AirFunders. The Community Based Pension Support Scheme.



Welcome to the AirFunder’s Privacy and Cookie Policy. AirFunders respects your privacy and is committed to protecting your personal data. This Privacy and Cookie Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this Privacy and Cookie Policy.

You will not be able to activate The AirFund services unless you agree to this Privacy and Cookie Policy.















The AirFund is operated and managed by AirFunders Ltd, a private limited company incorporated in Scotland with company number SC628045 and whose registered address is at 4 Hope Street, Edinburgh, Scotland, EH2 4DB. In this Privacy and Cookie Policy, “we”, “us”, “our” or “AirFunders” refers to AirFunders Ltd.

AirFunders Ltd is not registered with or authorised by the Financial Conduct Authority, and The AirFund is currently in its testing phase. In the situation where The AirFund does not proceed to full launch after the testing phase, any information relating to you that the AirFunders has obtained during the initial testing phase will be destroyed and/or returned to you. In the situation where The AirFund proceeds to a full launch, any information relating to you that the AirFunders has obtained during the initial testing phase will be retained.



This Privacy and Cookie Policy aims to give you information on how AirFunders collects and processes your personal data through your use of this website, including any data you may provide through this website when you (a) sign up to our newsletter or any other services, (b) purchase a service, (c) take part in a competition, and/or (d) your other interactions with AirFunders.

This website is not intended for children and we do not knowingly collect data relating to children, or direct marketing at children.

It is important that you read this Privacy and Cookie Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy and Cookie Policy supplements other notices and privacy policies and is not intended to override them.



AirFunders Ltd is the data controller and responsible for your personal data.



If you have any questions about this Privacy and Cookie Policy or our privacy practices, including any requests to exercise your legal rights, please contact us in the following ways:


Full name of legal entity: AirFunders Ltd

Company number: SC628045

Registered address: 4 Hope Street, Edinburgh, Scotland, EH2 4DB

Email address:

Telephone: 0845 8622382


Should you have any concerns in relation to our use of your personal data, we would appreciate the chance to deal with your concerns before you approach the supervisory authority, and so please contact us in the first instance. However, you have the right to make a complaint at any time to the supervisory authority for data protection issues in the EU Member State in which you reside.

In the United Kingdom, the independent authority is the Information Commissioner’s Office whose contact details are:


Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow, Cheshire



Telephone: +44 0303 123 1113

Fax: +44 01625 524510




We keep our Privacy and Cookie Policy under regular review and will publish new versions of the policy on our website. Use of The AirFund services after the date of your being notified of any such amended Privacy and Cookie Policy will constitute acceptance of such revised terms and conditions. This version was last updated on 11th March 2020

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.



This website may include links to third party websites, plug-ins and applications (hereinafter collectively referred to as “Third Party Services”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third Party Services and are not responsible for their privacy statements. When you leave our website or use any Third Party Services, we encourage you to read the privacy policy and any other relevant policies of every Third Party Service you visit or use.



Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes, for example, your first name and last name.

  • Contact Data includes, for example, billing address, delivery address, email address and telephone numbers.

  • Transaction Data includes, for example, details about services you have purchased or signed up to from us.

  • Marketing and Communications Data includes, for example, your preferences in receiving marketing from us and our third parties and your communication preferences.

We reserve the right to collect, use, share, and sell Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or funds being donated through The AirFund. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookie Policy.

An Internet Protocol (IP) address is a number that is automatically assigned to your computer whenever you are surfing the internet. Internet servers automatically identify your computer by its IP address. If you contact us electronically, we may collect your electronic information identifier, for example your IP address or telephone number supplied by your service provider. This would be for the purposes of system administration, to analyse Aggregated Data, and to audit the use and avoid the abuse of our services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.



By registering a payment card in connection with transaction monitoring, you authorise AirFunders to share your payment card information with The IDCO. Ltd (trading as Direct>D) and other necessary payment service providers, such as Visa, MasterCard, American Express, (Payment Service Providers) to confirm your enrolment. You authorise the Payment Service Providers to monitor transactions on your registered card(s) to identify purchases in order to determine whether you have qualified for an offer linked to your payment card, and for the Payment Service Providers to share such transaction details with Direct>D to enable your card-linked offer(s) and target offers that may be of interest to you.

You may opt-out of transaction monitoring on the payment card(s) you have registered at any time by sending your request by email to



Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us, or may not be able to provide services to you, but we will notify you if this is the case at the time.




We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you, for example:

  • Apply for our services;

  • Request marketing to be sent to you;

  • Enter a survey; or

  • Give us feedback or contact us.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:

    • Analytics providers such as Google based inside and outside the EU; and/or

    • Search information providers based inside and outside the EU.

  • Contact Data and Transaction Data from providers of technical, payment and delivery services.

  • Identity and Contact Data from publicly available sources such as the Electoral Register based inside the EU.



We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have given us your consent to process and use your personal data.

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

You have the right to withdraw consent to marketing at any time by contacting us.

From time to time we may change the way we use your information. Where such change is not necessary to perform a contract with you and we believe you may not reasonably expect such a change, we will contact you to inform you of the changes.



We will process your personal data only where there is a lawful basis to do so, specifically:

  • Where we need to perform the contract with you, including:

    • using your information to provide, or contact you regarding, your membership or any other service; and

    • updating you with any changes to the contract between us.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, including;

    • to deliver relevant content to you;

    • to improve our service offering;

    • to make suggestions and recommendations to you about goods or services that may be of interest to you; and

    • to establish, exercise and/or defend our legal rights including in any legal proceedings.

  • Where we need to comply with a legal or regulatory obligation, including:

    • complying with any applicable regulatory requirements in terms of anti-money laundering rules;

    • undertaking conflict of interest checks; or

    • data protection rules.

  • Where you have consented to the particular use of your data, including:

    • sending you marketing emails; and

    • taking part in surveys.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

You understand that:

  • The information you provide to us will be used by us for the direct marketing of cash rewards offers and other related offers to you.

  • Some of the information provided by you to us will be shared by us with External Third Parties, including some reward suppliers for the purposes of making reward offers to you on a real-time basis and otherwise.

  • Information which you provide. To or is collected by us may be provided to External Third Parties to assist in market research or to optimise their businesses.

  • We will use information which you provide, or is collected by us, to enable us to conduct trend analyses and profiling to improve upon areas such as (a) fraud prevention and detection, (b) the accuracy of underwriting practices and pricing, (c) claims management and detection, (d) the development of products and services, and (e) profiling and behaviour analyses.

  • Where you sign into The AirFund services using a third party or social media platform, for example Facebook, then, subject to your agreement at appropriate points, we may have access to your public information provided by you to that third party.



We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. In order to improve our service and provide you with the best experience, we may from time to time send a request for feedback. We may use a partner feedback specialist to obtain your feedback. Any shared information between partners will be clearly stated and your reviews can remain anonymous on request if published.



We may use your Identity Data and Contact Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.



We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.



You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.



We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.



We may share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy and Cookie Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.



Some of our External Third Parties may be based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


7.         DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.




We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.



Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.



You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.



We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.



We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


10.        COOKIES

Cookies are small text files placed on your browser and are commonly used on the Internet. There are various types of cookies which perform different functions, such as remembering which items you have placed in your shopping basket or analysing your browsing behaviour to enable advertisers to present you with adverts more relevant to you and your interests.

Cookies are used to capture basic information about cash reward transactions that you make, and to improve your experience. If cookies are disabled your cash reward will not be tracked and you will not receive a cash reward for any transaction. In addition, the functionality of your account may be affected.

Please note that if you disable cookies, our website functionality may be impaired and prevent you from collecting your cash rewards.



Most web browsers will accept cookies, but if you would prefer we did not collect data by this method, you can disable this function within your browser settings. Your web browser service provider will be able to assist with your browser settings. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies.



We use cookies to:

  • Collect information that will help us to distinguish visitors, to understand visitors’ browsing habits on our website and to improve their experience.

  • Compile statistical reports on website activity, for example numbers of visitors and the pages they visit.

  • Collect information that will allow us to tailor advertising to make it more relevant for you, based on your previous interactions with our website.

  • Collect information to help improve your experience on future visits.

  • Remember information about you when you visit our site. Some of the cookies are essential in order to provide our services to you.


The following types of cookies may be used during your visit to our website:

  • Strictly necessary cookies.

  • Performance cookies.

  • Functionality cookies.

  • Targeting cookies.


Some of our websites also include third party cookies in any of the above categories, which are cookies not set by The AirFund.

We update our site frequently and sometimes that involves some changes in the cookies we have listed above. We try our best to keep this list up-to-date



These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.



These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the website, all of which enable us to see how visitors use the website in order to improve the way that our website works. These cookies are used to improve how our website works and to provide necessary servicing analytics



These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a website may be able to provide you with news or updates relevant to the products and services you buy. These cookies can also be used to remember changes you've made to text size, font and other parts of web pages that you can customise.

They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.



These cookies collect several pieces of information about your browsing habits. They are usually placed by advertising networks rather than website operators. They remember that you have visited a website and share this information with other organisations such as advertisers. They do this in order to provide you with targeted adverts more relevant to you and your interests. Quite often they will be linked to site functionality provided by the other organisation. Although the cookies can track your visits around the Internet they do not usually know who you are.

Without these cookies, online advertisements you encounter will be less relevant to you and your interests. These cookies will usually be third party cookies, although if you are visiting the advertising network's own website, it is technically possible these could be first party cookies. These cookies can be associated with services provided by the third party, but this is not always the case. All information these cookies collect is anonymised, although they contain a unique key that is able to distinguish individual user browsing habits or store a code that can be translated into a set of browsing habits or preferences. In general, the third party’s privacy and cookie policy on their website will indicate if the cookie is being used as part of an advertising network.



We may use Graphics Interchange Format (GIFs) and similar tools. All data derived from the use of such technology is anonymised and does not gather or pass personal data outside the website.

We may acquire information about individuals from other sources and add such information to our house files for the same purposes as for information generally. We will only obtain information from sites such as Facebook, Instagram and Twitter where you have agreed to give us such access by means of your privacy settings in the social media site. We will notify you should we acquire data about you from any third party source, other than that collected as a result of your use of The AirFund services as set out in this Privacy and Cookie Policy.

11.        GLOSSARY


Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.




  • Service providers acting as processors based inside and outside the EU, including in the United States, who provide IT and system administration services and secure cloud-based information storage services.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based inside and

  • outside the EU, including in the United Kingdom, who provide consultancy, banking, legal, insurance and accounting services.

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COMPANY REG SC628045 TEL 0845 8622382