Status and acceptance of privacy policy

1. Hello and welcome! ANO RRC “Airalab Rus” provides it’s services through it’s website located at airalab.org as well as by community-supported websites aira.life and robonomics.network, along with related features, content, applications, application protocol interface (“API”), and products (collectively the “Services” or “Airalab”).
2. This Privacy Policy (hereinafter referred to as the “Policy”) sets forth the general rules of User’s Personal Data collection, processing, distribution, use and keeping by Airalab.
3. Throughout this Policy, Airalab will use the term “Personal Data” to describe information that can be associated with a specific person (the User) and can be used to identify that person (including the information about the User’s activities, such as information about Your use of the Website, when directly linked to personally identifiable information, including automatically collected).
4. Other terms that may be used throughout this Policy include:
   1. Website - group of interrelated websites owned and operated by Airalab and which can be accessed on the Internet via the following addresses: robonomics.network and aira.life;
   2. Airalab Token - digital cryptographic token designed to represent an internal operational instrument on the Airalab/Robonomics platforms;
   3. User (or “You”) - person that has accessed the Website.
5. It is presumed that by the fact of the Website use or purchase of Airalab Tokens or by providing Airalab the Personal Data directly on its request, the User has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should withhold from using the Website and/or purchase of Airalab Tokens.

Collection, processing and use of personal data

5. Airalab collects Personal Data from running the Website and uses Personal Data, provided to Airalab by You. When the User visits the Website, Airalab collects the Personal Data sent to Airalab by Your computer, mobile phone, or other access device. This Personal Data includes:
   1. Your mobile network information;
   2. Your IP address;
   3. Information about the device that User uses to access the Website. Such information includes, but is not limited to, identifier, name, and type, operating system;
   4. Web log information, such as Your browser type, and the pages You accessed on Airalab Website.
   When the User uses a location-enabled device with Airalab Website and products, Airalab may collect geographical location data or use various means to determine the location, such as sensor data from the User’s device that may, for instance, provide data on nearby cell towers and Wi-Fi access spots. However, Airalab will not release Your personally identifying information of such kind to any third party without Your explicit opt-in consent, except as set forth herein.
6. If the User wants to purchase Airalab Tokens, Airalab will collect and store the following types of Personal Data about You:
   1. Your name;
   2. Your email.
7. Airalab may require You to provide additional information, and namely:
   1. Your address;
   2. Date of birth;
   3. Passport or driver license details;
   4. Numbers that You may use or have registered with Your local tax authority;
   5. Utility bills;
   6. Confirmation of proceeds sources.
8. Airalab reserves the right to request basic Personal Data, described in clauses 6 and 7, prior to the purchase of Airalab Tokens and/or use of any services, available through the Website. Airalab may refuse the User access to the Website in case if Airalab has grounded doubts as to the validity, authenticity and genuineness of the Personal Data, provided by the User.
9. If the User does not provide Airalab with the Personal Data as specified in clauses 6 and 7. hereof, the User shall not be able to use the full functionality of the Website and purchase Airalab Tokens. At that, Airalab shall not bear any liability for such possible incomplete use.
10. When the User accesses the Website or uses Airalab products or services Airalab (or a service provider on our behalf) may place small data files called “cookies” on the User’s computer or other device. Airalab uses these technologies to recognize You as our User, customize Airalab Website, measure promotional effectiveness and collect information about Your computer (as described in clause 5 hereof) or other access device to mitigate risk, help prevent fraud, and promote trust and safety. You may control the use of cookies within Your internet browsers’ settings. If you reject or delete certain cookies, be aware that the performance of the related features and functions of our Website and services may be impaired.
11. Airalab collects from the Users only the Personal Data that Airalab needs for their proper use of the Website or for purchase of Airalab Tokens. In particular, Airalab uses the User’s Personal Data to:
    1. Fulfill legal or regulatory requirements;
    2. Administer Airalab Website;
    3. Personalize Airalab Website for You;
    4. Send You technical notices, support and administrative messages;
    5. Communicate with You about the news and information Airalab may think will be of interest to You;
    6. Monitor and analyze trends, usage and activities in connection with Airalab Website;
    7. Provide third parties with statistical information about Airalab Users (but those third parties will not be able to identify any individual User from that information);
    8. Detect, investigate and prevent illegal activities within the Website, as well as protect the rights and property of the Airalab and others;
    9. Verify compliance with the Terms of Service governing the use of Airalab Website.
12. Airalab is the only data controller and processor, except for the cases when there is an objective Airalab needs to control/process or store Personal Data at Airalab’s counterparties or agents. Should such counterparty or agent be engaged by the Airalab, Airalab shall notify You in advance.
13. You may access, review and edit Your Personal Data at any time by communicating Airalab in writing.
14. The User has the right to require Airalab to delete User’s Personal Data provided by the User to Airalab or revoke his (or her) consent for collection, processing and storage of his (or her) personal data by Airalab at any time. If You decide to do this, You should send the respective notification to the Airalab. Airalab shall delete Your respective Personal Data from any sources within 24 hours from the moment Airalab receive such request from You. At that, the Airalab reserves its right to suspend provision of any services to You referring to Airalab project without prior notice, not providing any compensations to You.
15. Airalab will not publish any Personal Data related to Your purchase of Airalab Tokens without Your prior written consent.

Personal data protection and sharing

16. Airalab will do any and all efforts and actions to store any of Your personal data in secrecy.
17. Airalab will not share Your Personal Data with any third parties other than Airalab respective identity verification partners. Airalab reserves it’s right to share Your Personal Data with:
    1. Airalab banking and brokerage partners, if necessary;
    2. Companies that Airalab plans to merge with or be acquired by (should such a combination occur, Airalab will notify You and will require that the newly combined entity follow these terms with respect to Your Personal Data);
    3. Third party identification service providers for fraud prevention purposes;
    4. Law enforcement, government officials, or other third parties when Airalab are compelled to do so by a subpoena, court order, or similar legal procedure; or Airalab believes in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of Airalab policies;
    5. Airalab Personal Data processing counterparties or agents, hired by or cooperating with us, who’s services are required by us from the practical point of view;
    6. Other third parties only with Your prior consent or direction to do so.
18. Airalab will not provide Your Personal Data to any other Website users or third parties other than described in clause 17 herein without Your consent or direction.
19. Airalab will not sell or rent Your Personal Data to third parties.
20. Airalab may combine Your Personal Data with information Airalab collects from other companies and use it to improve and personalize the Website, as well as our content and advertising.
21. Airalab may use Your email address to provide You with information about the state of the project’s development, as well as other information that may be of interest to You, only after Your explicit opt-in consent.
22. Airalab services may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the Website is advertised). If You follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that Airalab does not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before You submit any personal data to these websites or use these services.

Retain information

23. In accordance with the law and as needed to provide services to Airalab Users, Airalab may hold Your Personal Data. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. Airalab may retain Your Personal Data for as long as You possess Airalab Tokens and/or use the Website. Moreover, Your Personal Data may be hold beyond the above mentioned period till it is indispensable for Airalab to have relevant information to respond to any issues that may arise later. According to the clause 14 of this Policy, You have the right to require Airalab to delete any of Your Personal Data or revoke Your consent to Your Personal Data collection and processing.

Security

24. Airalab uses relevant electronic and procedural safeguards to protect the privacy of the information the User provides to Airalab from loss, misuse, disclosure, alteration and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that Airalab are not liable for the security of any data Users are transmitting over the Internet, or third party content.
25. If Data breach of any kind that may be related to the User’s Personal Data will occur, Airalab will notify You via email within 72 hours of the first having become aware of this breach.
26. You have a right to demand Airalab to provide You access to Your Personal Data and to require the correction, updating or deletion of incorrect or/and inaccurate data by contacting Airalab.

Amendments

27. Airalab reserves the right to modify or amend this Policy at its own discretion. If such modifications or amendments will occur, Airalab shall notify You via email. Your continued usage of the Website shall mean Your acceptance of these modification or amendments.