States Department of Labor Requests, or other governmental agencies that request statistical information from AireSpring.  Aggregate information excludes information that could be used to identify any particular individual.

In Response to Lawful Government Demands.  Certain federal, state and local laws or government regulations may require us to disclose personally identifiable information about you. In these circumstances, we will use reasonable efforts to disclose only the information required by law, subpoena or court order to be disclosed.

Customer Proprietary Network Information (“CPNI”) – Certain information related to your telecommunications services account with AireSpring such as to whom, where and when you make calls is considered Customer Proprietary Network Information (“CPNI”).  CPNI is protected by specific federal laws and regulations and as such we are fully committed to comply with such laws and regulations, both through our web site and in all other respects. Without your consent, we will only share or disclose your CPNI (i) to market to you services or products among the categories of services or products you currently subscribe, (ii) to initiate, render, bill and collect fees for our telecommunications services, (ii) to protect you or other carriers from illegal or fraudulent use of, or subscription to, our services or to protect our rights or property, (iii) to provide your call location information in certain specified emergency situations, (iv) to comply with industry traceback requests, including those from USTelecom, to help identify the source of illegal robocalls or other unlawful calls, (v) to comply with rural call completion investigations in compliance with Federal Communication Commission (“FCC”) guidance and rules, (vi) to comply with subpoenas and civil investigative demands, (vii) to troubleshoot issues with your service, and (viii) for other legally permissible purposes.

Email – AireSpring’s policy is not to read or disclose private e-mail communications that are transmitted using AireSpring services except to respond, if directed to us, or as required to operate the service, as set forth in the terms of use and policies established from time to time governing the service, or for other legally permissible purposes.

Transfer of Information Outside of the EU – AireSpring may transfer your information to countries outside the EU using appropriate safeguards when necessary.   In such instances, we will obtain your consent before using your data for these purposes, as required by applicable law.

Security and Protection of Personally Identifying Information

Security – AireSpring maintains physical, electronic and procedural safeguards designed to protect the confidentiality of personally identifiable information provided by you on and through our web site. For example, unique passwords or user identifications are required to access a number of our web site services. In addition to requiring the use of a unique password or user identification, all payments processed through our web site require certain personally identifiable information provided by you to be sent in a “Secure Session” using Secure Socket Layer encryption technology.  This technology is designed to encrypt – or scramble – your financial or credit card account information to help prevent unauthorized parties from reading it.  We seek to regularly test and update our technology to help protect your personally identifiable information. However, such precautions do not guarantee that our web site is invulnerable to all security breaches.  AireSpring makes no warranty, guarantee, or representation that use of our web site is protected from all viruses, security threats or other vulnerabilities or that your information will always be secure. When doing business with others, such as advertisers to whom you can link from our site, you should consider the separate security and privacy policies of those other sites.

Your Use of Passwords or User Identification.  Except as specifically permitted by this privacy policy or other instructions regarding the online services you may not, and will ensure that you do not, lend, give, or otherwise disclose any passwords or user identifications to any unauthorized person, or permit any unauthorized person to use your accounts or related passwords or user identifications.  Any loss of control of passwords or user identifications may result in the loss of control over personally identifiable information.  You will be responsible for any actions taken on your behalf or any person using your passwords or user identifications.  If passwords or user identifications have been compromised for any reason, then you should immediately change such password or user identification or notify us so that we may issue a new password or user identification.

Children’s Privacy.  AireSpring does not intend for AireSpring’s web site to be used by children under the age of 13, nor does AireSpring seek to collect information about children under the age of 13. If you are under the age of 13, please do not provide us with information and promptly exit this site. We encourage parents or legal guardians to talk with their children about the potential risks of providing information over the Internet.

Reviewing and Modifying Your Personally Identifying Information

Updating Your Personally Identifying Information Online.  Your use of certain of AireSpring’s online services may permit you to update personally identifiable information from our database by accessing our web site.  If you remove certain information from your account, we will only retain copies of such information as are necessary for us to comply with governmental orders, resolve disputes, troubleshoot problems, enforce any agreement you have entered into with us, and as otherwise reasonably necessary.  In accessing AireSpring’s web portal, you will be required to enter a unique password, which is to be kept private at all times.

Other Methods to Update Your Account Details.  You may also update your AireSpring account information by contacting Customer Service  at the AireSpring telephone number or email address provided below in this Privacy Policy.  The Customer Service Department will authenticate you before any changes to your customer account information are made.  

Qualified Consumer Report Request.  If you are a “Qualified Consumer”, defined as i) a resident of any state in the Unites States that provides for applicable enhanced rights pertaining to your personal identifying information, or ii) a natural person who is a citizen or resident of a European Union (“EU”) Member State or the United Kingdom, you may request AireSpring provide you with a report concerting your personal information (“Report”).  A business is not a Qualified Consumer.  Based on what you request, the Report may include among other information a) the categories of your personal information (“Consumer Personal Information” or “CPI”) AireSpring collected, b) the categories of sources from which the CPI was collected, c) the business purpose for collecting the CPI, d) the categories of third parties with whom AireSpring shares CPI, and e) the specific pieces of CPI AireSpring collected from you.  Upon AireSpring’s verification that you are a Qualified Consumer, AireSpring shall respond to your request.   You may not request a Report more than twice in a twelve (12) month period.   AireSpring shall conform its response, as reasonable and/or necessary, to applicable law.

Qualified Consumer Deletion Request.  If you are a Qualified Consumer, you may request AireSpring delete your personal information provided by you to AireSpring.  There are several reasons for which AireSpring may not be required to delete your personal information, including if AireSpring uses your personal information i) in support of completing or performing a transaction for goods or services, ii) internally, in a lawful manner that is compatible with the context in which you supplied the information, iii) to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with AireSpring, iv) to detect any security incidents, or protect against fraudulent, deceptive or illegal activity, v) for debugging to detect and repair errors that impair existing intended functionality, vi) pursuant to a response to a government-issued warrant, order, or  other legal process,  or to comply with any legal obligation, or vii) for the exercise of free speech, or ensure the right of another consumer is allowed to exercise his/her right to free speech, or exercise another right provided for by law.  If the above exceptions do not apply and upon AireSpring’s verification you are a Qualified Consumer, AireSpring shall delete as applicable your personal information from AireSpring records and direct any service providers to delete your personal information from their records.

Qualified Consumer Correction Request. A Qualified Consumer has the option to request access to the personal information we have about them. If you are a Qualified Consumer, you may request that AireSpring correct inaccurate personal information AireSpring has for you.

Qualified Consumer Request to Limit Use and Disclosure of Certain Information. If you are a Qualified Consumer, you may request that AireSpring limit use and disclosure of sensitive personal information (SPI), as defined below, to certain uses including: i) that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services and for ii) short term transient use.

SPI Definition. “SPI” is personal information that reveals sensitive personal information such as: i) a consumer’s social security, driver’s license, state identification card, passport number or citizenship data; ii) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; iii) a consumer’s precise geolocation; iv) a consumer‘s racial or ethnic origin, religious or philosophical beliefs, union membership or biometric data; v) the contents of a consumer’s mail, email and text messages, unless the business is the intended recipient of the communication and, vi) a consumer’s genetic data, religious belief and sexual orientation. 

Additional Qualified Consumer Requests Under the GDPR.  If you are a Qualified Consumer from the EU or the United Kingdom you also have a right to request access to, erasure of, and rectification of your personal information.  You also have the right to request restrictions on the processing of your personal information in certain cases such as inaccurate personal information, unlawful processing of your personal information, or no further need of AireSpring for your personal information.  At any time you have the right to withdraw your consent to any use of your personal information to which you previously consented.  You have the right to request your personal information to be transferred to a third party.  Please be aware that i) under certain circumstances the GDPR may limit your exercise of these rights and ii) without the use of your personal information, AireSpring may not be able to provide you the services or the same quality of services you request.

No Discrimination.  AireSpring shall not discriminate against you for exercising your legal rights as a Qualified Consumer with respect to service or price, except if the difference is reasonably related to the value provided by your data.  AireSpring may charge for administrative costs if AireSpring determines a Qualified Consumer’s request(s) are  unfounded or excessive, or alternately in such situations AireSpring may refuse such unfounded or excessive request(s) and notify the Qualified Consumer.

Changes to AireSpring’s Privacy Policy

AireSpring’s Privacy Policy is posted on the AireSpring website at www.airespring.com. There shall be an “Effective Date” set forth on the Privacy Policy. The Effective Date is the date the Privacy Policy goes into effect. The latest Privacy Policy will always be posted on the AireSpring website.  We may, from time to time, change this Privacy Policy with or without notice.  

Submitting Requests, Questions, Comments, and Complaints

AireSpring welcomes any questions or comments you have regarding this Privacy Policy.  You may submit such questions or comments, or make other requests provided for in this Privacy Policy, by:

Reporting fraud or abuse.  If you believe you have been the victim of any abusive practice or service, such as but not limited to unlawful content, you may report such abuse via email to abuse@airespring.com.

Lodging a Complaint Under the GDPR.  If you are a Qualified Consumer from the EU and think your data protection rights have been breached, or you otherwise have a complaint with AireSpring’s privacy practices, you have the right to lodge a complaint with your national Data Protection Authority (“DPA”), which can be located through web site https://edpb.europa.eu/about-edpb/board/members_en.

Effective Date of this Privacy Policy

This Privacy Policy is effective as of January 1, 2023.

By accessing or using AireSpring’s web site, you acknowledge that you have read and accepted the practices, procedures and terms and conditions of this Privacy Policy and any other terms of use or policies posted by us.  Please note that this Privacy Policy applies to AireSpring only and not to the partners, vendors, agents or other companies or organizations to which the AireSpring web site links or references.