Privacy Notice for Beta Users of the Sample Web Portal and Access Points

Effective Date: December 2024

Airties (Airties SAS, a French corporation having its registered corporate address at 7 Rue Vignon, 75008, Paris France, registration number 913 315 693 RCS Paris, its affiliated companies, hereinafter also “we” and/or “us” and/or “Airties“) recognizes the importance of your privacy. As a data controller, we carry out our activities in line with the applicable data protection regulation, including the EU General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and other related laws, including the privacy regulations of Texas, Delaware, California and New York states.

This Privacy Notice aims to specify how we collect, process and disclose your personal data.

1. What data do we collect?

Airties collects and processes your personal data mentioned below:

• Identity information, including your name, surname,
• Contact information, including your e-mail address, phone number, address,
• The company you work for and your position,
• Device model, serial number, MAC address, LAN/WAN IP, SSID, station name, device name, Wi-Fi statistics (RSSI, RX, TX values, device and frequency capacities), connected devices (wired and wireless), DHCP options, DHCP host names, device description fields, MDNS host name, device Wi-Fi capabilities, vendor information, HTTP User agent header, SSDP message content, user friendly name and application name type and session statitstics of application connecting to the internet

Airties does not process any sensitive personal data. Only Wi-Fi statistics are processed, and no data on the websites visited or the browser content are processed.

2. Purposes of processing

Airties processes personal data for the following purposes:

• Collecting and archiving of Wi-Fi performance metrics and configuration data from Airties and Airties licensed devices,
• Analysis of collected and real-time Wi-Fi metrics data for Wi-Fi issue diagnostics and performance optimizations,
• Maintenance and technical support,
• Device identification,
• Personalized Wi-Fi,
• Security.

3. How do we collect your personal data?

Airties collects data and processes data when you:

• register to Airties Customer Portal.
• complete a form or survey or provide feedback on Airties devices or communicate through phone or email.
• use the physical samples.

4. What are the legal grounds?

Airties collects and processes your personal data on the following legal grounds, which are stated in Article 6(1) of the GDPR and the UK GDPR:

• We request consent to the processing of your personal data and for the international transfer.
• Processing is necessary for the performance of a contract, including our terms and conditions.
• Processing is necessary for the compliance with a legal obligation to which we are subject.
• Processing is necessary for the purposes of our legitimate interests pursued by the controller, provided always that such interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.

5. Disclosure of Your Personal Data

The data collected by Airties may be transferred to other Airties entities and/or Airties suppliers, hosting and cloud service providers, and legally authorized persons for the purposes mentioned above.

• For instance, employees of Airties subsidiaries and affiliates located outside the EEA may provide the necessary support and participate in analysis activities in order to resolve technical problems experienced by users during the use of the device.

• For instance, users’ personal data collected while using Airties devices may be transferred to cloud service providers in order to analyze Wi-Fi and device performance in synchronization with Airties systems.

• For instance, in order to send Airties devices to your address and deliver them to you, your personal data may be disclosed to our cargo service providers.

In the event of any data transfer to a country outside of the European Economic Area or somewhere that has no recognized adequacy decision, including the United States, Airties systematically ensures the application of an adequate level of protection of such data in accordance with applicable data protection legislation.

6. Your Rights

If you are in the European Economic Area or United Kingdom or in certain countries, you are also entitled (with some exceptions and restrictions) to:

• Access: You have the right to request information about how we process your personal data and to obtain a copy of that personal data.
• Rectification: You have the right to request the rectification of inaccurate personal data about you and for any incomplete personal information about you to be completed.
• Objection: You have the right to object to the processing of your personal data, which is based on our legitimate interests (as described above).
• Deletion: You have the right to request us to delete your personal data.
• Automated decision-making: You have the right to object to a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
• Restriction: You have the right to ask us to restrict our processing of your personal data so that we no longer process that personal data until the restriction is lifted.
• Portability: You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and to have that personal data transmitted to another organization in certain circumstances.
• Complaint: You have a right to lodge a complaint with the authorized data protection authority if you have concerns about how we process your personal data. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

You may, at any time, exercise any of the above rights by contacting us via privacy@airties.com using a valid e-mail address, which can allow us to confirm your identity.

7. Right to Withdraw Consent

If you have provided your consent to the processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact us via privacy@airties.com.

Once Airties has received notification that you have withdrawn your consent and you have stopped using Airties services , Airties will no longer process your information where applicable for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

8. Security of Your Personal Data

In order to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect.

9. Retention of Your Personal Data

We will only retain your personal data for as long as necessary to fulfil our collection purposes.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Upon the expiry of the applicable retention period, we will securely delete, destroy or anonymize your personal data in accordance with applicable laws and regulations.

10. Retention of Your Personal Data

We reserve the right to update and change this Notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. We will inform you of any changes to our Notice via your email address or through our platforms.

11. Contact Us

If you have any questions in relation to this Privacy Notice, please get in touch with us via privacy@airties.com.