SkyKick, Inc. Privacy Policy

Modifications

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage). We encourage you to review the Privacy Policy whenever you access the SkyKick Site to stay informed about our information practices and the ways you can help protect your privacy.

Collection of Information

Information You Provide Us. We collect information you provide directly to us. For example, we collect information when you submit content to the SkyKick Site, request information about SkyKick’s products and services or otherwise communicate with us. The types of information we may collect include your name, email address and any other information you choose to provide.

Information We Collect Automatically When You Use the SkyKick Site. When you access or use the SkyKick Site, we automatically collect information about you, including:

• Log Information: We log information about your use of the SkyKick Site, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to the SkyKick Site.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the SkyKick Site and your experience, see which areas and features of the SkyKick Site are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the SkyKick Site or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see “Your Choices” below.

Information We Collect From Other Sources

We may also obtain information from other sources and combine that with information we collect through the SkyKick Site.

Use of Information

We may use information about you for various purposes, including to:

• Provide, maintain and improve the SkyKick Site;
• Respond to your comments, questions and requests;
• Communicate with you about SkyKick Site, offers, promotions, rewards, and events offered by SkyKick and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage and activities in connection with the SkyKick Site;
• Personalize and improve the SkyKick Site and provide advertisements, content or features that match user profiles or interests;
• Link or combine with information we get from others to help understand your needs and provide you with better service; and
• Carry out any other purpose for which the information was collected.

SkyKick is based in the United States and the information we collect is governed by U.S. law. As a result, we are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). By accessing or using the SkyKick Site or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation. This includes requests by which to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of SkyKick or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or
• With your consent or at your direction, including if we notify you through the SkyKick Site that the information you provide will be shared in a particular manner and you provide such information.

Currently, we do not share your information with any vendors, consultants or other service providers who would need access to such information to carry out work on our behalf. Consistent with our long-standing commitment to privacy and transparency, any such future change to this policy will:

• Only include aggregated or de-identified information.
• Be accompanied by an unambiguous opt-in mechanism.
• Be reflected clearly in our data privacy policy.

Social Sharing Features

The SkyKick Site may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on the SkyKick Site with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Provided by Others

We may contract vendors to serve advertisements and/or marketing messaging on our behalf and to provide analytics on users’ activity on the SkyKick Site and on the sites on which the advertising appears. These entities may use cookies, web beacons, and other technologies to collect information which may include IP addresses, web browsers, and site behavior (e.g. pages viewed, time on pages, etc.). This information is used to target content to each user’s interests for a more relevant and personalized user experience.

For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices.

Data Transfer; EU-U.S. Privacy Shield Framework

SkyKick is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under local law.

SkyKick complies with the EU-U.S. Privacy Shield Framework and 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 the European Union and Switzerland to the United States. SkyKick has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy 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/

As noted in the “Sharing of Information” above, we may in future transfer information – including data from the EU, EEA or Switzerland – to our vendors, consultants and other service providers who need access to such data to carry out work on our behalf.

Under certain circumstances, we may remain liable for the acts of those third-party service providers for their handling of EU, EEA or Swiss Data that we transfer to them. Under certain circumstances, we may be required to disclose EU, EEA or Swiss Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Please refer to the remainder of our Privacy Policy for further information about how we collect, use and disclose EU, EEA or Swiss Data, including the purposes for which we use and disclose EU, EEA or Swiss Data.

EU, EEA and Swiss individuals have rights to access personal data about them, and to limit use and disclosure of their personal data. If you are an EU, EEA or Swiss national and believe SkyKick holds data about you, and wish to request access (or to limit use or disclosure) of such data, you can submit a written request to the point of contact listed in the “Contact Us” section below. If the requested data is information we process on behalf of customers, please include the name of the applicable customer in your request; we will refer the request to that customer to respond directly to you and will support them as needed to respond to your request. We will respond to all requests within a reasonable timeframe.

In compliance with the Privacy Shield Principles, SkyKick commits to resolve complaints about our collection or use of your personal information. EU, EEA and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Data Privacy Officer for Europe:

Gerard Doeswijk

Data Privacy Officer EU & EEA Email:

DataPrivacy@SkyKick.com

SkyKick has further committed to refer any unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Should the recourse through JAMS not provide you with a satisfactory resolution you may have the possibility, under certain conditions, to invoke binding arbitration through the so-called arbitration panel. Consistent with applicable law, the U.S. Department of Commerce and the European Commission will develop a list of at least 20 arbitrators, chosen based on independence, integrity, and expertise. To learn more about the Privacy Shield program, please visit www.privacyshield.gov. To learn more about our certification, view SkyKick in the Privacy Shield List.

Security

SkyKick takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Rights and Choices

Your rights.

As an EU, EEA or Swiss national you have specific rights with regards to the data we collect. Any EU, EEA or Swiss national may request to have data which is stored by SkyKick to be updated, corrected or deleted, provided there is a legal ground to do this. Note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Your choices

We offer you a number of options and choices for limiting the use and disclosure of your personal data with regards to the data we collect:

• Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Removing or rejecting browser cookies does not necessarily affect third party flash cookies used in connection with the SkyKick Site. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the SkyKick Site.
• Promotional Communications. You may opt out of receiving promotional emails or messages from SkyKick by following the instructions in those emails or messages. If you opt out, we may still send you non-promotional communications, such as those about our ongoing business relationship.

Contact Us

Should you wish to invoke any of your rights as an EU, EEA or Swiss national or if you have any questions about this Privacy Policy, please contact us at DataPrivacy@SkyKick.com.