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Aires Privacy Notice - Last revised 06/19/2024

At Aires, we are committed to protecting your privacy. This Privacy Notice explains how we collect, use, disclose, and safeguard your personal information when you visit our website or use our services. By accessing our website or using our services, you agree to the terms of this Privacy Notice.

Our Role

In most situations Aires operates as a data processor. We process personal information for purposes determined by the data controller. If you are visiting our website, we operate as a data controller.

Aires affirmatively commits to complying with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Aires has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Aires has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Information We Process

As a data processor, Aires processes your personal information that we collect from you or the data controller.

As a data controller, we process personal information of our employees in the EEA in order to facilitate standard day-to-day business activities and employment relationship activities. The types of personal information we may process include:

Non-HR

  • Contact information (e.g., name, email address, phone number)
  • Identifying Information (e.g., DOB, driver’s license number, social security number, passport number, EIN)
  • Demographic information (e.g., address, destination address)
  • Financial Information (account balances, income, assets, insurance premiums, payment history )
  • Device information (e.g., IP address, browser type)

HR

  • Resume/CV
  • Personal contact information
  • Job title, job status, department, and job code
  • Performance management information
  • Pay information

Use of Information

We may use the personal information we collect for various purposes, including:

Non-HR

  • Providing Global Mobility Services
  • Providing and improving our products and services
  • Responding to your inquiries and fulfilling your requests

HR

  • Managing our employment relationship
  • Onboarding and offboarding employees
  • Providing applicable benefits
  • Responding to your inquiries and fulfilling your requests

We may share your personal information with third parties in the following circumstances:

  • Service Providers: We may engage trusted partners to perform certain functions on our behalf. These partners have access to your personal information only to the extent necessary to fulfill their duties.
  • Legal Requirements: We may disclose your personal information if required to do so by law or in response to a valid legal request, such as a court order or government investigation.
  • Protection of Rights: We may disclose your information to protect our rights, property, and safety, as well as the rights, property, and safety of our users and others.

Aires will endeavor to ensure that its agreements with third party service providers limit the retention, use, and disclosure of personal information by the third-party service provider solely for the purpose of carrying out the contracted services and provide a level of protection for personal information that is comparable to that provided by Aires.

Aires may be liable in cases of onward transfers to third parties. For more information on this principle, please visit: ACCOUNTABILITY FOR ONWARD TRANSFER

Your Choices and Rights

Aires receives and processes personal data from the data controller as necessary for the performance of contract. Aires does not require consent to process your data if you are receiving global mobility services.

Aires does not distribute nor otherwise disclose personal information to other parties except for those business partners, suppliers, and other third parties who act for or on behalf of Aires to provide direct services to our clients. Where disclosure of personal information to a third party is likely or necessary, further notice may be provided, where appropriate, at such collection points as to the intended use of the data.

We require that such third parties protect the information and, where appropriate, we will contractually require them to process data transferred only for the purposes expressly authorized by Aires.

Pursuant to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) and to the rights of EU and UK individuals and Swiss individuals, you have the right to access, update, correct, or request deletion of your personal information. You may also have the right to object to certain data processing activities. To exercise your rights or make changes to your preferences, please contact us by emailing privacy@aires.com or access the Privacy Webform on our website.

Data Security

We take the security of your personal information very seriously and have implemented appropriate technical and organizational measures to protect it. Our Information Security Management System is certified to ISO 27001, and our Privacy Information Management System is certified to ISO 27701. However, please note that no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Tracking Technologies

Any information that Aires’s webservers may store in cookies is used for internal purposes only. Cookie data is not used in any way that would disclose personally identifiable information to outside parties unless Aires is legally required to do so in connection with law enforcement investigations or other legal proceedings.

Legal

Data Privacy Framework (DPF) Commitment

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Aires commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of HR data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.

Further, Aires commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U. S DPF, UK Extension to the EU-U. S DPF, and Swiss-U. S DPF to the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR-AAA), an alternative dispute resolution provider headquartered in New York, NY, U.S.A. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit ICDR-AAA DPF IRM Service for more information or to file a complaint. The services of ICDR-AAA are provided at no cost to you.

Aires is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to your organization and following the procedures and subject to conditions set forth in Annex I of Principles. For more information on this principle, please visit: Data Privacy Framework ANNEX I introduction.

Aires may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), American International Relocation Solutions, LLC d/b/a Aires has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR: 

  • by using EDPO’s online request form: EDPO Data Request
  • by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

General Data Protection Regulation

European Union data subjects have certain rights including the right to access personal information, the right to rectification, the right to erasure (to be forgotten), the right to restrict processing, the right to object, and the right to data portability. Any inquiries related to these rights can be sent to privacy@aires.com. Clients with active credentials may also login to www.aires.com and submit a data inquiry request. Aires primarily operates as a processor on behalf of client controllers and has certain obligations within data processing agreements with those controllers. As such, verified inquiries will be sent to appropriate data controllers to evaluate data subject rights.

U.S. State Law (CA, UT, CO, VA, CT, et.al)

Aires is a service provider (or equivalent), and only processes personal information as directed by the applicable business (or equivalent).

Aires does not use, disclose, or retain personal information for any purpose outside of the business contract, unless otherwise permitted by law.

Aires is obligated to assist the business in carrying out legal consumer rights requests.

Enforcement

Aires’ compliance with the DPF is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) and/or the U.S. Department of Transportation (DOT).

Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or applicable laws. The revised Privacy Notice will be effective when posted on our website. We encourage you to review this page periodically for the latest information on our privacy practices.

Contact Us

If you have any questions, concerns, or requests, please visit the Privacy Webform or email privacy@aires.com.