Effective Date: March 3, 2025

Last Updated: April 2, 2025

This Privacy Policy (“Policy”) governs the manner in which AIRA (“we,” “us,” “our”) collects, uses, retains, discloses, and safeguards personal and sensitive information of individuals and organizations (“you,” “your,” “Data Subjects”) in accordance with applicable data protection laws, including but not limited to Republic Act No. 10173 (the Data Privacy Act of 2012 of the Republic of the Philippines), General Data Protection Regulation (GDPR), and any other relevant jurisdictional statutes.

By accessing or using the AIRA platform, its services, website, or associated applications (collectively, the “Services”), you explicitly acknowledge that you have read, understood, and agreed to the terms of this Policy.


1. Definitions

Personal Information – Any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained.

Sensitive Personal Information – Includes, but is not limited to, information about an individual’s health, age, government-issued identifiers, race, ethnic origin, or affiliations.

Processing – Any operation or set of operations performed upon personal data including, but not limited to, collection, recording, organization, storage, updating, retrieval, consultation, use, consolidation, disclosure, or destruction.


2. Scope and Application

This Policy applies to all individuals whose personal data are processed by AIRA, including but not limited to:

• Users of the AIRA website or mobile applications

• Clients, partners, vendors, and government agencies

• Individuals involved in incidents reported through AIRA’s Command Center

• Data collected from AI interactions, incident reporting, and analytics


3. Collection of Information

We collect data in the following categories:

3.1. Personal Information

May include:

• Full name

• Contact information (email, phone number)

• Government-issued ID or reference numbers (when required by law)

• Organization or agency affiliation

• User credentials (stored in encrypted format)

3.2. Sensitive Personal Information

Only when strictly necessary and with appropriate safeguards:

• Incident-related audio, images, and video

• Geolocation data tied to incident reporting

• Voice recordings for AI analysis

• Facial recognition data (with prior informed consent)

3.3. System and Usage Data

Automatically collected when using our services:

• IP addresses

• Browser type and version

• Operating system and device type

• Date and time of access

• User interactions, queries, and command logs

3.4. Incident and AI Interaction Data

• Incident metadata, reports, classifications

• AI-generated summaries, analyses, and predictions

• Tags, categories, and annotations created or inferred by AIRA


4. Lawful Basis for Processing

We process personal data under one or more of the following legal bases:

Consent – freely given, specific, informed, and unambiguous

Performance of a contract – to deliver services as agreed

Compliance with legal obligations – including law enforcement and public interest reporting

Legitimate interest – to improve our systems, enhance user experience, and ensure security

Vital interest – for protection of life or safety in emergencies


5. Purpose of Data Processing

Your data may be processed for the following purposes:

• Identification, verification, and authentication

• Incident tracking, AI-powered analysis, and real-time response

• Predictive risk assessment and pattern detection

• Communication, service updates, or support

• Research, development, and system improvement

• Legal and regulatory compliance

• Security monitoring, auditing, and fraud prevention


6. Data Retention and Disposal

• Personal data will be retained only as long as necessary for the purposes outlined above, or as required by law.

• AIRA applies strict retention schedules and automatic purging protocols for obsolete or irrelevant data.

• Anonymized and aggregated data may be retained indefinitely for research and model training.


7. Data Sharing and Disclosure

We do not sell personal data. Disclosure may occur under the following conditions:

Authorized Government Entities – For public safety, emergency response, or lawful investigations

Third-party Service Providers – Cloud storage, analytics, AI infrastructure (bound by Data Processing Agreements)

Affiliates and Partners – Only with user consent or contractual agreement

Legal Obligations – Pursuant to valid legal process (e.g., subpoena, court order)

Mergers or Acquisitions – Subject to notification and new policy application

All third parties are contractually bound to process data securely, lawfully, and confidentially.


8. Data Subject Rights

You have the right to exercise the following, subject to verification:

Right to be informed

Right to access your data

Right to rectification

Right to erasure or “right to be forgotten”

Right to object or withdraw consent

Right to data portability

Right to file a complaint with the National Privacy Commission (NPC) or relevant authority

To exercise your rights, contact our Data Protection Officer via the details in Section 11.


9. Data Security and Safeguards

We implement organizational, technical, and physical security measures, including:

• SSL encryption and HTTPS for data in transit

• Encrypted data at rest using secure servers

• Multi-factor authentication and role-based access controls

• Audit logs and breach detection systems

• Regular security audits, penetration testing, and patching

• Compliance with ISO/IEC 27001 standards where applicable

In the event of a data breach, we will notify affected individuals and authorities within the prescribed timeframe.


10. International Data Transfers

Where applicable, data may be transferred outside the Philippines or your jurisdiction to service providers or cloud infrastructure partners, subject to:

• Adequate level of data protection

• Binding contractual clauses

• Cross-border data transfer agreements in line with legal standards (e.g., GDPR Art. 46)


11. Contact Information

For privacy inquiries, data access requests, or complaints, please contact:

Data Protection Officer

AIRA – Adaptive Intelligence Response Agent

Atty Rose

commandcenter@airalabs.ai

You may also contact the National Privacy Commission at https://privacy.gov.ph for concerns regarding the Data Privacy Act.


12. Policy Updates

We reserve the right to amend this Privacy Policy at any time. All changes will be posted on our official website and, where applicable, notified to you directly. Continued use of our services after any update constitutes your acceptance of the revised policy.


By using AIRA’s services, you acknowledge that you have read, understood, and agreed to this Privacy Policy.