Overview

What Is Covered in this Privacy Policy?

This Privacy Policy contains information regarding how Air2Web, Inc. and its subsidiaries (collectively “we”, “our”, “us”, “Air2Web”) processes certain categories of data relating to individual persons.

• If you are a visitor to our website, www.air2web.com (“Website”), please see the section “Website Privacy” below for a description of our data processing practices with respect to data about you.

• If you are an end user of Air2Web’s services (including services provided to Air2Web’s clients such as mobile telephone companies and providers of mobile content or services; “Clients”), please see the section “Service End User Privacy” below for information on our data processing practices with respect to data about you.

• If you are a resident of any European Union Member State (“EU”), please also see the section “EU Safe Harbor Privacy Statement” below for a description of our data processing practices with respect to data about you in reference to the European Union Safe Harbor Principles.

This Privacy Policy does not apply to the practices of companies that Air2Web does not own or control, or to people that Air2Web does not employ or manage. This includes any companies from whom you may have ordered services or products that are transmitted over Air2Web’s mobile messaging network and any companies from whom you may be purchasing telecommunications services.

We urge you to read this Privacy Policy so that you will understand both our commitment to you and your privacy, and how you can participate in that commitment. Air2Web reserves the right to amend this policy at anytime without notice. The revised Privacy Policy will take effect on the date posted on the Air2Web Website. Please check this page for occasional updates to remain appraised of Air2Web’s Privacy Policy.

How Can You Contact Us?

If you have questions or concerns regarding this Privacy Policy or otherwise regarding data collection, processing or transmission, please email us at This e-mail address is being protected from spambots. You need JavaScript enabled to view it or write to us via postal mail at Privacy Matters, c/o Air2Web, Inc., 1230 Peachtree Street, N.E., Suite 1200, Atlanta, GA 30309, United States. We will endeavor to respond timely to your inquiry.

Additionally, you may send an email to This e-mail address is being protected from spambots. You need JavaScript enabled to view it to be removed from any email, standard mail or other contact list. Please specify from which list you wish to be removed when sending the email.

Website Privacy

What Is Covered by This Section?

This section describes how we collect, use and disseminate information collected about Website visitors through our Website. It does not cover any other data processing activities.

Your Use of the Air2Web’s Website Implies Consent.

Your use of the Website signifies your acceptance of this Privacy Policy. If you do not agree or are not comfortable with any policy described in this Privacy Policy, your remedy is to discontinue your use of the Website.

If You Don’t Volunteer Any Personal Data, We Won’t Collect Any Through the Website.

We use cookies and various traffic tracking technologies to monitor the use of our Website. We collect such data related to IP addresses but do not link it to any personally identifiable information (such as names and email addresses) that you may voluntarily submit to us through other means (except as described below, in “Agents and Service Providers”). You always have the option not to provide information including by choosing not to enter information in any web form, purchase a particular product or use a particular service or feature.

Agents and Service Providers.

We may engage data processing agents and service providers that assist us in the processing of personally identifiable information that Website visitors may volunteer through the Website, as well as electronic messages and traffic data that is linked to IP addresses. Such third parties process data only on our behalf and are contractually obligated to refrain from using such data for their own purposes. Each time visitors visit our Website after they have submitted a web form to us or clicked on a particular link in a marketing email from us, we maintain a record of certain information about their visit including the pages viewed on our Website, the time of the visit, the order of pages accessed and the amount of time such visitors spend at each page. We use this information to better tailor our services to our visitors.

Use of Cookies.

When you access the Website, our web server may send a cookie to your computer. A cookie is a small text file containing information that a web browser transfers to your computer’s hard drive for record-keeping purposes. The Website may use session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows us to process your online data and requests. Session cookies help us make sure you are who you say you are after you have logged in. We may also use persistent cookies, which only we can read and use, to identify the fact that you are an Air2Web customer or prior Website visitor. Additionally the Website, we may also use cookies to analyze our site traffic patterns, but, except as described above, we link cookies only to IP addresses and not any personally identifiable information about Website visitors (such as names or email addresses). For example, we currently use third party service providers (e.g., Google Analytics) to analyze traffic to the Website. Other than as mentioned above, the software used by us does not have a database of individual profiles for each visitor connected to personally identifiable information. This third party software uses cookies to track non-personally identifiable information, and links cookies only to IP addresses and aggregate data about the traffic to the Website.

Most web browsers automatically accept cookies. Please consult your browser’s manual or online help if you want information on restricting or disabling the browser’s handling of cookies. If you disable cookies, you can still view the Website, but some features may not be available and you may not be able to take advantage of offers or activities regarding online registration, which may include online sales.

Volunteered Information Collected on the Website.

We may collect various types of personally identifiable information including name, address, telephone number, credit card number or other billing information, e-mail address, and other information that, either alone or in combination with other kinds of information, may personally identify you. Air2Web may collect personally identifiable information from you in a variety of ways, including through online forms for ordering products and services, and other instances where you are invited to volunteer such information. Air2Web may also collect information about how you use our Website, for example, by tracking the number of unique views received by the pages of the Website or the domains from which you originate. We may use “cookies” to track how your use our Website. While not all of the information that we collect from you is personally identifiable, it may be associated with personally identifiable information that you provide to us through our Website.

Air2Web may use personally identifiable information collected through the Website to contact you regarding products and services offered by Air2Web and its trusted affiliates, independent contractors and business partners, and otherwise to enhance users’ experience with Air2Web. Air2Web may also use information collected through the Website for research regarding the effectiveness of the Website and our marketing, advertising and sales efforts. Because Air2Web is a global company, we may share your information with other Air2Web affiliates, business units or contractors in other parts of the world, who will maintain the privacy of your information in accordance with this Privacy Policy. In addition, Air2Web uses information for the following general purposes:

• to fulfill your requests for products or services

• to improve our services

• to contact you

• to inform you of promotions, new products and/or services

• for reporting purposes for external Clients such as mobile telephone companies and providers of mobile content or services

• in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims

We limit access to your personally identifiable information to employees and contractors who we believe need access in order to provide services to you or to do their jobs. You should know that your personally identifiable information may be transferred from your home country to employees and contractors in other areas of the world, who may communicate with you regarding your inquiry.

We take appropriate technical and organizational measures to guard against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. While no computer system is completely secure, we believe the measures implemented by our Website reduce the likelihood of security problems to a level appropriate to the type of data involved.

Disclosure to Third Parties.

In the course of our normal business activities, we do not share personally identifiable data about Website visitors with any independent third parties, other than with our agents, service providers and authorized resellers as described in the preceding paragraphs “Agents and Service Providers” and “Volunteered Information Collected on the Website”. In particular, we are not in the business of selling, renting or loaning personally identifiable information to independent third parties.

Nevertheless, we may have to disclose information to third parties when required by law or under the good-faith belief that such disclosure is necessary in order to conform to applicable law, comply with legal process served on us, or to protect the property or interests, its agents and employees, or the personal safety of others, or the public. Under such circumstances, we may be prohibited by law, court order or other legal process from providing notice of the disclosure, and we reserve the right to not provide such notice in its sole discretion.

We may disclose aggregate, anonymous data based on information collected from Website users to investors and potential partners. Additionally, we may transfer personally identifiable and other information collected from Website users in connection with a merger, acquisition, or any form of sale of some or all of Air2Web’s assets or business at which time such information may become subject to the privacy policies of the acquiring entity.

Links to Other Sites.

The Website may contain links to other sites. We are not responsible for the privacy practices of any sites other than our own. We encourage you to be aware of when you leave the Website and to read the terms of use and privacy statements of each and every website that collects personally identifiable information.

This section on “Website Privacy” applies only to information collected by us on the Website. We may use service providers to collect certain information about those users who register for our webinars including the user’s name, title, company name, physical address, email address, phone number, web address, job title, company size, and job function. Our service providers then provide us this information so that we may follow-up to provide our services to such users.

Service End User Privacy

What Is Covered by This Section?

This section provides information on how we use and disseminates information collected about end users of our Air2Web services (including services provided to Air2Web’s Clients). It does not cover any other data processing activities.

Air2Web is a data processor which processes mobile data on behalf of its Clients who are the data controllers. Clients contract with Air2Web to provide mobile data delivery and application services by which such mobile data is transmitted between and on behalf of Clients and end users via Air2Web’s and mobile telephone carriers’ mobile networks. The term data controller is defined in US Safe Harbor and EU privacy legislation as the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data. The data controller retains full responsibility for the data with regards to the individual(s) concerned. The term data processor means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.

All legislation referred to herein requires that the relationship between a data controller and a data processor be covered by a contract before outsourcing related to the processing of personal data takes place. The purpose of the contract is to protect the interests of the data controller, i.e. the person or body who determines the purposes and means of processing and who retains full responsibility for the data with regards to the individuals concerned. The contract thus specifies the processing to be carried out and any measures necessary to ensure that the data are kept secure.

Air2Web obligations. 

Air2Web’s obligations may vary according to the jurisdiction of our Client and their area of business. The typical obligations to ensure compliance with the most common privacy legislation are: to comply with the U.S. Safe Harbor principles, EU data protection legislation or other similar national legislation as a data processor; to ensure that the data is only used for the purpose of providing our mobile data delivery and application services and purposes that are authorized and requested by our Client; to keep the data confidential.

Client obligations. 

To ensure that we process personal data in accordance with relevant privacy regulations we will only offer our service under a contract which defines the obligations of Air2Web and our Client according to applicable privacy legislation. We will always require our Clients to comply with relevant privacy legislation as the data controller. Air2Web does not control the sharing of personal information related to our service. This is governed by our Client, the data controller, in accordance with the respective Client’s privacy policy and applicable privacy legislation.

Air2Web may transfer personal data when legally required to do so. 

Air2Web will not transfer personal data to other entities without authorization or request from our Client unless Air2Web is legally required to do so, for example, by a court order or subpoena.

Who should end users contact regarding privacy?

If you are an end user of our service you should contact our Client for any information related to information held about you and the privacy policy which governs the relationship between you and our Client. In some cases our Client will be your employer, your mobile telecommunications carrier, or an entity from which you purchase or request products or services.

Access by Air2Web employees. 

Access to private and confidential data on our systems is limited to only those employees and contractors with a specific need to retrieve this information. Air2Web uses commercially reasonable computer security safeguards to protect its databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data. These risks, however, cannot be completely eliminated and Air2Web therefore cannot guarantee complete security of any information you transmit to us, and this information is transmitted at your own risk.

EU Safe Harbor Privacy Statement

Air2Web adheres to the US Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Access, Security, Data Integrity and Enforcement, and is registered with the U.S. Department of Commerce’s Safe Harbor Program. Our Safe Harbor certification can be found at https://www.export.gov/safehrbr/list.aspx

For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s website at http://export.gov/safeharbor/.

This policy was last updated February 17, 2010.