fine print

Privacy Policy

Privacy Policy

Why have we prepared this Privacy Notice?

At Aircards we understand that privacy is important and are committed to ensuring that personal information is processed in accordance with applicable data protection and privacy laws. We have put together this Privacy Notice which you are currently reading to help you understand what information we collect about users of web Experiences and how we use and share this information. It also contains important information about your rights. The Privacy Notice is an essential part of your engagement with Aircards and it is important that you read it carefully. By engaging with us in the ways set out in this notice, you confirm that you have read and understood the entirety of this notice, as it applies to you.


This Privacy Notice applies to your use of those Aircards Experiences that display or provide an authorised link to this notice.

This Privacy Notice does not extend to any websites or services of third parties which can be accessed from the Aircards website or Experiences, including any links we may provide to social media sites.

What means what?

In this Privacy Notice some of the words we use have capital letters. This is because we have given these words a particular meaning. These words are listed below:

“Anonymous Information” means information that does not identify and cannot reasonably be used to identify a specific individual. When Anonymous Information is linked with Personal Data, this Anonymous Information is normally treated by Aircards as Personal Data.

“Content” means content made available on or via an Aircards Experience. This might include avatars, animation, mini-games, documents, images, links, sound files, videos, text, and other content associated with the experience.

Experience” means any interactive, web-based immersive experience created by Aircards. A reference to an Aircards Experience includes any and all related databases, features, functionality, plug-ins, software and web pages.

“Information” (depending on the context) means any or all information that you or your device send, submit or transmit to Aircards via the Experience. Information also includes information automatically collected by us and information about you, which we obtain from other sources.

“IP Address” means an Internet Protocol address, a number that is automatically assigned to your device when you use the internet and which may vary from session to session.

“Personal Data” means any information we hold about you which could be used to identify who you arewhich includes, but not limited to your name, email, phone number, image, IP Address and may include other information such as identification numbers and location data.

“Third Party Content” means Content which is owned or controlled by a person other than Aircards, including Content which is created by Aircards for a brand, entertainment franchise or other client 

“you” means you, the natural person accessing, browsing, downloading or using any Aircards Experience.

“Aircards” or “we” means Aircards Ltd, a private limited company incorporated in the United Kingdom and registered in England with company number 12558369

“Aircards Website” means the official Aircards website available at

Where we refer to a “person” this includes individuals, companies, corporations, partnerships, limited liability partnerships, co-operatives, associations and other natural and legal persons.

When we use the words “includes” or “including” in this Privacy Notice we are not limiting ourselves in any way and mean “includes or including without limitation”.

Identity of the Data Controller

The data controller is Aircards Ltd, a private limited company incorporated in the United Kingdom and registered in England (company number 12558369). Our contact details are shown below in the section headed “Contacting Us”. Third parties, such as publishers, are the controllers with regard to the processing of your personal information in connection with your use of Third Party Content and, in that capacity, are solely responsible for compliance with applicable data protection and other legislation and regulation with regard to such processing.

Your rights

As a data subject, you have the following rights under UK and EU data protection legislation (including the European General Data Protection Regulation (GDPR)), which we will always work to uphold:

When making a request, please be aware that we may be unable to delete Information that resides in our archives, and the requested removal of certain Information may mean we are no longer able to provide you with all or certain parts of the Aircards Experiences.

Our standard response period for replying to formal data requests is 28 days from receipt of request.

If you have any cause for complaint about our use of your Personal Data, please contact us using the details provided in “Contacting Us” and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (ICO).

 The ICO’s contact details are:
Information Commissioner’s Office
Wycliffe House
Water Lane
Helpline number: 0303 123 1113

 Information that we may collect

As and when you visit, browse or use an Aircards Experience we may collect certain Information from you. Some of this Information may be Personal Data and some of the Information may be Anonymous Information. We use your Information in accordance with the terms of this Privacy Notice.

Below is a list of some of the Information we may collect from you, depending on how you interact with Aircards:

Use of certain features

There are some features of the Aircards Experiences that may require you to provide certain Information about yourself when doing this. This could be one or more of the following items of Personal Data: your name, your email address, your phone number, your country of residence, your selfie image. You will be prompted to voluntarily consent to this collection of data so that you are able to utilise the Aircards Experience.

 User Generated Content

Some features of the Aircards Experiences may allow you to create, submit, post, display, transmit or share content (e.g. photos, videos, comments, messages, and other materials) on or through the Aircards Experience ( “User Generated Content”).

When you use the Aircards Experience we will only collect and store your User Generated Content if it is essential to the operation of that particular Experience.

Some of your User Generated Content may contain personal information about you or other natural persons, e.g. audio, photos or videos featuring you or your friends. We therefore advise you to be selective about what personal information you include in User Generated Content, and not to include any of the following types of personal information in any submission to any publicly available area of the Aircards Experience: telephone numbers, physical addresses, full name or any other information of a sensitive nature. If you upload personal information about or depicting other individuals (e.g. a photo of a friend), it is your responsibility to obtain their consent first.


 Information collected from other sources

We may engage the services of other companies to handle certain tasks relating to the Aircards Experience. This may include payment processing, search engine facilities, storage and serving of content, advertising and marketing, and analytics. These companies may send us Personal Data relating to you. We may also collect information about you from publicly available sources, such as via the internet and social networks, including through public or licensed APIs. If we do collect such information from third parties, we will only use that information in accordance with this Privacy Notice. Equally, these companies may collect personal information directly from you. If they do, that company and not Aircards will be the data controller in respect of any information you provide to them and you should check their privacy policy to find out how they will use your information. 

Analytics and information about your device

When you use the Aircards Experience, our servers will automatically access or collect information from your device (e.g. smartphone), including the following:

We use this Anonymous Information to analyse and optimise your use of the Aircards Experience.

GPS Location Data

Aircards does not currently receive or process any GPS location data provided by you or which we receive from location service providers. We may however wish to do so in the future to tailor the Aircards Experiences offered to users in a particular geographical location. If this becomes the case, we will only process GPS location data for which you have given us your consent, including your GPS location, which were provided by you or which we receive from GPS location service providers, but only for so long as this is necessary for delivering the Aircards Experience and/or to the extent required as permitted by applicable law.

 Legal basis for processing Personal Data

Our legal basis for collecting and using your Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where (i) we need the Personal Data to perform a contract with you; (ii) the processing is in our legitimate interests and not superseded by your rights; (iii) we have a legal obligation to process your Personal Data; or (iv) we have your consent to do so (e.g. you have ticked a box, or signed up for a newsletter).

Under our terms of use for the Aircards Experiences, “performance of contract” as a legal basis for processing your Personal Data refers to when we make the Aircards Experiences available to you, If there is no legal contract between you and Aircards (e.g. because you are a minor), then we will process Personal Data for these purposes on the basis of our legitimate interests.

We process your Personal Data on the basis of our “legitimate interests”, for example, when we provide you with the Aircards Experiences, carry out marketing, keep the Aircarsd Experiences secure, for engineering purposes, analysing users behavior across the Aircards Experiences, providing customer support, and running, growing and developing our business.

We have a “legal obligation” to process your Personal Data when complying with a legal obligation, such as preventing a crime or fraud or maintaining tax records. This ground may also include our obligation under the UK Data Protection Act 2018 and GDPR to protect your Personal Data.

If you have questions about the legal basis for collecting and using your Personal Data, please contact us using the contact information provided in the “Contacting Us” section below.

 Marketing communications

We may use your Information to send you notifications and information about the Aircards Experiences and other Aircards products and services we think may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. If at any time you no longer wish to be contacted for this purpose, please let us know (contact and we will remove you from our mailing list. 

 Where will your information be stored?

Your Personal Data may be transferred to, and processed in, countries other than the country of which you are a resident. These countries may have data protection laws that are different from the laws of your country.

We use Amazon Web Services (“AWS”) to store and process data on our behalf in connection with the Aircards Experiences. We primarily use AWS servers located in Europe to store and process your Information; however AWS also use various servers located around the world to cache data locally and speed up access to Experiences.

We may engage other businesses to carry out data processing on our behalf. For example, we may engage someone to provide payment services, to host the Aircards Experiences, to administer computer vision processing, or to provide analytics services. We will continue to be the data controller in respect of any Personal Data transferred to or shared with such third parties and shall remain responsible for the processing undertaken by them.

The following is a list of the main businesses who currently process data on our behalf in relation to the Aircards Experiences:

Processing purpose(s)
Data Storage Location

Amazon Web Services 
Content hosting & serving
Worldwide; Content may be cached locally to improve content delivery performance

8th Wall
Computer vision and developer tools

Business email and analytics services

We may also share Information between our group countries, which are located in countries worldwide, including the United States.

Transfers outside of Europe

If you use an Aircards Experience while you are outside the European Economic Area (EEA), your Personal Data may be transferred to countries outside the EEA to enable us to provide you with those services. The circumstances in which this may happen are:

If any of our servers are located outside the EEA or our service provider is located outside the EEA (see the table above).

When you use the Aircards Experiences, they are available for use internationally. This means it is possible that any Personal Data contained in your User Generated Content (e.g. your picture) that you publish may be automatically transferred by our servers to a device, server or other computer equipment being used in a country outside the EEA.

Countries outside of the EEA may not have similar data protection laws to the GDPR and UK Data Protection Act. If we do transfer any of your Personal Data outside the EEA (e.g. to a data processor located outside the EEA) we shall take all steps reasonably necessary to ensure that your Personal Data is adequately protected by: (i) only using processors who comply with EU data protection laws; (ii) the use of the European Commission's Standard Contractual Clauses; and (iii) (in the case of transfers to the US) the transfer of Personal Data to service providers and partners that are certified under the EU-US Privacy Shield. 


When might Aircards share your information with others?

We may disclose your Information to or share it with the following types of recipients, including but not limited to:

We will not sell, trade or rent your Personal Data to anyone.

Controlling the use of your information

You may withdraw your consent for Aircards to process your Personal Data for direct marketing purposes at any time by notifying us in writing (an email will suffice).

You can opt-out from the future collection of Information by Aircards in accordance with this Privacy Notice by discontinuing use of the Aircards Experiences. 

Changes of business ownership and control

Aircards may choose to expand or reduce our business and this may involve the sale and/or transfer of control of all or part of Aircards or the Aircards Experiences. Information provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part as one of the transferred assets. The new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use the Information for the purposes for which it was originally supplied to Aircards.

We also reserve the right to disclose de-identified user data to the prospective buyer of such business or assets. 

Links to Non-Aircards Services

The Aircards Experiences may contain links to websites, microsites and other on-line services that are operated by third parties i.e. businesses other than Aircards (collectively, “Third Party Services”). Aircards does not control these Third Party Services and is in no way responsible for their content, or information collection practices. This Privacy Notice DOES NOT apply to your use of any Third Party Services.

Please consult the terms and conditions and privacy policy of any Third Party Service you choose to access to find out how they will collect, use and share your personal information and to establish whether and for what purpose they use cookies and similar technologies. Some Third Party Content contained on or accessible via the Aircards Experiences may operate as links to that third party’s website(s) and as such any information they collect by virtue of your clicking on that link will be collected and used in accordance with the privacy policy of that third party.

How do we keep your Personal Data secure?

Data security is of great importance to Aircards. We have put in place commercially reasonable physical, electronic and managerial security measures to protect your Personal Data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. Specifically, we use the following measures:

Even though we have taken the above security measures given the nature of online communications we cannot 100% ensure the security of your Information or guarantee that your Personal Data will not be accessed, disclosed, altered or destroyed by an unauthorised person who is determined to circumvent our security measures.

How long do we keep your Personal Data for?

We will retain your Personal Data for the duration of your use of the Aircards Experiences and for a reasonable period thereafter for backup, archival and/or audit purposes or for as long as the law otherwise requires. 

Where you have chosen to upload User Generated Content we will need to continue to store your content on our servers for so long as the third party wishes to have access to your content in accordance with any agreement you or Aircards may have entered into with that party.

How can you access your Personal Data?

You have the right to ask for a copy of any of your Personal Data held by us (where such data is actually held by us and we can identify who you are). We will normally provide copies in response to your request free of charge. We do, however, reserve the right to charge a reasonable fee for requests which are manifestly unfounded or excessive, particularly if it is repetitive and for further copies of the same Information.

We will ask you to provide reasonable proof of your identity before we disclose any Information to you.

Children’s Privacy and the Children’s Online Privacy Protection Act (COPPA)

This section of the Privacy Notice applies if any Aircards Experiences are accessed from within the USA or any other country which requires parental consent to be obtained before any collection of personal information from a child under the age of 13.

Aircards does not knowingly collect or solicit personal information from children under the age of 13. The Aircards Experiences and their Content are not intentionally directed at children under the age of 13 and we do not target children under 13 as our primary audience. In the event we learn that we have inadvertently collected personal information from a child under the age of 13, and that child lives in a country which does not permit such collection without prior parental consent, we will delete that information as quickly as possible.

If a parent or legal guardian becomes aware that their child under the age of 13 has provided us with personal information without prior parental consent, please contact us at the address below and we will delete such information from our files.

So we can comply with international privacy laws, we may use age screens for some Experiences. We do not store any individual’s date of birth.

Cookies, analytics and similar technologies

Some Aircards experiences uses cookies via Google Analytics. Google Analytics utilises first-party cookies to provide standard website analytics data.

If our use of cookies involves the processing of Personal Data, the legal basis for this will be our legitimate interests, i.e. to help us to provide you with a good experience when you use the Aircards Experiences (including making them more secure) and to improve the Aircards Experiences by understanding how you use them.

 Changes to our Privacy Notice

The Aircards Experiences, our collection and use of Personal Data and other information, and the laws and regulations which apply will change over time. We reserve the right to make changes to this Privacy Notice. When we update the Privacy Notice, we will post the new version and change the “Last Updated” date. We encourage you to visit this page from time to time for the latest on our information collection practices.

Contacting us

If you have any questions about the Aircards Experiences or this Privacy Notice, please contact us by email or by post using the details below. Please ensure that your query is clear, particularly if it is a request for information about the Personal Data we hold about you.

Postal Address: Aircards Ltd, 3 Waterloo Square, Newcastle Upon Tyne, NE14DR



Applicable law

Irrespective of which country you live in or submit Information from the law which applies to this Privacy Notice shall be the law of England.

Monthyl Recurring Commission

Please read this privacy policy carefully

This privacy policy applies between you, the User of this Website and Great North Digital Ltd, the owner and provider of this Website. Great North Digital Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Definitions and interpretation

In this privacy policy, the following definitions are used:

Collectively all information that you submit to Great North Digital Ltd, Trading as Aircards via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);Data Protection Laws

Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

Great North Digital Ltd, trading as Aircards, or us
the General Data Protection Regulation (EU) 2016/679;Great North Digital Ltd, or Aircards, or us Great North Digital Ltd, a company incorporated in England and Wales whose registered office is at 3 Waterloo Square, Newcastle-upon-tyne, NE1 4DR

UK and EU Cookie Law
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you
any third party that accesses the Website and is not either (i) employed by Great North Digital Ltd, Trading as Aircards and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Great North Digital Ltd, Trading as Aircards and accessing the Website in connection with the provision of such services

the website that you are currently using,, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation:
the singular includes the plural and vice versa;
references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
a reference to a person includes firms, companies, government entities, trusts and partnerships;
"including" is understood to mean "including without limitation";
reference to any statutory provision includes any modification or amendment of it;
the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of Great North Digital Ltd, Trading as Aircards and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Great North Digital Ltd, Trading as Aircards is the "data controller". This means that Great North Digital Ltd, Trading as Aircards determines the purposes for which, and the manner in which, your Data is processed.

Data collected

We may collect the following Data, which includes personal Data, from you:
contact Information such as email addresses and telephone numbers;
demographic information such as postcode, preferences and interests;
IP address (automatically collected);
web browser type and version (automatically collected);
operating system (automatically collected);
in each case, in accordance with this privacy policy.

How we collect Data

We collect Data in the following ways:data is given to us by you;
data is received from other sources; and data is collected automatically.

Data that is given to us by you

Great North Digital Ltd, Trading as Aircards will collect your Data in a number of ways, for example:
when you contact us through the Website, by telephone, post, e-mail or through any other means;
when you use our services;
in each case, in accordance with this privacy policy.
Data that is received from third parties
Great North Digital Ltd, Trading as Aircards will receive Data about you from the following third parties:
Website tracking application;
Data that is received from publicly available third parties sources

We will receive Data about you from the following publicly available third party sources:
Facebook & Twitter;

Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:
we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

Our use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
internal record keeping;improvement of our products / services;
transmission by email of marketing materials that may be of interest to you;
contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
in each case, in accordance with this privacy policy.
We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.

For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.

If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

Who we share Data with

We may share your Data with the following groups of people for the following reasons:our employees, agents and/or professional advisors - For contact, admin and marketing purposes.; in each case, in accordance with this privacy policy.

Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example: access to your account is controlled by a password and a user name that is unique to you. We store your Data on secure servers.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address:

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit Get Safe Online is supported by HM Government and leading businesses.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

You have the following rights in relation to your Data:

Right to access -
the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

Right to correct -
the right to have your Data rectified if it is inaccurate or incomplete.

Right to erase -
the right to request that we delete or remove your Data from our systems.

Right to restrict our use of your Data -
the right to "block" us from using your Data or limit the way in which we can use it.

Right to data portability -
the right to request that we move, copy or transfer your Data.

Right to object -
the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address:

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers outside the European Economic Area

Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, eg by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.Changes of business ownership and control

Great North Digital Ltd, Trading as Aircards may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Great North Digital Ltd, Trading as Aircards. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.CookiesThis Website may place and access certain Cookies on your computer. Great North Digital Ltd, Trading as Aircards uses Cookies to improve your experience of using the Website. Great North Digital Ltd, Trading as Aircards has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Great North Digital Ltd, Trading as Aircards to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.