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AirSuite Inc. Privacy Policy

Scope

This notice is effective as of April 22, 2025

AirSuite Inc. (“AirSuite”) owns and operates: airsuite.ca, air-suite.com, air-suite.ca, getcirro.com, getcirro.ca, cirro.app, and companynote.com (collectively referred to herein as “Website”). All references to “we”, “us”, this “website” or this “site” shall be construed to mean AirSuite and/or the Websites, as the context requires.

Our collection, use, and disclosure of your personal information is governed by Canada’s Personal Information Protection and Electronic Documents Act S.C. 2000, c. 5 (“PIPEDA”). Generally, organizations covered by PIPEDA must obtain an individual’s consent when they collect, use, or disclose that individual’s personal information. Personal information can only be used for the purposes for which it was collected. Personal information must be protected by appropriate safeguards, and people have the right to access their personal information held by an organization.

This Privacy Policy was developed in compliance with the provisions of PIPEDA and describes our policy regarding the collection, use, and disclosure of Personal Information (defined below).

BY USING THIS WEBSITE, ACCESSING ANY OF OUR SERVICES, OR OTHERWISE PROVIDING US PERSONAL INFORMATION AS DESCRIBED HEREIN, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACYPOLICY.

How we modify this policy

We reserve the right to modify this Privacy Policy at any time, and without prior notice, by posting an amended Privacy Policy that is always accessible by clicking on the “Privacy Policy” link on this Website’s home page. Your continued use of this Website indicates your acceptance of the amended Privacy Policy. You should check the Privacy Policy through this link periodically for modifications by clicking on the link provided near the top of the Privacy Policy for a listing of material modifications and their effective dates. Regarding Personal Information (defined below), if any modifications are materially less restrictive on our use or disclosure of the Personal Information previously disclosed by you, we will obtain your consent before implementing such revisions with respect to such information; provided, that your continued use of this Website after such modifications shall be deemed consent to the modifications.

Definitions

Whenever used in this Privacy Policy, the following words, and phrases, unless the context otherwise requires, shall have the following meanings:

  • “Express consent” means written authorization permitting AirSuite to collect, use, and disclose the individual’s personal information for the purposes set out in this Privacy Policy.
  • “Implied Consent” means AirSuite assumes that the individual consents to the information being used, retained, and disclosed for the original purposes, unless notified otherwise.
  • “Non-Personal Information” means any information that is not used to identify a specific individual, including without limitation, the URL of the previous website you visited, your computer’s operating system and Internet protocol (IP) address, internet domain and host name, your internet service provider, your clickstream data, and the dates and times that you may access this Website and specific pages.
  • “Personal Information” means any information about an identifiable individual, including; without limitation, information relating to identity, nationality, age, gender, address, telephone number, e-mail address, Social Insurance Number, date of birth, and information relating to online activity such as location data, screen names, and lists of contacts, as well as certain personal opinions or views of an Individual.
  • “Purpose” means the specific, legitimate reason(s) for which AirSuite collects, uses, distributes, and/or processes an individual’s Personal Information, as more particularly described in Section 2 of this Privacy Policy.
  • “Representative” means any of the AirSuite’s employees, agents, associates, directors, officers, volunteers, and/or committee members.
  • “Services” means any subscription-based service provided by AirSuite pursuant to the AirSuite Subscription Agreement.
  • “Third Party” means a person or company that provides services to AirSuite in support of the programs and other services it offers, including but not limited to any party which provides services, tools, or support, such as cloud hosting, payment processing, analytics, or outsourced development to assist AirSuite in the delivery of such programs and services.

All words importing the singular number only shall include the plural, and vice versa, and words importing the masculine gender shall include the feminine gender, and words importing persons shall include firms and corporations and vice versa.

All other words, and phrases, unless the context otherwise requires, shall have the meanings assigned to them under PIPEDA.

Principles of PIPEDA

This Privacy Policy is founded on the following ten “Fair information principles” of PIPEDA:

  1. Accountability: organizations are accountable for the Personal Information they collect, use, retain, and disclose in the course of their commercial activities, including, but not limited to, appointing an individual to be responsible for the organization’s compliance with PIPEDA;
  2. Identifying Purposes: organizations are to explain the purposes for which the information is being used at the time of collection, and Personal Information can only be used for those purposes;
  3. Consent: organizations must obtain express or implied consent when they collect, use, or disclose Personal Information and (subject to legal or contractual restrictions and reasonable notice) individuals can withdraw consent at any time;
  4. Limiting Collection: the collection of Personal Information must be limited to only the amount and type that is reasonably necessary for the identified purposes;
  5. Limiting Use, Disclosure, and Retention: Personal Information must be used for only the identified purposes, and must not be disclosed to third parties unless the individual consents to the alternative use or disclosure;
  6. Accuracy: organizations are required to keep Personal Information in active files accurate and up-to-date, taking into account its use and the interests of the individual;
  7. Safeguards: organizations are to use physical, organizational, and technological safeguards to protect Personal Information from unauthorized access or disclosure, in a way that is appropriate to the sensitivity of the information;
  8. Openness: organizations must inform their clients and train their employees about their privacy policies and procedures, and ensure such policies and procedures are accessible and easy to understand;
  9. Individual Access: an individual has a right to access his or her Personal Information held by an organization, and if necessary, to challenge the accuracy of such information; and
  10. Provide Recourse: organizations are to inform clients and employees of how to bring a request for access, or a complaint, to the Privacy Specialist, and must respond promptly to a request or complaint by the individual.

1. Accountability

AirSuite is committed to being accountable for the collection, use, and disclosure of Personal Information and has developed this Privacy Policy in accordance with PIPEDA to ensure specific guidelines exist to protect Personal Information. Personal Information held by AirSuite, including any Personal Information transferred to a Third Party, is appropriately protected by ensuring confidentiality measures are in place for any persons with access to Personal Information.

AirSuite has an appointed Privacy Specialist to ensure the organization’s compliance with this Privacy Policy:

Attn: Privacy Specialist
Email:[email protected]
AirSuite Inc.
Suite 106, 1205 Amber Drive
Thunder Bay, Ontario, P7B 6M4
Telephone:+1 (807) 577-7511

2. PURPOSE OF COLLECTING YOUR INFORMATION

If you are a customer of AirSuite’s, we collect, use, and disclose your Personal Information as part of your registration for an account or product, for customer support and communication, to send marketing and promotional materials, for our internal reporting and security assessments for our Website, for data analytics & usage monitoring, to meet legal, tax, or regulatory requirements, for the performance/delivery of the Services, and for any ancillary purposes thereto.

If you are an employee, volunteer, contractor, supplier, or other stakeholder of AirSuite, we collect, use, and disclose your Personal Information for purposes such as recruitment and hiring, to assess job applicants, verify qualifications, and conduct background checks; payroll and benefits administration; compliance with legal and regulatory requirements; workplace safety and security, including IT and network security, employee records, and human resources management, and other ancillary purposes thereto.

(collectively referred to herein as the “Purpose”).

The AirSuite Software as a Service (SaaS) Subscription Agreement also sets forth in more detail how we may use this information, as well as any other information collected from you.

3. Consent – How and When we Collect Information

Personal Information

We collect Personal Information at the time you provide it to us via our Website, or otherwise communicate it to us by phone, email, or other means of verbal or electronic communication. By providing Personal Information to us for the above-identified Purpose(s), AirSuite is given your Implied Consent to collect, use, and disclose your Personal Information as provided in this Privacy Policy. Implied Consent is also granted to permit AirSuite to report or otherwise disclose information to federal and provincial regulatory departments for programs and services administered by AirSuite.

Non-Personal Information

Non-Personal Information may be passively collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies and web beacons when you use our Website or Services.

We reserve the right to make full use of Non-Personal Information. For example, we may use Non-Personal Information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends about the use of this site, and otherwise administer and improve this site or our Services for your use.

We do NOT tie or link your Personal Information to Non-Personal Information with persistent identifiers. For example, we would not tie or link your email address (Personal Information) with information collected by a cookie regarding the length of time you visit our site (Non-Personal Information).

You can withdraw consent to AirSuite’s use of Personal Information at any time prior to registration for an account or product, or prior to subscribing for the Services by making such request in writing to the Privacy Specialist. Once an account or product is registered, or a subscription for the Services has commenced, you cannot withdraw consent to the use and disclosure of your Personal Information for the Purpose set out in this Privacy Policy.

Please note that there may be situations where we are required or permitted by law to retain and use your Personal Information despite your withdrawal.

4. Limiting Collection of Personal Information

Personal Information is collected by AirSuite only for the Purpose set out in this Privacy Policy. If or when a new purpose is identified for collecting your Personal Information, AirSuite will obtain your Express Consent for the new purpose(s). If AirSuite requests your Personal Information for any purpose other than that described herein, then we will explain the purpose for requesting your Personal Information before or at the time of collection.

5. Limiting Use, Disclosure, and Retention of Your Information

Limiting Use

Personal Information is only used for the purpose(s) described in the Privacy Policy, with the following exceptions as permitted under PIPEDA:

  1. The organization has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial, or foreign law, and the information is used for that investigation;
  2. An emergency exists that threatens an individual’s life, health, or security;
  3. The information is for statistical study or research;
  4. The information is publicly available;
  5. The use is clearly in the individual’s interest, and consent is not available in a timely way;
  6. Knowledge and consent would compromise the availability or accuracy of the information; and,
  7. Collection is required to investigate a breach of an agreement.

Limiting Disclosure

Personal information may be disclosed in the following ways:

  1. Disclosure to Service Providers for Website Operations. We may disclose your Personal Information to our trusted service providers that assist with AirSuite’s business; for example, we may use Third Parties to process payments or payroll, host our servers, provide security, and provide production, fulfillment, optimization, analytics, and reporting services.
  2. Disclosure to our Affiliates and Resellers. We may disclose your Personal Information to any of our (i) affiliates that referred you to our Website, and (ii) resellers that may re-sell our products or Services to you. Disclosures to affiliates will only be to the affiliate that referred you to our Website. Disclosures to resellers will be only to resellers that have already shared your information with us. Understand that the information you provide to these resellers is subject to their privacy policies.
  3. Disclosure When We Act as an Affiliate or Reseller for Others. We may act as an affiliate or reseller for certain of our marketing partners for purposes of selling their products or services to you, and we may disclose your Personal Information to them for purposes of transaction processing, fulfillment, and support. We and/or these marketing partners may also email or message you regarding complimentary products or services; provided, however, you have two ways to opt out of receiving these emails – (i) contact us (as provided below under the Contact Us heading), if you are subscribed to a paid AirSuite application, with a request to opt out (subscribers to any free AirSuite application may not opt out), or (ii) wait until you receive an email from the Third Party and then unsubscribe.
  4. Disclosure to Successors. If we are acquired by or merged with a Third-Party entity, or if we sell this Website, a line of business from this Website, and/or our AirSuite applications, we reserve the right to transfer your Personal Information and other information as part of such merger, acquisition, sale, or other change of control.
  5. Disclosure to Affiliated Entities and Representatives. We reserve the right to provide your Personal Information and other information to any Affiliated Entities we may have, including our subsidiaries, and our Representatives that need to know the Personal Information for carrying out the Services provided by AirSuite. In this paragraph “Affiliated Entities” means any entity that, directly or indirectly, through one or more intermediaries, controls or is controlled by or is under common control with AirSuite.

Without limiting the above, AirSuite may also disclose Personal Information without your knowledge and consent when it is permitted by PIPEDA, which includes disclosure:

  1. to a lawyer representing AirSuite;
  2. to collect a debt owed to AirSuite;
  3. to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction;
  4. to a law enforcement agency in the process of a civil or criminal investigation;
  5. to a government agency or department requesting the information; or,
  6. as required by law.

We will take commercially reasonable efforts to cause Third Parties to agree to hold your Personal Information in confidence or to disclose Personal Information only to Third Parties that we believe in good faith have instituted and follow privacy and security policies that are acceptable to us.

Retention

AirSuite retains Personal Information only as long as necessary to fulfill the Purposes for which it was collected or to comply with legal and regulatory requirements. When Personal Information is no longer required, it is securely destroyed. Provided, however, Personal Information related to an account or subscription will be retained as long as the account or subscription is active. It is your responsibility to terminate an account or subscription that is no longer required.

6. Accuracy

AirSuite takes commercially reasonable efforts to ensure that Personal Information retained in an individual’s human resources file, active account, or subscription is accurate, current, and complete as is necessary to fulfill the Purpose(s) for which the information has been collected, used, retained, and/or disclosed.

However, it is your responsibility to notify us of any change in Personal Information or otherwise update your Personal Information on your AirSuite account or subscription. You may access your Personal Information in any account you establish with AirSuite for the purpose of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.

Upon your request, we may make changes or updates to your Personal Information for legitimate purposes; provided however, that we reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others. We may request identification prior to approving such requests.

Personal Information contained on inactive accounts or subscriptions is not updated.

7. Safeguards

  • Physical Safeguards. Any non-electronic Personal Information is stored in locked filing cabinets and/or offices when unattended by AirSuite Representatives.
  • Organizational Safeguards. Access to Personal Information is limited to the Representatives who need to know the Personal Information for carrying out the Services provided by AirSuite. Representatives are required to sign a confidentiality agreement covering the Personal Information to which they have access. All AirSuite employees and contractors are required to undergo privacy training and awareness programs to understand their responsibilities and applicable privacy laws.
  • Technological Safeguards. Personal Information contained in our computers and electronic databases are password protected. Access to any of AirSuite’s computers is also password protected. Our internet router/server has firewall protection to protect Personal Information against virus attacks arising from Internet activity. When you transmit Personal Information through our registration process or if you purchase products or services, we encrypt that information in transit using transport layer security technology (TLS).

Although we follow reasonable and appropriate industry standards to protect your Personal Information and other data, you should be aware that no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Information and other data by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any Personal Information you transmit to us or archive at this site.

If at any time we determine that there has been a loss, or unauthorized access to, use or disclosure of Personal Information, the Privacy Specialist will:

  • report to the Office of the Privacy Commissioner any breaches of security safeguards that pose a real risk of significant harm;
  • notify affected individuals and relevant Third Parties of any breaches with a real risk of significant harm; and
  • keep records of all breaches, regardless of whether a breach presents a real risk of significant harm.

8. Openness

AirSuite makes its privacy practices known to you by making this Privacy Policy available on its Website.

9. Individual Access

If you wish to review or verify what Personal Information is held by AirSuite, or to whom the information has been disclosed, you may make a request for access, in writing (email or letter) with your name, title, and full contact information, to AirSuite’s Privacy Specialist.

Upon verification of the individual’s identity, the Privacy Specialist will respond to the request within thirty (30) days:

The 30-day response time limit for access requests may be extended by an additional 30 days, if:

  • responding to the request within the original 30 days would unreasonably interfere with the activities of AirSuite;
  • AirSuite needs additional time to conduct consultations; or
  • AirSuite needs additional time to convert Personal Information to an alternate format.

If the 30-day response time limit is extended, then the individual making the request will be notified within 30 days of receipt of the request of their right to complain to the Office of the Privacy Commissioner.

10. Complaints

You can file a complaint about AirSuite’s Personal Information handling practices, by providing a complaint in writing to AirSuite’s Privacy Specialist.

Upon verification of your identity, the Privacy Specialist will investigate the complaint and provide a written report of the investigation’s findings to the Individual.

Where the Privacy Specialist determines that a breach of this Privacy Policy or PIPEDA has occurred, the Privacy Specialist will take steps to correct the offending information-handling practice and/or revise this Privacy Policy as appropriate.

If you are dissatisfied with the findings and corresponding action taken by the Privacy Specialist, you may file a complaint with the Office of the Privacy Commissioner.

Individuals may also anonymously report a breach or any suspected incident using this anonymous private link and form that alerts internal privacy specialist and privacy designates at AirSuite.

11. General

11.1 Specific Information About Cookies And Web Beacons

Third-Party Cookies for Web Analytics and Reporting

We reserve the right to use web analytics services provided by Third Parties. These services use third party cookies (cookies passed by others, not by us) to collect Non-Personal Information about your use of this Website. These web analytics services may also transfer this information to Third Parties where required to do so by law, or where such Third Parties process the information on the service’s behalf.

Web Beacons

A web beacon is an electronic image placed in the code of a web page. We reserve the right to use web beacons to monitor the traffic patterns of users from one of our pages to another and to improve our site’s performance.

11.2 Onward Transfer Outside Your Country of Residence

Any Personal Information or other information that we may collect on this site will be stored and processed in our servers located only in Canada and the United States. By using this website, if you reside outside of Canada or the United States, you consent to the transfer of Personal Information and other information outside your country of residence to either Canada or the United States.

11.3 Email, SMS, and Pre-Recorded Phone Messages; Opt Out

If you supply us with your e-mail address, you may receive periodic email messages from us with information specific to the Website and required for the normal functioning of the Website as well as for new products or services or upcoming events. You may also receive periodic messages from the AirSuite application that is required for alerting functionality and cannot be disabled. If you are subscribed to a paid AirSuite application and prefer not to receive periodic email messages, you may opt-out by following the instructions on the email.

If you supply us with your phone number you may receive periodic pre-recorded and text messages from us with information specific to the Website and required for the normal functioning of the Website as well as for new products or services or upcoming events. You may also receive periodic messages from the AirSuite application. If you prefer not to receive periodic pre-recorded messages, you may opt-out by following the instructions in the message or disabling alerting features from within Cirro.

Our Website may contain links to other websites. You should be careful to review any privacy policies posted on any of these sites before providing information to them.

11.5 Children’s Online Policy

We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site. We will not knowingly collect any information from, or sell to, any person under the age of 18. If you are a parent or guardian who has discovered that your child under the age of 18 has submitted his or her Personal Information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact our site as provided below under “Contact Us” and be sure to include in your message the same login information that your child submitted.

11.6 Severability

If any provision of this Privacy Policy is declared invalid or unenforceable, such provision shall be deemed modified to the extent necessary and possible to render it valid and enforceable. In any event, the unenforceability or invalidity of any provision shall not affect any other provision of this Privacy Policy, and this Privacy Policy shall continue in full force and effect, and be construed and enforced, as if such provision had not been included, or had been modified as above provided, as the case may be

11.7 Contact Us

If you have any questions regarding this Privacy Policy, please contact our privacy specialist.