AirPortr Privacy Policy

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INTRODUCTION

We (“Portr”, “we” and/or “us”) provide remote check in luggage delivery services (the “Services”) to airline passengers. We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and/or use our Services and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Portr collects and processes your personal data through your use of this website (which includes the domain https://www.portr.com/ , https://www.airportr.com and all related subdomains) and our apps, including any data you may provide through this website or our app(s), when you sign up to our Services or to receive our tips, news and offers.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

CONTROLLER

Portr Limited is the data controller and responsible for your personal data.If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us for the attention of the Data Privacy Manager, using the details set out below.

Our full details are:

Full name of legal entity: Portr Limited

For the attention of: The Data Privacy Manager

Email address: support@airportr.com

Postal address: 2nd Floor, North, 70 South Lambeth Road, London SW8 1RL

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

THIRD-PARTY LINKS

This website and our app(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or our app(s), we encourage you to read the privacy notice of every website you visit.

 

2 THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, email address, username or similar identifier.
  • Travel Itinerary Data includes pick up (or delivery) address, pick up (or delivery) time, flight number, time, departure and destination airport.
  • Boarding Pass Data includes PNR number (passenger name record), QR code data, and copy of boarding pass.
  • Passport Data includes complete first and last name, nationality, expiry date, passport number, MRZ (machine readable zone), and a copy of the passport page.
  • Luggage Data includes photographs, x-ray images, IATA license plate numbers and weight of the baggage that we handle on your behalf.
  • Contact Data includes billing address, email address and telephone numbers
  • Transaction Data includes details of services you have purchased from us.
  • Financial Data includes last 4 digits, expiry date, type and postal code of credit/debit card used to purchase the service and transaction history, including successful and unsuccessful payments (including the amount of each payment) made to EdPlace.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or our app(s).
  • Profile Data includes purchases or requests made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, app(s) and services.
  • Marketing Data includes your preferences in receiving marketing from us and your engagement with our marketing activities.
  • Communications Data includes your communication preferences and email, voicemail and telephone records to customer support.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3 HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and/or Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
    • apply for or use our services;
    • subscribe to our service;
    • request marketing communications or content to be sent to you;
    • correspond with our Customer Service or Sales teams;
    • partake in a promotion;
    • complete a survey; or
    • provide us with feedback.
  • Automated technologies or interactions. As you interact with our website or app(s), we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our policy on cookies for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
    • Technical Data from analytics providers such as Google and Mixpanel based outside the EEA;
    • Financial Data (for example the success or otherwise of a transaction) from payment providers based either inside or outside the EEA.
    • Airline partners, Airport partners, or government entities (e.g. border force, CBP and police) when validating your eligibility for the specific service

 

4 HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new user (a) Identity
(b) Contact
Performance of a contract with you
To register your booking with us (a) Identity (b) Contact(c) Travel Itinerary (c) Financial (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To provide you with the Bag Check In service (a) Identity (b) Travel itinerary (c) Boarding Pass (d) Passport (e) Luggage(f) communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (including external security audits)
To provide you with the Standard Delivery Service (SDS, i.e. Airport Delivery or City Delivery) (a) Identity (b) Travel itinerary (c) Luggage(d) Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (including external security audits)
To deliver service improvements (a) Identity (b) Travel itinerary(c) Boarding Pass (d) Luggage Necessary for our legitimate interests (to develop improved processes, new services and better customer experience)
To process and deliver your subscription including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a Promotion (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website and our apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website and app content, and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, app(s) products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and app(s) updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about features or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business)
 

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US  

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details and in all cases have opted in to do so.

THIRD-PARTY MARKETING  

We do not share your personal data with any company for marketing purposes.

OPTING OUT  

You can ask us to stop sending you marketing messages at any time by contacting us.  We endeavour to make the opt out process as simple as possible.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or a service experience.

COOKIES 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. You can learn more about our usage of cookies below.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5 COOKIES

INTRODUCTION

Our website uses cookies. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

ABOUT COOKIES

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser, and which may then be sent back to the server each time the browser requests a page from the server. Cookies can be used by web servers to identify and track users as they navigate different pages on a website, and to identify users returning to a website.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

OUR COOKIES

We use both session and persistent cookies on our website. The type of cookies that we use on our website, and the purposes for which they are used, are set out below:

Persistent cookie which may be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website’s usability and for marketing purposes. We may also use that information to recognise your computer when you visit our website, and to personalise our website for you.

Session cookies. These cookies do not operate once you log off completely from the website whereas persistent cookies remain on your hard drive for an extended period afterwards. We do not store Personally Identifiable Information in our cookies nor do we link the information in our cookies to our users’ Personally Identifiable Information.

Web beacons or pixels or clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which track your online Web movement and which may be embedded virtually invisibly on Web pages. We employ Pixels to better manage content on our Sites. Clear GIFs are used to track the online usage pattern of our users anonymously. The information is used to enable more accurate reporting, improve the effectiveness of our Service. But, we do not link the information gathered by Pixels/ clear GIFs to our users’ Personally Identifiable Information.

HOW WE USE COOKIES

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies. We may use the information we obtain from your use of our cookies for the following purposes:

  • To recognise your computer when you visit our website;
  • To track you as you navigate our website, and to enable the use of the functions within it;
  • To improve the website’s usability;
  • To analyse the use of our website;
  • In the administration of this website.

Analytics cookies

We use an analytics service to collect information about how visitors use our site. Our analytics service provider generates statistical and other information about website use by means of cookies. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and pages visited.

Tracking cookies

Tracking cookies are used to track users’ web browsing habits. This can also be done to some extent by using the IP address of the computer requesting the page or the referer field of the HTTP request header, but cookies allow for greater precision.

Operational cookies

Operational cookies allow us to identify you as an individual user of our service and provide access to appropriate services and content. We also use operational cookies to maintain service stability, improve service performance and/or provide device-specific functionality (for example, serving mobile-friendly pages).

 

6 DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

  • Companies that we work with or partner with to deliver our Services to you including airlines, and certain operational partners
  • Professional services and technology providers such as marketing agencies, website development companies and other technology companies, such as Customer Relationship Management or Marketing Automation tools, who help us run our business.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Where we are required to do so for legal or regulatory compliance.

We may provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

7 INTERNATIONAL TRANSFERS

We share your personal data within Portr. This may involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

8 DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

9 DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 unauthorised 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.

In some circumstances you can ask us to delete your data: see Request Erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

10 YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are outlined in the Glossary below.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out in the Glossary, please contact us.

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND  
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

11 GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.