SkyGeni Privacy Policy

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Sources of Personal Data

We collect Personal Data about you from:

You: When you provide such information directly to us, and wen Personal Data about you is automatically collected in connection with your use of our Services.

Third parties: When they provide us with Personal Data about you. For example, SkyGeni links to other services, such as Salesforce. SkyGeni does not access any information from these third-party services without your authorization, or by the authorization of your organization. You grant SkyGeni this authorization when you connect these services to SkyGeni, or when your organization authorizes these connections on your behalf. To opt out of connecting to these services, contact SkyGeni at privacy@skygeni.com.

Sale of Personal Data

We DO NOT sell your Personal Data.

Information related to data collected for our Clients

Service Provider Collection and Use

SkyGeni collects information under the direction of its clients, and has no direct relationship with the individuals whose personal data it processes.

Choice

We collect information for our clients; if you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly. If you are a client and would like to update your account please contact us at support@skygeni.com.

We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our clients.

Access to Data Controlled by our Clients

SkyGeni acknowledges that you have the right to access your personal information. SkyGeni has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the SkyGeni’s client (the Data Controller). If the client requests SkyGeni to remove the data, we will respond to their request within 30 business days.

Data Retention

SkyGeni will retain personal data we process on behalf of our clients for as long as needed to provide services to our client, subject to any limitations imposed by our agreements with those clients. SkyGeni will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Information collected from you and used by SkyGeni

Notice

SkyGeni will notify you about the purposes for which it collects and uses information about you, how to contact SkyGeni with inquiries or complaints, the types of third parties to whom it discloses personal information, and the choices and means the organization offers individuals for limiting its disclosure. This notice will be provided by this Policy, which is available from SkyGeni’s homepage so that you may review it before you disclose personal information to SkyGeni.

Choice

SkyGeni provides you with the right to opt out whether your personal information is disclosed to a third party, or used for a purpose that is incompatible with the purpose for which it was originally collected or subsequently authorized by you. This Policy clearly describes the ways that SkyGeni uses and discloses your personal information. If you wish to opt out at any time, you may do so by contacting us at privacy@skygeni.com. If you no longer wish to receive newsletters or other promotional email communications from us you may also follow the unsubscribe instructions contained in each of the emails you receive

Personal Information Gathered

The SkyGeni website has various features which allow those interested in SkyGeni and its services to obtain more information about SkyGeni. SkyGeni asks those requesting information about SkyGeni to provide SkyGeni with certain personal contact information that SkyGeni may use to follow up with those interested in its services. The information SkyGeni may collect through the SkyGeni service includes but is not limited to first and last name, company or organization, title or position within the company or organization, phone number, and email address. SkyGeni stores this information and uses this information to respond to requests for information regarding our services and provide support to its customers as well as for SkyGeni’s own marketing purposes. SkyGeni’s use of personal information may include developing aggregated data that (once aggregated) no longer constitutes personal information.

Tracking Technologies

SkyGeni and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, and site functionality.

Onward Transfer

SkyGeni does not disclose personal information submitted to SkyGeni to any third party, except as follows and as otherwise outlined in this Policy:

SkyGeni may disclose personal information to subcontractors engaged by SkyGeni to perform services on its behalf and to any other third party such as fulfillment houses that send marketing information on SkyGeni’s behalf, an email service provider to send out emails on our behalf. Any subcontractors to whom personal information is disclosed are subject to written agreements of confidentiality. We do not sell your personal information to third parties. These companies are authorized to use your personal information only as necessary to provide these services to us. Any subcontractor that receives any personal information of individuals resident in the EU is either itself subject to EU data privacy law, subscribes to the Safe Harbor Principles or another adequacy finding, or has entered into a written agreement with SkyGeni requiring that such third party provide at least the same level of privacy protection as the Safe Harbor standards. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.

SkyGeni reserves the right to disclose personal information if required by law enforcement authorities, subpoena or other court order, or other governmental authority, and (to the extent permitted by law and the Safe Harbor principles) to the extent necessary to protect the legal rights and personal safety of SkyGeni and its employees and agents. In certain situations, SkyGeni may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If SkyGeni is involved in a merger, acquisition, or sale of all or a portion of its assets, your personal information may be disclosed to the successor or acquirer of SkyGeni business. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

 Security

SkyGeni maintains reasonable precautions designed to ensure the security of personal information covered by this Policy, and to protect such personal information from loss, misuse or unauthorized access, alteration, destruction, or disclosure. When you enter sensitive information (such as login credentials) we encrypt the transmission of that information using secure socket layer technology (SSL). SkyGeni has a written data security policy that describes the policies and procedures by which data security is to be maintained. Although SkyGeni makes every effort to ensure security of its customer information, no data transmission over the Internet can be guaranteed to be 100% secure. If you have any questions about security on our website, you can contact us at support@skygeni.com.

 Data Integrity

SkyGeni takes reasonable steps to ensure that personal information it collects is reliable for its intended use, accurate, complete, and current. SkyGeni does not use personal information in ways that are incompatible with the purposes for which the information was disclosed.

 User Access to Personal Information

Upon request SkyGeni will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@skygeni.com.

SkyGeni allows you access to personal information held about you and allows you to correct, amend, or delete that information if inaccurate or if you no longer desire our service subject to contractual commitments you may have entered into with SkyGeni, except where the burden or expense of providing access would be disproportionate to the risks to your privacy. If you have submitted personal information to SkyGeni, and you wish to obtain access to such information in order to review, amend, or delete that information, you should contact SkyGeni by emailing us at privacy@skygeni.com. SkyGeni reserves the right to confirm your identity before providing access. We will respond to your request for access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services or to comply with the restrictions of separate agreements we may have signed with you. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 General Provisions

Enforcement of This Policy

If you have a question, comment or complaint about this Policy or enforcement of this Policy, please address your concern to SkyGeni at privacy@skygeni.com. SkyGeni will investigate your concerns promptly, and will respond within thirty days. SkyGeni will provide you with a clear explanation of any decisions made with respect to your request.

Verification

SkyGeni conducts an annual self-assessment to verify that this Policy is accurate, comprehensive, prominently displayed, completely implemented and accessible, and to confirm that employee training and appropriate compliance procedures are in place.

 Changes to This Policy

Changes to this Policy will be posted in this section. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. This way you will always have a clear understanding of what information is collected online and offline, how it is used, and the choices you have. Your personal information will only be used in accordance with the version of the Policy that is in place at the time that you provided your information, unless you provide your consent to do otherwise. We encourage you to periodically review this page for the latest information on our privacy practices.

 State-Specific Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@skygeni.com. If you are a California resident, you also have the rights pursuant to the CCPA, as outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@skygeni.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you must send us a request that: (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (for example, providing us your enterprise email address used to register for the Services), and (2) describe your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. You may submit a Valid Request by emailing us at: privacy@skygeni.com

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@skygeni.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

 General Data Protection Regulation

General Data Protection Regulation (GDPR) is a European Union regulation that establishes a new framework for handling and protecting the personal data of EU-based residents. It is the most comprehensive EU data privacy law in decades and became effective on May 25, 2018.

Besides strengthening and standardizing user data privacy across the EU nations, it will require new or additional obligations on all organizations that handle EU citizens’ personal data, regardless of where the organizations themselves are located.

GDPR is intended to offer protections for you or any identifiable natural person (the “Data Subject”) regarding your information (your “Personal Data”, “data”). You, as a Data Subject, have broad rights.

 Your rights under GDPR

Consent

Under GDPR, you opt in to have an organization (the “Data Controller”) collect your Personal Data.

Special Categories of Data

Unless specifically authorized, GDPR prohibits processing of certain special categories of data such as race, ethnicity, political and religious beliefs, sexual orientation, genetic, and biometric data. SkyGeni does not acquire or process any data belonging to these categories.

Right of Access

If you consented to a Data Controller processing your Personal Data, you may then request the following:

• A copy of your Personal Data undergoing processing
• Purpose of processing
• Categories of data processed (e.g., name, address, online browsing behavior)
• Any third-party recipients of your Personal Data, both backward or forward looking, especially recipients in third party countries (i.e. countries outside of the EU)
• Any third-party sources of your Personal Data (i.e. not collected from the Data Subject directly, for instance by purchasing said data from another source that previously collected the data directly)
• How long such Personal Data would be stored, or if that is not determinable, how the length of this period would be determined
• Data rectification
• Data erasure
• Restriction of data processing
• Objection to data processing

 Right to Rectification

You, as a Data Subject, have the right to have any errors or inaccuracies of Personal Data corrected. The Data Controller will implement requests without undue delay.

Right of Erasure

You, as a Data Subject, have the right to have your Personal Data erased or forgotten. The Data Controller will remove your Personal Data and confirm deletion via a notification to you. Data Controllers are also required to maintain these transactions.

Right to Data Portability

You, as a Data Subject, have the right to have your Personal Data exported and provided to you in complete form.

Breach Notification

In the event of a data breach and your Personal Data is compromised, your Data Controller is required to notify you within 72 hours.

Our commitment to protecting your personal data

We are committed to partnering with customers and users to ensure that we are fully compliant with the requirements of GDPR. We recognize your rights under GDPR, and will ensure that these rights are honored and your Personal Data is protected. We will continue to monitor the guidance around GDPR compliance from privacy-related regulatory agencies and services, and adjust our plans accordingly if that guidance changes.

 Data controller versus data processor

Your Personal Data may enter our processing scope in multiple ways. We are either a Data Controller or a Data Processor under the GDPR. The way in which your Personal Data is obtained, who has control over that data, and who has the responsibility for protecting and administering your rights, determines whether we are a Data Controller or a Data Processor. This section describes our role as both a Data Controller and Data Processor, and explains how you can interact with us in either role.

Role of a Data Controller

When you interact with SkyGeni via our marketing and sales development outreach programs as a website visitor, webinar participant, or asset downloads, we act as the primary Data Controller from a GDPR perspective. In these cases, we are responsible for obtaining your consent and providing means for exercising your data rights.

 Personal Data

Personal Data you submit during registration, such as your name, email, phone number, and address.

Consent

• When you interact with web forms and similar registration pages at our website (or partners that we collaborate with), we will request explicit consent prior to you submitting your Personal Data.
• When we contact you and you provide information to us, and you consent to us for using the information we obtained from you.
• When your colleague from your organization volunteers your Personal Data to us via email, or other information channels. We will follow up to obtain consent using the email provided to us, or we will indicate in our email communication that we do not yet have consent but request that you provide us consent to continue our use of your personal data.

We ensure that any data we procure from third-party services is obtained by that third party after obtaining your consent.

If you had previously provided consent to collect your Personal Data, you may choose to withdraw that consent at a later point. Please send an email request to privacy@skygeni.com and we will process the request, and provide a confirmation of your consent withdrawal via a reply email to your email address. The acknowledgement email will also provide you consequences of withdrawing your consent.

Onward Transfers

We do not sell Personal Data to any other third-party organization. We do not transfer rights to Personal Data to any party or use the data other than for the original purpose it was obtained. Any transfer to a third party is solely intended for the processing of data and SkyGeni has secured agreements with downstream Data Processors to protect Personal Data and enforce GDPR data rights for you.

Data Access

As part of GDPR you have the right to request your Personal Data be made available to you. We will provide:

• All Personal Data that we have on record
• How and when we obtained the data
• Our use of your data
• Whether any data was transferred to any other third party

To request this data, please contact privacy@skygeni.com and we will respond within 30 days of your request.

Data Erasure, Accuracy, and Portability

You may submit a request via privacy@skygeni.com to delete all data about you. We will comply with this request, but will use your email to send a confirmation notice that we performed the requested action.

 You may submit a request via privacy@skygeni.com to update Personal Data that we have about you. We will perform this, and will use your email to send a confirmation notice that we performed the requested action.

 You may submit a request via privacy@skygeni.com to obtain an export of all your data for data portability. We will provide this information via a CSV or JSON file. Such a report will include metadata such as when particular data was added, any updates to the data. This will include an audit trail of the data.

 Data Breach Notification

We will notify you by email if your Personal Data was compromised via a breach within 72 hours. This includes any breach that was caused by a Data Processor that we have authorized to process your data.

 Filing a Complaint

 In the event that you are not satisfied with our resolution of your requests, you have the right to file a complaint. Please submit a request via privacy@skygeni.com to file a complaint. You also have a right to file a similar complaint with a supervisory authority for the jurisdiction you are in and seek appropriate remediation.

Role of a Data Processor

To request your Personal Data, please send a request to privacy@skygeni.com. For data processed by us, we will forward your request to your employer or the organization to which you provided the data (the Data Controller), who will then initiate a request to provide that information. Since our role is only that of a Data Processor, we will not be able to provide your Personal Data directly.

 Consent

When we process and display your Personal Data, that data was acquired from your employer or our customer that you interact with. If it is Personal Data that you submitted to your employer, you provided consent to your employer to use that data for their business purposes. If it is Personal Data that our customer obtained in the process of conducting business with you or your employer, they rely on your consent to use the data for business purposes. To withdraw an earlier consent that you provided, contact your employer or the organization to which you provided the original Personal Data. We will not be able to alter your consent, as we are the Data Processor.

Data Breach Notification

In the event of a data breach, SkyGeni, as a Data Processor, is required to notify your employer / organization that there was a data breach. Your organization will then notify you regarding the breach, its impact, and potential remedies. We will not notify you directly.

Data Erasure, Accuracy, and Portability

To request an export or erasure or update of Personal Data held by SkyGeni, please send a request to privacy@skygeni.com. We will forward your request to your employer/organization, who will then initiate a request us to complete the request. Since our role is only that of a Data Processor, we will not be able to perform these actions directly.

List of sub-processors

SkyGeni as a Data Processor has engaged the services of the following sub- processors. Some or all of your Personal Data may be transferred to them. All such transfers are governed by Master Service Agreements that establish the scope of processing as well as legal basis for such processing. We require sub-processors to perform the specified processing only for the purposes of delivering the services that are part of the agreement. To learn more about the GDPR initiatives of our sub-processors, please visit the web pages listed here.

Analytics Sub-Processors

Google Analytics – Analytics

Platform Sub-Processors

Microsoft Azure – Hosting

Effective Date of Policy: August 03, 2020