Privacy Policy

1.Who we are

2.Controller data vs client (processor) data

Airsenseinc operates a unified website through which we provide information about our business, services and service offerings, including Business Outsourcing and Corporate Concierge. Our role in processing personal data depends on the nature of the activity and the services involved.

Personal data we process as a Data Controller

When we determine the purposes and means of processing personal data, we act as a Data Controller, or the equivalent role under applicable data protection law. In this capacity, we may process personal data relating to website visitors, prospective and existing clients, individual customers, business contacts, suppliers, vendors, service providers, marketing contacts, employees, contractors and job applicants. This may include information submitted through website forms, consultation requests, booking enquiries, service requests, recruitment applications, customer communications and other interactions with us. We process this information for legitimate and lawful business purposes, including responding to enquiries, providing and managing our services, administering client and supplier relationships, processing bookings and service requests, communicating with customers, improving our website and service delivery, managing recruitment, conducting marketing where permitted, maintaining business records, protecting our systems and property, preventing fraud, and complying with applicable legal and regulatory obligations. Where Airsenseinc acts as the Data Controller, we are responsible for identifying an appropriate lawful basis, providing relevant privacy information, implementing appropriate safeguards, and responding to applicable data protection rights and requests.

Personal data processed through Business Outsourcing

Airsenseinc provides outsourcing and managed operational services, which may include customer experience, customer support, business operations, growth and community, and related services. In delivering these services, we may process personal data belonging to our clients’ customers, users, employees, or other individuals whose information is handled as part of the contracted services. Where we process personal data on behalf of a client and in accordance with that client’s documented instructions, the client will generally act as the Data Controller, while Airsenseinc acts as a Data Processor; where we engage another service provider to process that information on our behalf, that provider may act as a Sub-processor, subject to the applicable contractual and legal requirements. In these circumstances, the relevant client is generally responsible for determining the purposes and lawful basis of processing, providing the appropriate privacy notice to affected individuals, determining the scope of the data processing, and ensuring that its instructions comply with applicable data protection law. Airsenseinc will process such personal data in accordance with the applicable service agreement, DPA, documented client instructions and relevant legal requirements, apply appropriate technical and organisational security measures, and will not use client personal data for unrelated purposes unless authorised by the client or otherwise permitted or required by law. Individuals who wish to exercise rights or raise questions concerning personal data processed by Airsenseinc on behalf of an outsourcing client should generally contact the relevant client in the first instance.

Personal data processed through Corporate Concierge

Airsenseinc Corporate Concierge provides corporate concierge and support services, which may include travel arrangements, accommodation and transportation coordination, airport transfers, corporate and personal assistance, gifting, event and retreat support, bookings, courier coordination and related services. When clients contact us, request a quote, make a booking, purchase a service or otherwise engage Airsenseinc Corporate Concierge, we may process personal data necessary to respond to the request, coordinate the relevant services, communicate with the individual, manage bookings and payments, liaise with relevant suppliers, provide customer support, maintain records and meet applicable legal obligations. Depending on the service requested, this information may include contact details, booking information, travel or accommodation details, service preferences, delivery information, payment or transaction records, and communications relating to the requested service. For these activities, Airsenseinc will generally act as the Data Controller where we determine the purposes and means of processing, and as a Data Processor where a corporate client or another organisation determines the purposes and means and engages us to act on its behalf. Where fulfilling a request requires us to share relevant information with airlines, hotels, transport providers, couriers, event organisers, gifting suppliers or other service providers, we will share information reasonably necessary to coordinate the requested service, subject to applicable legal requirements and appropriate safeguards.

A single website, different processing activities

Although Airsenseinc is presented through one website, the personal data we process depends on the service, transaction or interaction involved. This Privacy Policy applies to personal data processed through our unified website and related business activities. Additional service-specific notices, booking terms, contractual provisions or Data Processing Agreements may apply where necessary to explain particular processing activities or allocate responsibilities between Airsenseinc and another organisation. The fact that our service offerings share a website or brand does not mean that personal data collected for one purpose will automatically be used for another; we process personal data in accordance with the purpose for which it was collected, the applicable lawful basis, any relevant contractual restrictions and applicable data protection requirements.

Questions, requests and privacy enquiries

If you have questions about this Privacy Policy, wish to understand how we process your personal data, or want to exercise a data protection right, you may contact Airsenseinc through the privacy contact details published on our website. If your enquiry concerns personal data that Airsenseinc processes on behalf of an outsourcing client, please identify the relevant client or service, where possible, so that we can direct your request appropriately. Nothing in this section limits any rights you may have under applicable data protection law or prevents you from contacting the relevant Data Controller or competent data protection authority where appropriate.

3.Personal data we collect

Depending on the relationship, we may collect the following categories of Personal Data (as a Controller):

4.Sensitive / special-category data

Across our services, we are committed to protecting the privacy, confidentiality and security of the personal data entrusted to us. We do not routinely collect or seek to process sensitive or special-category personal data about our business contacts, prospective clients, suppliers, job applicants, or other individuals who interact with us. We ask that you do not submit such information through our website, contact forms, emails, booking enquiries, consultation requests or other channels unless we have specifically requested it or it is reasonably necessary for the service or purpose concerned.

In limited circumstances, processing sensitive or special-category personal data may be necessary for a legitimate and clearly defined business purpose, which may include:

• Employment and recruitment: processing limited sensitive personal data relating to our employees or applicants where necessary and permitted by applicable employment, data protection or other relevant laws.
• Outsourcing and managed services: handling personal data belonging to our clients’ customers or end users where Airsenseinc acts as a data processor on the client’s documented instructions, and where permitted by applicable data protection law.
• Corporate concierge and lifestyle services: processing information that may be sensitive in nature, such as accessibility requirements or dietary restrictions relating to a medical condition, only where necessary to fulfil a requested service and subject to appropriate safeguards and a valid legal basis.
• Legal and regulatory obligations: processing information where required or authorised by applicable law, or where otherwise lawfully necessary to establish, exercise or defend legal claims.

Where such processing is necessary, we apply appropriate technical and organisational safeguards proportionate to the nature and sensitivity of the information, which may include restricting access to authorised personnel, limiting collection and retention to what is necessary, maintaining confidentiality obligations, applying secure handling procedures, and obtaining specific consent or meeting other applicable legal requirements where required. We do not use sensitive or special-category personal data for unrelated purposes or collect it simply because it may be useful. If you believe that you have provided sensitive personal data to us unintentionally, please contact us so that we can assess the circumstances and take appropriate action where legally and operationally possible.

5.How we collect data

Airsenseinc collects personal data through various channels and interactions in connection with our website, business operations, services and relationships. Depending on the service you use and your relationship with us, we may collect personal data in the following ways:

• Directly from you: when you complete forms on our website, submit an enquiry, request a consultation, make a booking, request concierge assistance, communicate with our team, attend meetings, provide feedback, or otherwise interact with us.
• Through our clients and their systems: where we provide outsourced customer experience, business operations, growth and community, or other managed services, we may access personal data supplied by or made available through our clients, their customers, authorised representatives, business systems, CRM platforms, support tools and other operational systems.
• Through concierge requests and service arrangements: when you request or use Corporate Concierge services, we may receive personal data relating to your identity, contact details, preferences, bookings, travel arrangements, accommodation, transportation, deliveries, event planning, corporate gifting requests, or other services you have requested, including from authorised representatives and service providers involved in delivering the service.
• From employers, business partners, suppliers and vendors: we may receive personal data from current or prospective employers, corporate clients, business partners, service providers, professional advisers, payment or booking partners, and other organisations where relevant to our relationship or services.
• From public and professional sources: we may collect relevant business or professional information from publicly available websites, business directories, professional networking platforms, company websites, public records and industry publications, for purposes such as business development, recruitment, verification and relationship management, where permitted by law.
• Through our website and digital channels: when you visit or interact with our website, we may collect information such as your IP address, browser type, device information, approximate location derived from technical data, pages visited, referral source, access times and interactions with website features, using cookies and similar technologies subject to applicable consent requirements and our Cookie Policy.
• Through recruitment and application channels: when you apply for a role, submit a CV, participate in an interview or are referred for an opportunity, we may collect your contact information, employment history, qualifications, skills, references, interview information and other details relevant to your application.
• Through communications, technology and security systems: including service records, customer support interactions, correspondence, system access logs, security alerts, incident reports, audit trails and other records necessary to deliver our services, maintain system security and meet legal or contractual obligations.
• From authorised representatives and third parties: where appropriate and lawful, we may obtain personal data from someone acting on your behalf, such as an employer, corporate administrator, authorised booking contact, family representative or referrer.

The categories of personal data we collect depend on the nature of your interaction with Airsenseinc, the specific service requested, and our legal and contractual obligations. We seek to collect only information that is relevant and necessary for the applicable purpose.

6.Why we process data and our lawful bases

Airsenseinc processes Personal Data to operate our business, provide our services, manage relationships with clients and customers, improve our website, and meet our legal and regulatory obligations. Depending on the service involved, we may act as a Data Controller, a Data Processor, or, where permitted, a Sub-processor. The purposes for which we process Personal Data, the lawful bases we may rely on, and our role are outlined below.

Our lawful bases

Depending on the applicable law and the purpose of processing, we may rely on one or more of the following lawful bases:

• Consent: where you have freely agreed to a specific use of your Personal Data. You may withdraw your consent at any time, subject to any processing lawfully carried out before withdrawal.
• Performance of a contract: where processing is necessary to enter into or fulfil a contract with you, including providing services you request.
• Steps before entering into a contract: where processing is necessary to respond to your request, prepare a proposal or take other requested steps before a contract is concluded.
• Legitimate interests: where processing is necessary for a legitimate business purpose, provided those interests are not overridden by your rights and freedoms.
• Legal obligation: where processing is necessary to comply with an applicable legal or regulatory requirement.
• Other lawful grounds: where recognised by applicable law, including the protection of vital interests or the performance of a task carried out in the public interest, where the relevant conditions are met.

We determine the appropriate lawful basis for each processing activity based on the circumstances and the law that applies. We do not treat consent as a blanket authorisation for unrelated processing; where consent is required, we seek it appropriately, do not rely on pre-ticked boxes, and provide a means to withdraw it. For Personal Data processed on behalf of an outsourcing Client, the Client is generally responsible for determining the purposes and lawful basis, and Airsenseinc processes that data in accordance with the Client’s documented instructions, our contractual arrangements and applicable law.

7.Who we share personal data with

Airsenseinc does not sell Personal Data. We share it only where necessary for the purposes described in this Policy, where authorised by the relevant individual or Client, or where permitted or required by applicable law. Depending on the service you use and our relationship with you, we may share Personal Data with the following categories of recipients:

• Our clients and business partners, where necessary to deliver contracted services, coordinate projects or manage a business relationship.
• Our employees, contractors and authorised personnel, limited to individuals who need the information to perform their responsibilities and who are subject to appropriate confidentiality and data protection obligations.
• Service providers and technology vendors, including providers of cloud hosting, CRM systems, communications platforms, email services, payment processing, scheduling, analytics, cybersecurity, document management and other business tools.
• Concierge suppliers and service providers, such as airlines, hotels, accommodation providers, transport operators, travel agents, gift suppliers, courier companies and event organisers — sharing only the information reasonably necessary for the arrangement, subject to applicable law.
• Approved AI and automation providers, where appropriate to support internal operations or deliver services agreed with a Client, subject to applicable law, contractual restrictions and appropriate safeguards.
• Professional advisers, such as our lawyers, accountants, auditors and insurers, where reasonably necessary for advice, compliance, risk management or the protection of our legal interests.
• Regulators and public authorities, including courts, regulators and law enforcement agencies, where required by law or otherwise lawfully permitted.
• Corporate transaction parties, in connection with a merger, restructuring, financing, acquisition or sale of assets, subject to appropriate confidentiality and other safeguards.

Client data and service providers

When Airsenseinc processes customer data on behalf of a Client, we do not use or disclose that data for our own unrelated purposes. Any access by our personnel, suppliers or Sub-processors must be consistent with the applicable service agreement, DPA, the Client’s documented instructions and applicable law. We take reasonable steps to ensure that recipients who process Personal Data on our behalf are subject to appropriate contractual, confidentiality and security obligations.

8.International data transfers

Airsenseinc serves clients and customers in Nigeria and other markets and may use technology providers, suppliers and business partners located in different countries. As a result, Personal Data may be transferred to, stored in, or accessed from a country other than the country in which it was collected. International transfers may arise when we provide outsourcing services to international Clients, coordinate concierge arrangements with overseas suppliers, use cloud-based business systems, or engage approved service providers operating across borders.

Where Personal Data is transferred internationally, we will assess the applicable legal requirements and implement the safeguards required for the relevant transfer. Depending on the countries involved, the nature of the data and the applicable law, these safeguards may include:

• transfers to countries recognised as providing an adequate level of data protection, where the relevant legal requirements are satisfied;
• appropriate contractual safeguards, including standard contractual clauses or equivalent mechanisms where applicable;
• additional technical, organisational or contractual measures where necessary to protect Personal Data;
• compliance with applicable transfer requirements under the NDPA and relevant regulations, the EU GDPR, the UK GDPR and other applicable data protection laws; and
• other legally recognised transfer mechanisms applicable to the relevant jurisdiction and circumstances.

Where applicable, our contractual arrangements and Data Processing Agreements address international transfers of Client data, including the responsibilities of Airsenseinc, the relevant Client and any approved Sub-processors. International transfers will not remove the protections required by applicable data protection law.

9.Cookies, website technologies and AI

Cookies and similar technologies

Our website may use cookies, pixels, tags, local storage and similar technologies to operate the website, maintain security, remember preferences, understand website performance and, where enabled, support analytics or marketing activities. These technologies may be grouped into the following categories:

• Essential technologies: necessary for core website functions, security and the delivery of services you request.
• Functional technologies: used to remember preferences and improve your website experience.
• Analytics technologies: used to understand how visitors interact with our website and identify opportunities for improvement.
• Marketing technologies: used, where applicable, to measure campaigns or deliver relevant marketing.

Where consent is required for non-essential cookies or similar technologies, we will seek consent before activating them and provide an appropriate way to manage or withdraw that consent. For more information about the technologies we use, their purposes, retention periods and how to manage your preferences, please consult our Cookie Policy and any cookie preference tools provided on the website.

Artificial intelligence and automation

Airsenseinc may use artificial intelligence (AI) and automation tools to support business operations, improve efficiency and assist in delivering agreed services. Depending on the task, these tools may help us organise enquiries, categorise information, draft communications, summarise records, support internal research, analyse operational information or assist with customer service and other workflows. Where we provide outsourcing services, AI tools may also be used as part of a Client-approved workflow, subject to the agreed service scope, applicable instructions and relevant data protection obligations.

We recognise that AI-generated outputs may be incomplete, inaccurate or inappropriate. We therefore apply human review and oversight where appropriate to the nature and risk of the activity, and AI-generated outputs are not automatically treated as accurate or final. We do not use Personal Data for AI model training by third-party providers unless the use has been appropriately authorised and is permitted by applicable law and the relevant contractual arrangements; we apply safeguards to the use of third-party AI tools and restrict the submission of Personal Data to approved uses. Where we process Client data, our use of AI is subject to the applicable Client agreement, DPA, documented instructions and any agreed restrictions. We do not routinely make decisions producing legal or similarly significant effects about individuals solely through automated processing; where such processing occurs, we will meet the applicable transparency, review and other legal requirements.

10.Data security and retention

Data security

Airsenseinc takes reasonable technical and organisational measures designed to protect Personal Data against unauthorised access, disclosure, alteration, loss, destruction or other forms of unlawful processing. Depending on the systems used, the nature of the information and the risks involved, these measures may include:

• access controls and least-privilege permissions;
• authentication and account security measures;
• encryption where appropriate;
• confidentiality obligations and relevant personnel training;
• security monitoring and logging where available and appropriate;
• secure data transfer, storage and disposal practices;
• backup, recovery and business continuity arrangements;
• vendor assessment and appropriate contractual safeguards; and
• procedures for identifying, investigating and responding to security incidents.

We review our security measures as appropriate to the risks associated with our operations and the Personal Data we process. No method of electronic transmission, storage or processing is completely secure, and although we take reasonable steps to protect Personal Data, we cannot guarantee absolute security. Where a Personal Data breach occurs, we will assess the incident and take the actions required by applicable law, including notification to relevant authorities or affected individuals where legally required.

Data retention

We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected or processed, including providing services, maintaining business records, resolving disputes, enforcing agreements and meeting applicable legal, tax, accounting, regulatory and reporting requirements. Retention periods vary according to the type of information, the purpose of processing, the nature of the relationship and applicable legal obligations. For example:

• client and account records may be retained for the duration of the business relationship and for a reasonable period afterwards where necessary;
• concierge booking, supplier, payment and transaction records may be retained for service administration, dispute resolution and applicable financial or legal requirements;
• recruitment records may be retained for the recruitment process and, where justified and lawful, for a defined period afterwards;
• marketing contact information may be retained until an individual withdraws consent, objects where applicable, or the information is no longer required, subject to lawful recordkeeping needs;
• website and security logs may be retained for periods appropriate to their operational, analytical or security purposes; and
• client data processed on behalf of an outsourcing Client is retained, returned or deleted in accordance with the applicable agreement, DPA, Client instructions and legal requirements.

When Personal Data is no longer required, we will take reasonable steps to delete it, securely dispose of it or anonymise it, unless retention is required or permitted by applicable law. Where deletion from backups or archived systems cannot be immediate, the information will remain subject to appropriate protections until it can be removed in accordance with our retention procedures. Our detailed retention periods and disposal procedures may be set out in a separate Data Retention and Deletion Policy.

11.Your data protection rights

Depending on your location, the applicable data protection law and our role in processing your Personal Data, you may have the right to:

• be informed about how your Personal Data is collected and used;
• access your Personal Data and request a copy of the information we hold about you;
• request correction of inaccurate, incomplete or outdated Personal Data;
• request erasure of your Personal Data where the applicable legal conditions are satisfied;
• request restriction of processing in circumstances provided by law;
• object to processing based on legitimate interests or other applicable grounds, including direct marketing where relevant;
• request data portability where the right applies;
• withdraw consent where processing is based on consent (withdrawal does not affect the lawfulness of processing carried out before withdrawal);
• request human intervention or challenge certain automated decisions where applicable law provides those rights; and
• raise a complaint with the relevant data protection supervisory authority.

These rights are not absolute and may be subject to legal exceptions, competing rights, recordkeeping obligations and the circumstances of the request.

How to exercise your rights

To exercise your rights or ask a question about the handling of your Personal Data, contact us using the details in section 13. Please explain your request and provide sufficient information for us to identify the relevant records and verify your identity where reasonably necessary. We will review and respond to requests within the timeframes required by applicable law. Requests are generally handled without charge, although applicable law may permit a reasonable fee or refusal in limited circumstances, such as where a request is manifestly unfounded or excessive.

When we process data for a Client

If your Personal Data was collected by one of our outsourcing Clients and we process it on that Client’s behalf, the Client may be the appropriate party to receive and decide your request. Where we receive such a request, we will handle it in accordance with our contractual obligations and applicable law, including referring it to the relevant Client where appropriate. You may also lodge a complaint with the relevant supervisory authority. In Nigeria, this may include the Nigeria Data Protection Commission (NDPC); depending on your location, another competent national or regional authority may be relevant.

12.Marketing, children and automated decisions

Marketing communications

Airsenseinc may use business contact information to communicate with prospective and existing clients about our services, relevant updates, industry insights, events and other business-related information, subject to applicable law. We will obtain consent where required and rely on legitimate interests only where legally permitted and appropriate. We will respect objections and unsubscribe requests and provide an appropriate means to opt out. Where required, marketing emails will include an unsubscribe mechanism. Opting out of marketing will not prevent us from sending essential service messages, transactional communications, security notices or other communications that we are legally entitled or required to send. We do not sell your contact information to third parties for their independent marketing purposes.

Children’s personal data

Our website and services are primarily designed for businesses, professionals, adult customers and individuals seeking outsourcing or concierge services. They are not intended to encourage children to provide Personal Data unnecessarily. Some concierge arrangements, travel bookings or family-related requests may involve information about a child where this is necessary to fulfil a legitimate service request, such as an authorised travel or accommodation arrangement; in such cases, we will handle the information in accordance with applicable law, appropriate safeguards and any relevant requirements concerning parental or guardian authorisation. We do not knowingly collect children’s Personal Data for purposes that are unlawful or incompatible with applicable legal requirements, and if we become aware that Personal Data has been collected unlawfully, we will assess the circumstances and take appropriate steps, which may include deleting the information where required.

Automated decision-making

We may use automated tools to support operational activities, organise information and improve service delivery. However, we do not routinely make decisions about individuals solely through automated processing where those decisions produce legal or similarly significant effects. If such processing is introduced, we will provide the information, safeguards and rights required by applicable law, including human intervention or review and the ability to challenge the decision where those rights apply. Where AI tools assist with customer service, Trust & Safety, concierge coordination or other managed operations, the nature of human oversight will depend on the task, the level of risk, the agreed service scope and applicable legal requirements.

13.Contact details and changes

Contact Airsenseinc

If you have questions about this Privacy Policy, how we handle Personal Data, or how to exercise your data protection rights, you can contact us using the details below.

This Privacy Policy applies to the website and the services presented under Airsenseinc, including Business Outsourcing and Corporate Concierge, unless a separate privacy notice or contractual arrangement expressly applies to a particular service or processing activity. For requests concerning Personal Data processed by Airsenseinc on behalf of a Client, we may need to coordinate with that Client to respond appropriately.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, business operations, technology, data processing practices or legal and regulatory requirements. When we make changes, we will update the effective date or version information displayed with the Policy. Where a change is material and notification is required or appropriate, we will notify affected individuals through our website, email, or another suitable communication channel. We encourage you to review this Policy periodically to understand how Airsenseinc handles Personal Data.