‍Purpose

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps Air Aware Labs has taken to ensure that slavery and human trafficking are not taking place in our supply chains or any part of our business.

Our Commitment 

Air Aware Labs is committed to acting ethically and with integrity in all our business relationships. We have implemented systems and controls to prevent modern slavery and human trafficking in our operations and supply chain.

Our Policies 

We have established the following policies to prevent modern slavery and human trafficking:

• Supplier Code of Conduct: Requires compliance with labour laws and prohibits forced labour.
• Whistleblowing Policy: Encourages employees to report unethical or unlawful practices confidentially.

Risk Assessment and Due Diligence 

We regularly assess areas of our business and supply chain to identify and mitigate risks related to modern slavery and human trafficking. This includes:

• Conducting due diligence on new suppliers.
• Periodic audits of existing suppliers.
• Reviewing supply chain practices to identify potential vulnerabilities.

Effectiveness Monitoring 

To ensure the effectiveness of our efforts, we:

• Monitor compliance with our policies through audits and reviews.
• Address non-compliance promptly through corrective action plans.
• Continuously refine our practices based on industry best standards.

Effective Date: 24/01/2025
Version: 1.0

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‍Purpose

Air Aware Labs is committed to conducting business ethically, responsibly, and in compliance with applicable laws. This policy aims to prevent bribery and corruption in all business dealings, ensuring integrity and transparency.

Scope

This policy applies to:

• All employees, contractors, officers, and directors of Air Aware Labs.
• Third parties, including consultants, suppliers, and partners, when acting on behalf of the company.

Definitions

• Bribery: Offering, promising, giving, or receiving something of value to influence a business outcome.
• Corruption: Abuse of entrusted power for personal or business gain.
• Facilitation Payments: Small, unofficial payments made to expedite routine government actions.

Policy Statements

1. Prohibition of Bribery and Corruption
   
   • Employees and representatives must not offer, promise, give, or receive any bribes or engage in corrupt practices.
   • Facilitation payments are strictly prohibited unless there is a direct threat to health or safety.
2. Gifts and Hospitality
   
   • Gifts, hospitality, or expenses must be reasonable, proportionate, and compliant with company guidelines.
   • Any gifts or hospitality exceeding a value of £1,000 must be declared and approved by management.
3. Third Parties
   
   • Air Aware Labs conducts due diligence on third-party partners to ensure compliance with this policy.
4. Donations
   
   • Political or charitable donations must not be used to gain an improper business advantage.
   • All donations must be approved by senior management.

Reporting and Whistleblowing

• Employees are required to report any suspicions of bribery or corruption immediately to their manager.
• Reports can be made anonymously, and whistleblowers are protected from retaliation.

Monitoring and Compliance

• The company reserves the right to monitor and audit business activities to ensure compliance.
• Any breach of this policy may result in disciplinary action, up to and including termination of employment or partnership.

Responsibility

• The CEO and management team are responsible for implementing and enforcing this policy.

Review

This policy will be reviewed annually or when there are significant legal or business changes. This statement is available on the Air Aware Labs website or by contacting hello@airawarelabs.com.

Effective Date: 24/01/2025
Version: 1.0

Who We Are

Air Aware Labs Ltd is an environmental health technology company with company registration number 15435500. Air Aware Labs is the Joint Data Controller of the information you provide to us through our AirTrack mobile app that integrates with Third-Party Account Providers (such as Strava, Apple Health, and Google Fit). Air Aware Labs is the Data Controller for data you provide directly via the AirTrack mobile app.We are committed to the protection and responsible handling of your personal data.

The type of personal information we collect

We collect, process and store the following information:

• Personal identifiers, contacts, and characteristics (for example, name and contact details).
• Location data collected directly from your mobile device when using the app.
• Third party activity data including activity IDs, types, locations, times, and dates. This includes collecting and processing location information.
• Environmental data related to your activities (e.g., air pollution levels encountered during your activities).
• We may collect or infer health information. Certain health information may be inferred from sources such as heart rate or other measurements, including power, cadence, and weight or other indicators.
• When you make a payment on Air Aware Labs, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry (PCI) compliant third-party payment services and we do not store your credit card information.
• We may collect information directly from you, such as when we collect your feedback through surveys.
• Information about how you interact with AirTrack (e.g., feature usage, time spent on app). 

Third Party authentication (e.g. Strava integration) is a service provided by the Third-Party. We cannot see your username or password.

How we get the personal information and why we have it

We collect personal information from:

• Direct Input: Information you provide when creating an account or using AirTrack.
  
  
• Third-Party Services: When you authorise AirTrack to access data from platforms like Strava or Apple Health.
  
  
• Automated Tracking: Through cookies, app permissions, and other technologies when you interact with AirTrack.

We do this for the following reasons:

• To provide personalised air pollution data and insights based on your activities.
• To enhance your understanding of environmental health as it relates to your health and fitness routine.
• To improve our services (e.g. to analyse app usage, fix bugs, and enhance the user experience). We use aggregated, anonymised data for this purpose.This includes improving onboarding experience and app discoverability on platforms such as the Apple App Store and Google Play Store. Metadata such as screenshots, previews, and Open Graph images may be used to enhance discoverability and user experience during app downloads and referrals.

Your personal information is collected:

• Directly from you when you use our app or website and its features.
• From third-party software such as Strava, when you authorise our app to access your Strava data for the purpose of providing our services.
• Through automated technologies or interactions with our services using cookies and other tracking technologies.

We may share this information with third-party service providers who assist us in delivering our services, under strict confidentiality agreements. 

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) you have given consent to the processing of your personal data for one or more specific purposes and can withdraw this at any time by contacting us at our email address.

(b) processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

(f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where the data subject is a child.

How we store your personal information

Your information is securely stored within our data processing systems and third-party cloud services, ensuring the highest standards of data protection.

We keep your personal information for as long as you use our app or until you request its deletion. After a period of 12 months of inactivity we consider you to be no longer using our app and will ask you to access the app otherwise we will delete your account and data after a further 1 month. We dispose of your information by securely erasing it from our systems.

How we use your personal information 

We use the information that you - or a Third-Party - has given us in order to offer personalised environmental health insights and recommendations to improve your fitness experience. There are several uses of your information:

(a) To customise your experience

We may use the information we collect and receive to customise your experience. For example, we may suggest low-pollution segments, routes, challenges, or clubs on Strava that you may want to try. We generate Open Graph metadata to enrich universal links (e.g., previews when you share a route or challenge). These previews may include anonymised environmental data or images related to AirTrack but do not contain personal data.  Legal basis: b) contract

(b) To provide you with targeted promotions

We may use the information we collect and receive to serve you with relevant promotions, subject to your notification and email preferences. For example, if you are an active user who has never subscribed to our premium service, we may send you an offer for a free subscription trial. We may also use the information we collect and receive to market and promote the Services, for partnership opportunities,  activities and events on Air Aware Labs, and other commercial products or services, including using email and push notifications, in accordance with your preferences. Legal basis: a) consent

(c) To assist you with a support request

We use the information we collect and receive to provide support in response to your requests and comments. Depending on your request, this may require us to access your account, for example, to troubleshoot or replicate a reported issue. Legal basis: f) legitimate interest

(d) To improve our Services

We also use the information we collect and receive to conduct research, and to analyse, develop, troubleshoot, and improve the Services. To do this, Air Aware Labs may use third-party analytics providers to gain insights into how our Services are used, using aggregated data, and to help us improve the Services. Legal basis: f) legitimate interest

(e) To communicate with you

We may contact you when investigating alleged violations of our terms or to send proactive customer support messages. Legal basis: f) legitimate interest

(f) To process your subscription

We use the information we collect to process your subscription, including using your location data to determine your country pricing. Legal basis: b) contract

How we share your personal information 

We share your personal information with third-party service providers (“sub-processors”) who assist us in delivering our services. These may include analytics, email, authentication, infrastructure, marketing, attribution, and payment tools. We maintain a Record of Processing Activities and ensure all providers meet GDPR compliance standards. A current list is available in this section and may be updated as needed. Air Aware Labs uses the following sub-processors:

MailerLite

We use MailerLite to manage our email marketing subscriber list and to send emails to our subscribers. MailerLite is a third-party provider, which may process your data using industry-standard technologies to help us monitor and improve our newsletter. MailerLite’s privacy policy is available at https://www.mailerlite.com/legal/privacy-policy. You can unsubscribe from our newsletter by clicking on the unsubscribe link provided at the end of each newsletter at any time.

PostHog

We use PostHog to capture and process user analytics data, to help improve our products and services. You can change your settings by clicking the cookie control icon at the bottom left of any page.

Meta Pixel

We use Meta Pixel to track the effectiveness of our marketing campaigns. You can change your settings by clicking the cookie control icon at the bottom left of any page.

FusionAuth

We use FusionAuth to provide user authentication services

Fly.io

Our virtual servers and databases are hosted by Fly.io

Branch.io

We use Branch.io to generate and manage universal deep links to the AirTrack app, enabling features such as campaign tracking, user onboarding flows, and shareable links with previews. Our integration with Branch is configured in a way that does not collect Personally Identifiable Information (PII). However, Branch may collect certain metadata for attribution purposes, such as referring URLs, device types, and anonymised location estimates.

We are currently reviewing GDPR compliance for Branch and have listed them as a sub-processor. We will update our Record of Processing Activity and privacy documentation as required. Branch’s privacy policy is available at: https://www.branch.io/policies/#privacy

RevenueCat

We use RevenueCat to manage in-app purchases and subscriptions across the Apple App Store and Google Play Store. RevenueCat does not store full payment details, but may process anonymised purchase metadata for analytics and revenue tracking. You can view their privacy policy here: https://www.revenuecat.com/privacy/

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is not Personal Data

We may convert Personal Data into anonymous data, that is data which can no longer be linked with identifiable individuals, for example by aggregation of data about multiple individuals. We may create aggregated, de-identified or anonymised data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. 

We may use such anonymous data and share it with third parties for our lawful business purposes, including to analyse, build and improve the Service and other future products and services, and promote our business, provided that the data remains anonymous. We do not delete anonymous data on any particular timetable. You may assume that we could keep it indefinitely. 

Your data protection rights

Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information. 
• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 
• Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at support@airawarelabs.com if you wish to make a request.

Marketing and Communication Preferences

• You can opt out of promotional emails at any time via the "unsubscribe" link in emails.
  
• You can manage notification preferences in the AirTrack app settings.

Our contact details

Name: Air Aware Labs Ltd

Address: 76 Dalberg Road, London, England, SW2 1AW, United Kingdom

E-mail: support@airawarelabs.com

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at support@airawarelabs.com. You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Privacy Policy Updates

Air Aware Labs reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Air Aware Labs makes changes to this Privacy Policy, the updated Privacy Policy will be posted in a timely manner. If we make changes we deem to be material, we will provide a prominent notice. If you object to any changes to this Privacy Policy, you should stop using the Services and delete your account.

This policy (Version 7) was last updated on 31 March 2025 and will take effect from 1 April 2025.

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Welcome to AirTrack, a product of Air Aware Labs. These Terms of Use ("Terms") govern your use of AirTrack, a service provided by Air Aware Labs. By using AirTrack, you agree to these Terms. Please read them carefully. If you do not agree with any of these Terms, you are prohibited from using the AirTrack service.

1. Acceptance of Terms

By registering and using AirTrack, you accept and agree to be bound by these Terms and any posted guidelines or rules applicable to the services provided.

2. Description of Service

AirTrack is a mobile app that provides personalised air quality information based on your activity data. It directly records location data and/or synchronises with Strava, Apple Health, and Google Fit to help you understand your exposure to air pollution during physical activities and make informed decisions to minimise health risks.

Key features include:

• Personalised air quality insights based on your location and activity data.
  
• Real-time air quality modelling (Google Air Quality API) data and personal exposure algorithms
  
• Direct integration with third-party platforms (e.g., Strava, Apple Health).
  

The service is a direct-to-consumer mobile app and a web dashboard (which is being phased out for individual use).

3. Subscription and Billing

By subscribing to AirTrack Premium, you acknowledge that the service involves recurring billing unless your access is provided through a business-to-business (B2B) agreement or a research contract. Payment will be charged on a monthly or annual basis, depending on the plan you select. 

• All prices are inclusive of VAT.
• Monthly Subscriptions: After any introductory or discounted period, your monthly subscription fee will revert to the regular price (e.g., £2.99 per month) unless cancelled prior to the renewal date.
• Annual Subscriptions: You will be charged for the full year upfront. Refunds for early cancellation of an annual subscription are not provided unless stated otherwise. Please refer to the specific cancellation terms for annual plans in your account settings.

The exact cost of your subscription will be shown at checkout, including any discounts or introductory offers. The discounted price and the regular price after the discount will be made explicitly clear during the sign-up process.

Important: By subscribing, you agree that Air Aware Labs has the right to charge your payment method on a recurring basis until you cancel the subscription.

By subscribing to AirTrack, you acknowledge that payment processing services for our service are provided by Stripe and are subject to Stripe’s Terms of Service and Privacy Policy. By using AirTrack and agreeing to these Terms, you also agree to be bound by Stripe’s terms, which can be reviewed at Stripe Terms of Service and Stripe Privacy Policy.

By providing a payment method to Stripe, you authorise us and Stripe to charge the applicable subscription fees on a recurring basis (monthly or annually, depending on your chosen plan) as described during your sign-up process. Your payment will automatically renew until cancelled.

We take the security of your payment information seriously. Stripe is PCI-DSS compliant, meaning it adheres to the highest security standards for handling payment information. Air Aware Labs does not store your full payment information; all sensitive payment details are securely processed and stored by Stripe. If you choose to delete your AirTrack account, we will no longer have access to your payment information; however, Stripe may retain certain data in accordance with its legal obligations. For more information on how Stripe handles data, please refer to their Privacy Policy.

4. Cancellation and Refunds

You can cancel your AirTrack subscription at any time. If you cancel a monthly subscription, you will continue to have access to the service until the end of the current billing cycle, but no further charges will be made. No refunds will be provided for the remaining period of a monthly subscription once billed.

For annual subscriptions, cancellation will not result in a pro-rated refund unless explicitly offered as part of a specific promotion. You will retain access to AirTrack until the end of your billing year, after which the subscription will not renew unless you resubscribe.

All transactions, including subscription charges and refunds, are processed through Stripe. If a payment fails to process due to issues with your payment method (e.g., expired credit card or insufficient funds), Stripe will attempt to charge the payment method again. If the payment continues to fail, your subscription may be suspended, and access to the AirTrack service may be restricted until payment is successfully completed.

If you believe a payment has been processed incorrectly or you wish to dispute a transaction, please contact us immediately at support@airawarelabs.com. All payment disputes will be handled in accordance with Stripe’s dispute resolution process. You are responsible for reviewing your subscription charges and ensuring any discrepancies are reported within a reasonable time frame.

5. User Obligations

As a user, you agree to:

• Provide accurate, current, and complete information about yourself as prompted by AirTrack.
• Maintain and promptly update your information to keep it accurate, current, and complete.
• Use AirTrack only for personal, non-commercial purposes.
• Not use AirTrack for any unlawful or prohibited activities.
• You are responsible for maintaining accurate and complete payment information in your account. Failure to provide a valid payment method or resolve payment issues may result in the suspension or termination of your subscription and access to the Premium or Pro service.

6. Data Collection and Privacy

We collect, use, and share your data as described in our Privacy Policy. AirTrack collects location data and activity data via the mobile app and/or from integrated platforms (e.g., Strava, Apple Health, Google Fit) to personalise air quality insights. By using AirTrack, you consent to the collection and use of your data, including activity data from integrated third-party services, in accordance with the Privacy Policy.

7. Intellectual Property

All content included on AirTrack, such as text, graphics, logos, and software, is the property of Air Aware Labs and is protected by applicable intellectual property laws. Unauthorised use of any materials on AirTrack may violate copyright, trademark, and other laws.

8. Limitation of Liability

Air Aware Labs will not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to your use of AirTrack. We do not guarantee the accuracy, completeness, or usefulness of any information provided by AirTrack.

9. Termination

We reserve the right to terminate or suspend your access to AirTrack at our sole discretion, without notice, for conduct that we believe violates these Terms or is harmful to other users of AirTrack, us, or third parties, or for any other reason. 

Deleting the app from your device does not automatically cancel your subscription. You must cancel through the app or by emailing support@airawarelabs.com to avoid further charges.

10. Changes to Terms

Air Aware Labs reserves the right to modify these Terms at any time. We will notify users of any significant changes by posting the new terms on our website. Your continued use of AirTrack after any changes to these terms constitutes your acceptance of the new terms.

11. Governing Law

These Terms are governed by and construed in accordance with the laws of England and Wales, without regard to its conflict of law principles.

12. Our Service

AirTrack provides you with various features and services, including:

• Offering personalised air quality insights based on your activity data from third parties such as Strava.
• Utilising technologies such as artificial intelligence and machine learning to improve our services.
• Connecting you with relevant information about air quality, health, and related topics.
• Providing access to a dashboard and a future app for direct-to-consumer interactions.

13. Your Commitments

In return for our commitment to provide the Service, we require you to make the following commitments:

• You must be at least 18 years old.
• You must not be prohibited from receiving any aspect of our Service under applicable laws.
• We must not have previously disabled your account for violation of law or any of our policies.

14. Prohibited Uses

You agree not to:

• Impersonate others or provide inaccurate information.
• Use AirTrack for any unlawful, misleading, or fraudulent activities.
• Violate these Terms or our policies.
• Interfere with or impair the intended operation of the Service.
• Create accounts or collect information in an unauthorised way.
• Post someone else's private or confidential information without permission.
• Modify, translate, create derivative works of, or reverse-engineer our products or their components.

15. Permissions You Give to Us

By using AirTrack, you give us permissions necessary to provide the Service:

• All content and data remain entirely owned by Air Aware Labs.
• Display your username, profile picture (if uploaded), and activity data in the app.
  
• Remove or restrict any content that violates these Terms.
  
• Suspend or terminate your account for repeated violations.

You can adjust permissions for accessing health and activity data in the AirTrack app settings.

16. Content Removal and Account Termination

We can remove or restrict content or information shared on AirTrack if we believe it violates these Terms or our policies. We can also terminate or change the Service, remove or block content, or stop providing all or part of the Service if necessary to avoid or mitigate adverse legal or regulatory impacts on us. In the case of termination or suspension, we may notify you of the action and provide the reason, though in some cases we may not provide notice if doing so would violate the law or put our systems at risk.

If your account is terminated, you may not be eligible for a refund of any fees paid, and we reserve the right to refuse future access to the Service under any new accounts you may attempt to create.

We also retain the right to modify or discontinue any part of the Service or the entire app, at any time, without liability. If the termination is a result of a violation of these Terms, any remaining rights to the use of the Service will be forfeited.

14. Web Dashboard Decommissioning

We are transitioning from the web dashboard to the mobile app.

• Individual access to the web dashboard will be phased out.
• Your web dashboard account will be accessible from the mobile app, and all your data will be available in the mobile app.
  
• You will receive advance notice before access is removed.
  

17. Disputes

If a claim or dispute arises out of or relates to your use of AirTrack, you agree to resolve it in the courts of England and Wales.

18. Contact Information

If you have any questions about these Terms, please contact us at support@airawarelabs.com.

By using AirTrack, you acknowledge that you have read, understood, and agree to be bound by these Terms.

Version 1 effective from 7 September 2024.

Version 2 last updated on 25 March 2025 and will take effect from 1 April 2025.

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