These Terms & Policies govern the provision of all services by AerEthos, including yearbook design and production, the AerEthos Vision platform, graduation products, and any related services (collectively, the "Services"). They apply to all schools, students, parents, and other individuals who engage with AerEthos in any capacity.
These policies are compliant with the General Data Protection Regulation (GDPR) (EU) 2016/679, the Data Protection Acts 1988–2018 (Ireland), and applicable Irish and EU consumer and commercial law.
Where AerEthos acts as a data processor on behalf of a school (the data controller), the applicable controller–processor terms are set out in the separate Data Processing Addendum. These Terms operate alongside, and do not replace, the DPA.
AerEthos is a memory publishing company providing yearbook design, production, and digital memory platform services to schools and educational institutions in Ireland and internationally.
Principal contact: Nathan Sfendji — nathan@aerethos.com
Registration status: AerEthos is currently operating prior to formal company registration. A registered address and company number have not yet been assigned. All agreements and obligations are fully valid and enforceable regardless of registration status.
Jurisdiction: Ireland / European Union. These policies are governed by Irish law. Any disputes arising from the use of AerEthos services are subject to the exclusive jurisdiction of the Irish courts, without prejudice to any mandatory consumer protection rights you may have in your country of residence.
When acting as your data processor, AerEthos processes personal data strictly on the school's documented instructions. Categories of personal data processed include:
Special category data: AerEthos does not intentionally collect special category data (health, religion, ethnicity, etc.). Content submitted by students may incidentally contain such data. AerEthos processes this only as strictly necessary to deliver the agreed service and applies data minimisation throughout.
The school, as data controller, is responsible for ensuring appropriate consents and transparency are provided to students and parents before data is shared with AerEthos. AerEthos provides a template consent notice and Data Processing Addendum for this purpose.
AerEthos uses sub-processors based in the United States. Where personal data is transferred outside the European Economic Area, AerEthos relies on one or more of the following transfer mechanisms:
Documentation of transfer mechanisms for each sub-processor is available to schools on request. AerEthos monitors the legal landscape regarding international transfers on an ongoing basis and will update transfer mechanisms as required.
To exercise any of these rights, contact: nathan@aerethos.com. Requests will be acknowledged within 72 hours and fulfilled within one calendar month (extendable by two further months for complex requests, with notice).
Where AerEthos acts as a data processor for a school, data subject requests should be directed to the school as data controller in the first instance. AerEthos will assist schools in fulfilling their obligations under Article 28(3)(e) GDPR.
AerEthos processes personal data relating to minors (persons under 18 years of age) in the course of providing yearbook services. This processing occurs solely on the instruction of the school as data controller, and is limited to what is strictly necessary for the yearbook and Vision services.
Responsibility of schools: As data controller, the school is responsible for ensuring that appropriate notices are provided to students (and, where required, their parents or guardians) before student data is shared with AerEthos. AerEthos provides a template privacy notice and consent form for this purpose on request.
Direct processing by AerEthos: AerEthos does not knowingly collect data directly from individuals under 16 without school mediation. The student submission system is accessed through a school-issued link — it is not publicly accessible. AerEthos does not create accounts for students under 16.
Marketing: AerEthos does not direct marketing communications to individuals under 18 and does not use student data submitted through yearbook production for any marketing purpose without separate, explicit consent from the student (and parent/guardian where required).
AerEthos reserves the right to update these policies at any time. The "Last updated" date at the top of this page reflects the date of the most recent material change.
For material changes (those that meaningfully affect how we process personal data or the rights of data subjects), AerEthos will: provide at least 30 days' notice to active school partners via email; update this page with a summary of changes; and, where required by GDPR, seek fresh consent or update the Data Processing Addendum.
Continued use of AerEthos services after the effective date of a policy change constitutes acceptance of the updated terms. Schools may terminate the service agreement without penalty if they object to material policy changes, provided written notice is given within 30 days of the change notice.
You have the right to lodge a complaint with the Data Protection Commission (DPC) at any time if you believe your data protection rights have been infringed. We would however ask that you contact us in the first instance so we have the opportunity to address your concern directly.