MovePerX℠ is a service provided by Aires to provide negotiated and discounted rates to the general public.
- Aires is the data controller and determines purpose and means of processing.
- The purpose of processing is to provide contact information of Aires’ vendors to consumers that wish to be connected.
- The means of processing includes the Aires MovePerX℠ website, Zoho Forms Creator, Hubspot hosting services, and email.
- Lawfulness of processing is obtained through consent from the data subject
- Data subject is any employee of Client, friend, or family member of a Client’s employee. Data subjects self-identify as a citizen of the European Union or California at form submission.
- Disposal: PII will be disposed of as requested by the data subject, or after 2 years.
MovePerX℠ Privacy Notice
Aires (“Aires,” “we,” or “us”) is a global mobility and relocation company. We offer MovePerX℠ to anyone. MovePerX℠ is a free membership club. With MovePerX℠ you get exclusive access to a proven independent network of real estate, mortgage, and household goods shipping partners to assist you. MovePerX℠ members benefit from negotiated discounts and rebates secured by us, and gain access to preferred supply chain members who provide services to you.
We own and operate MovePerX℠ and this website. This privacy notice tells you how we collect, use, disclose and store information about you when you interact with or use MovePerX℠.
What information does Aires collect?
We gather various types of information, including information that identifies or may identify you as an individual (“Personal Information”) as explained in more detail below.
Information You Provide to Us:
From MovePerX℠: We may collect any Personal Information that you choose to send to us or provide to us (for example, information provided through our “Now Let’s Get Moving” [or similar] online form). If you contact us through this Website, we will keep a record of our correspondence.
Information We Automatically Collect:
When you use the Website: When you visit the Websites, we collect certain information related to your device, such as your device’s IP address, referring website, what pages your device visited, and the time that your device visited our Website.
When you use MovePerX℠:
Usage information – we keep track of user activity in relation to the types of Services our members use, the configuration of their computers, and performance metrics related to their use of the Services.
Log information – we log information about you, including Internet Protocol (“IP”) address.
Information collected by cookies and other similar technologies – we use various technologies to collect information which may include saving cookies to users’ computers.
How do we use the information?
We will use the information we collect via our Website:
- To administer our Website and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
- To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
- For trend monitoring, marketing and advertising;
- For purposes made clear to you at the time you submit your information – for example, to fulfill your request for information related to selling your house, to provide you with access to one of our specialists, or to provide you with information you have requested about our Services; and
- As part of our efforts to keep our Website secure.
Our use of your Personal Information may be based on our legitimate interest to ensure network and information security, or you consenting to it (e.g., when you submit your information to us).
We may use the information we collect from you for a range of reasons, including to:
- Manage our members’ use of the Services, respond to enquiries and comments, and provide service and support;
- Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities; and
- For any other purposes about which we notify members and users.
We use your Personal Information in this context based on the contract that we have in place with you or our legitimate interest for security purposes (e.g., the prevention and investigation of fraudulent activities). Personal Information will be deleted based on the terms of the contract. You can exercise your rights regarding your personal information by filling out this Web Form.
What are our Privacy Law roles?
We act as a data controller. We collect and process your data based on your consent. We are accountable to your local Data Protection Authority.
Our partners also act as independent data controllers. We connect you with these partners so you can explore and evaluate their offerings. If you decide to take advantage of one of these great deals, you will form an independent privacy relationship with that partner. These partner/controllers are also accountable to your local Data Protection Authority.
You are a data subject. Depending on your jurisdiction, you may have legal rights.
How do we share and disclose information to third parties?
We share and disclose information (including Personal Information) about you in the following limited circumstances:
Partners and other service providers: We may share your information with partners and other service providers with whom we contract to perform tasks on our behalf. These companies include realtors, mortgage providers, household goods shippers, and others.
Protection of Aires and Others: We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of Aires, our employees, our users, or others.
Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
We use appropriate technical, organizational, and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Aires Information Security Management System (ISMS), including MovePerX℠, is ISO/IEC 27001:2013 certified. Our Privacy Information Management System (PIMS) is ISO/IEC 27701:2019 certified as reflected in the certificates found here and here, respectively.
MovePerX℠ is scheduled for an ISO 27701:2019 audit March 20201.
Aires is audited annually and received a SOC 2 report addressing the security, confidentiality, and availability of Aires’s services.
Your Privacy Rights
What choices do I have?
You can always opt not to disclose information to us; however, this information is needed to register with us or to take advantage of your benefits.
You can accept or reject cookies for our Website by adjusting your web browser controls.
We do not send marketing emails.
How Can I Exercise My Data Subject Rights?
If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can fill out this Web Form. Our privacy team will examine your request and respond to you as quickly as possible.
Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
California residents have specific rights under the California Consumer Privacy Act (“CCPA”). For more information and to exercise your rights, please see the section headed “The California Consumer Privacy Act” below.
If you are a resident of the European Economic Area or the United Kingdom, please see the section below headed “Additional Information for users in the European Economic Area and in the United Kingdom” for further information about your privacy rights.
International Data Transfers
Personal Information you submit on this Website will be sent to the United States and processed by us there. We will always protect your information in accordance with this Privacy Notice wherever it is processed.
Information for users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”)
Aires may transfer Personal Information from the EEA or the UK to the United States, including Personal Information we receive from individuals residing in the EEA or the UK who visit our Website, use MovePerX℠, or otherwise interact with us. Please note that for individuals located in the EEA or the UK, the term Personal Information used in this notice is equivalent to the term “Personally Identifiable Information (PII)” under applicable European and UK data protection laws.
When Aires engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or ii) Standard Contractual Clauses issued by the European Commission. The European Commission has determined that the Standard Contractual Clauses provide sufficient safeguards to protect the personal data transferred outside the EU or EEA. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. Aires also continually monitors the circumstances surrounding such transfers to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.
Following the Court of Justice of the European Union’s invalidation of the EU-US Privacy Shield Framework in Case C-311/18 Schrems II, Aires will no longer rely on the EU-US Privacy Shield as a mechanism of international data transfer until further notice.
However, Aires is committed to maintaining its self-certification under the EU-US Privacy Shield Principles and respects its principles, as an additional measure of protection of its users’ privacy, until further notice.
Following the opinion of the Swiss Federal Data Protection and Information Commissioner (FDPIC) of 8 September 2020, Aires will no longer rely on the Swiss-U.S. Privacy Shield as a mechanism of international data transfer until further notice.
However, Aires is committed to maintaining its self-certification under the Swiss Privacy Shield Principles and respects its principles, as an additional measure of protection of its users’ privacy, until further notice.
Additional privacy measures for users in the European Economic Area (“EEA”), United Kingdom (“UK”) and Switzerland
Aires is self-certified to the EU-US Privacy Shield Framework
Please note that despite the Court of Justice of the European Union’s invalidation of the EU-US Privacy Shield Framework as a mechanism for transfers of personal data between the EU and the U.S. in Case C-311/18, Aires maintain its self-certification under the EU-US Privacy Shield Framework and remains committed to complying with the Privacy Shield Principles. For more information one the U.S. Department of Commerce’s continued administration of the Privacy Shield program, please visit https://www.privacyshield.gov/article?id=EU-U-S-Privacy-Shield-Program-Update.
This section sets out the privacy principles we follow with respect to transfers of Personal Information from the EEA or the UK to the United States, including Personal Information we receive from individuals residing in the EEA or the UK who visit our Websites and/or who may use of our Services or otherwise interact with us.
Please note that for individuals located in the EEA or the UK, the term “Personal Information” used in this notice is equivalent to the term “personal data” under applicable European and UK data protection laws.
Aires complies with the EU-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and the UK. Aires has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability with respect to such personal information. If there is any conflict between the policies in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, see the U.S. Department of Commerce’s Privacy Shield website located at https://www.privacyshield.gov. To view our certification on the Privacy Shield list, please visit https://www.privacyshield.gov/list.
In compliance with the EU-U.S. Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Information. Individuals located within the EEA or the UK with inquiries or complaints regarding this Privacy Notice should first contact Aires at: Peter McShea, J.D., Privacy Officer, email@example.com.
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data within 45 days of receiving your complaint. Aires has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to the American Arbitration Association International Centre for Dispute Resolution, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Under certain limited circumstances, individuals in the EEA or the UK may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution (discussed above) have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/.
Aires is subject to the jurisdiction of the U.S. Federal Trade Commission for purposes of Privacy Shield enforcement.
Please note that Aires is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Aires is self-certified to the Swiss-U.S. Privacy Shield Framework
Please note that despite the opinion of the Swiss Federal Data Protection and Information Commissioner (FDPIC) of 8 September 2020, Aires maintains its self-certification under the Swiss Privacy Shield Framework and remains committed to complying with its principles. For more information regarding the U.S. Department of Commerce’s continued administration of the Swiss Privacy Shield program, please visit https://www.privacyshield.gov/article?id=Swiss-U-S-Privacy-Shield-FAQs .
We comply with the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the Swiss-U.S. Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact Aires at: Pete McShea, J.D., Privacy Officer, firstname.lastname@example.org.
Under certain limited circumstances, individuals in Switzerland may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution (discussed above) have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/.
The California Consumer Privacy Act
Under the California Consumer Privacy Act (“CCPA”), California residents have certain rights regarding the personal information that businesses have about them. This includes the rights to request access or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.
Personal Information We Collect
We collect identifiers (such as name, address, email, phone number, and job title), commercial information (such as a record of the services requested), and Internet or other electronic network activity information (such as usage information, IP address, cookie information, and member feedback).
Why We Collect Your Personal Information
We use information to provide the services requested, such as to fulfill a request for quotes for services, provide access to partners, or provide you with information about our services.
We use identifiers and commercial information for general website administration, which includes record keeping, troubleshooting, data analysis, testing, and survey purposes.
We use identifiers, commercial information, and Internet or other electronic network activity to ensure website security.
How We Collect Your Personal Information
We collect identifiers and commercial information directly from you.
We collect Internet or other electronic network activity from your usage of the MovePerX℠ website and its services.
With Whom We Share and Sell Your Personal Information
Aires shares personal information as necessary for certain “business purposes,” as defined by the CCPA (Cal. Civ. Code 1798.140(d)). This includes sharing the information you gave us with service providers.
The Right to Opt-out of Sale
While Aires does not sell personal information in exchange for any monetary consideration, we do share personal information with our partner network that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(2)(a)). Although you direct us to intentionally disclose personal information to interact with our partners, we do not know what additional transfers of your information could be made by our partners.
We support the CCPA and wish to provide you with control over how your personal information is collected and shared.
You have the right to direct Aires to not “sell” your personal information. Click here to learn more and to exercise your right to opt-out.
With respect to cookies, you can customize your browser settings at any time.
Please note that we may retain information as needed in order to comply with legal obligations, enforce agreements, and resolve disputes.
Right to Request Disclosure
You have the right to request disclosure about what categories of personal information Aires has sold or disclosed for a business purpose about you and the categories of third parties to whom the personal information was sold or disclosed. Additionally, you have the right to request disclosure of specific pieces of information. Below is a full list of the information that you can include in your request.
- The categories of personal information that Aires has collected about you;
- The categories of sources from which Aires collected the personal information;
- The business or commercial purpose for collecting or selling the personal information;
- The categories of third parties with whom Aires shares personal information;
- The specific pieces of personal information Aires has collected about you;
- The categories of personal information that Aires disclosed about you for a business purpose; and
- The categories of personal information that Aires has sold about you, as well as the categories of third parties to whom Aires sold the information.
If you would like to exercise your right to request disclosure, please fill out this request form. Our privacy team will examine your request and respond to you as quickly as possible.
Right to Request Deletion
You have the right to request that Aires delete any personal information about your that Aires has collected from you. Please note that there are exceptions where Aires does not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.
If you would like to exercise your right to delete, please fill out this request form request form. Our privacy team will examine your request and respond to you as quickly as possible.
The Right to Non-Discrimination
Aires will not discriminate against you (e.g., through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.
In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your Personal Information. California residents with inquiries or complaints regarding this Privacy Notice should first contact Aires at:
Peter McShea, J.D.
Manager, Risk & Compliance
California and Delaware “Do Not Track” Disclosures
California and Delaware law require Aires to indicate whether it honors “Do Not Track” settings in your browser concerning targeted advertising. Aires adheres to the standards set out in this Privacy Notice and does not monitor or respond to Do Not Track browser requests.
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for this Service or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Information, please contact us at email@example.com.
For your convenience, hyperlinks may be posted that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy notice of each Linked Site that you visit to understand how the information that is collected about you is used and protected.
Changes to the Privacy Notice
We are constantly trying to improve our Websites and Services, so we may need to change this Privacy Notice from time to time as well. We will alert you to material changes (for example, by placing a notice on our Websites and/or by sending you an email [if you have registered your e-mail details with us] when we are required to do so by applicable law). You can see when this Privacy Notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Privacy Notice.
6 Penn Center West
Manager, Risk & Compliance
Peter McShea, J.D.
Email Address: firstname.lastname@example.org
If you have questions, requests, or concerns regarding your privacy and rights, please let us know how we can help.