Privacy Management Policy

Introduction

Consent Management

Skyone is a company that operates in the technology and IT sector with expertise in migration and management of environments and cloud computing and that maintains partnerships with several CLOUD PROVIDERS, which provide services and solutions based on cloud computing for companies and/or individuals and the ability to make these CLOUD PROVIDERS available for use, processing, storage, security and other services, keeping this environment connected to the Internet.

We at Skyone are committed to respecting privacy, protection of personal data and data security and treating personal data collected in accordance with legislation relating to privacy and protection of personal data in Brazil, such as Law No. 13,709/2018 ( LGPD).

This Policy applies (i) to Skyone employees; (ii) to Skyone’s individual and legal customers; (iii) all third parties, whether natural or legal persons acting for or on behalf of Skyone in operations involving the processing of personal data; and (iv) to holders of personal data, whose data is processed by Skyone.

With this Privacy Policy (“Policy”) we want to make it clear in an objective and transparent way how we process the personal data collected:

  1. What personal data we collect;
  2. How and why we use it;
  3. To whom we disclose them; and
  4. How we protect your privacy when you use our services or use our platforms.

In carrying out its activities, Skyone carries out various personal data processing operations, and may be characterized as a Personal Data Controller or Operator. For example: in its relationship with its customers, Skyone acts as a Personal Data Operator, regarding the processing of personal data hosted in its environments, while in relation to the personal data of its employees or collected in marketing actions and website navigation, Skyone acts as Personal Data Controller, always committed to seeking the best interests of the holders of personal data and respecting their rights.

Consent Management

Principles

Skyone will comply with the following personal data protection principles when processing personal data:

  1. Purpose: Skyone will process personal data only for legitimate, specific, explicit and informed purposes to the holder of personal data, without the possibility of further processing in a manner incompatible with these purposes;
  2. Adequacy: Skyone will process personal data in a manner compatible with the purposes informed to the data subject, and in accordance with the context of the processing;
  3. Necessity: the processing of personal data carried out by Skyone will be limited to the minimum necessary to achieve its purposes, with the scope of relevant data, proportional and not excessive in relation to the purposes of the processing;
  4. Free Access: Skyone will guarantee holders of personal data easy and free consultation on the form and duration of processing, as well as the completeness of their data;
  5. Data Quality: Skyone will guarantee, to holders of personal data, the accuracy, clarity, relevance and updating of the data, according to the need and to fulfill the purpose of its processing;
  6. Transparency: Skyone will guarantee, to holders of personal data, clear, precise and easily accessible information about the processing carried out and the respective agents processing personal data, observing commercial and industrial secrets;
  7. Security: Skyone will use technical and administrative measures capable of protecting personal data from unauthorized access and accidental or illicit situations of destruction, loss, alteration, communication or dissemination;
  8. Prevention: Skyone will adopt measures to prevent damage from occurring due to the processing of personal data;
  9. Non-Discrimination: Skyone will guarantee the impossibility of processing personal data for illicit or abusive discriminatory purposes;
  10. Responsibility and Accountability: Skyone is committed to demonstrating the adoption of effective measures capable of proving compliance with personal data protection standards, and the effectiveness of these measures.

Children and Adolescents

It is important to clarify that we are concerned with protecting the privacy of children and adolescents, our services were not designed nor are they intended to be used by anyone under 18 years of age. For this reason we do not collect or knowingly request information from minors under 18 using the forms available on our services and if we receive information we will delete it and will not keep it in our databases. If it is suspected that a minor under 18 is using Skyone services, an email may be sent to: governance@skyone.solutions .

By clicking on the “I Agree” button during registration on the Platform, hereinafter referred to as “Platform”, you will freely, expressly and informedly consent to the collection, processing and sharing of your data under the terms of this Privacy Policy.

With respect to users who only browse the websites https://www.skyone.solutions or https://www.skyone.cloud or https://support.skyone.cloud/ or https://latamsuporte.skyone.cloud / or https://suporte.skyone.cloud/ hereinafter referred to as “Web Sites”, the processing and sharing of personal data will take place under the terms of the cookie policy made available by SKy.One , as well as this Privacy Policy. Therefore, we suggest that you read this document carefully, as well as any updates thereto, before making the decision to use or continue using the Platform and/or browsing the Website.

What personal data do we collect?

The data that Skyone Solutions collects from the User is:

  1. Platform: this data includes all the information necessary for accessing and operating the Platform, including your Personal Data, technical information, including the type of device you are using, the IP address, browser and operating system being used to connect your computer to the internet . This information may be used for specific Platform functionality or to improve the services we offer.
  2. Web Site: this data includes all information that Skyone Solutions collects from the User when accessing and browsing the Web Site, including, among other data, the browser used, IP address, average time spent, date and city of access, the pages who you visit and how you navigate the Web Site, the duration of visits to certain pages, the services you viewed and searched for, referral sources (e.g., how you arrived at our Web Site).
  3. Cookies: We collect your personal information using cookies on our website https://www.skyone.solutions or https://www.skyone.cloud or https://support.skyone.cloud/ or https://latamsuporte.skyone .cloud/ or https://suporte.skyone.cloud/ as described in the item above Web Site. You can turn off cookies by setting your browser preferences or in our cookie consent management at: https://skyone.solutions/pb/cookies/ ;
  4. Social Media: When you interact with us on social media platforms such as Facebook, LinkedIn, Instagram and Twitter, we may obtain information about you (for example, when you publicly tag us in an event photo). The information we receive will depend on the privacy preferences you have set on these types of platforms.
  5. Public Information: We supplement information about you with information from publicly available sources, such as corporate websites, public social media accounts, in order to create a more complete understanding of your interests.

The Personal Data that we may collect, store and use may include:

  1. Full name, CPF, email address, telephone number, postal address, date of birth and others for specific purposes when necessary.
  2. And information about your activities on our Web Site and the devices used to access it, for example, your IP address and geographic location.

It is important to clarify that we do not usually collect confidential data about you and data protection laws such as the LGPD recognize certain categories of personal data as sensitive and therefore require greater protection, for example, information about your health, ethnicity and religion, which are not collected by us.

How and why is your information used?

We may use your information for a number of different purposes, which may include:

  1. Providing information about our services that you have requested;
  2. Orders for orders that you have submitted;
  3. Performance of our obligations under any contracts entered into between you and us;
  4. Record keeping of your relationship with us;
  5. Market analysis and research so that we can understand how we can improve our services and information;
  6. Seeking your opinions or comments about the services we provide;
  7. Notifying you of changes to our addresses and services;
  8. Sending communications that you have requested from us and that may be of interest to you. These may include information about campaigns, activities and promotions for our services; and
  9. Processing grants or job applications.
Entry Type Goal Personal data Legal base
forms Registration and Sending of Communication First name, last name, Email, Phone, Title, Department/Area legitimate interest
Marketing Hub Registration and Login Name, City, Region, Country, LinkedIn, Email, Phone, Title, Department/Area Execution of Contract
Skyone Marketplace Registration Name, Surname, Date of Birth, Gender, Email, Phone, Position, CPF, RG, Address Execution of Contract
Survey Researches First name, Last name, Telephone, Position, Department/Area Execution of Contract
Twilio Communication First name, Last name, Email, Phone Execution of Contract

How long is your personal data kept?

We only keep your personal data for the time necessary to achieve the purpose, and the time for retaining your personal data may be determined by contractual and legal considerations.

All personal data is stored in systems located in Brazil or in the United States and we can relocate and store these systems in any other country that complies with privacy legislation, always keeping them under our supervision and in a safe way.

We will keep your information for as long as you are a Skyone Solutions customer and for as long as necessary to comply with our legal requirements. The period during which the data is stored varies according to the purpose for which it was collected, if there is no specific legal requirement.

We review our retention periods regularly each year.

Who has access to your personal data?

We do not share your personal data with third parties for marketing purposes.

However, we may disclose your personal data to third parties in order to achieve the other purposes set out in this policy. These third parties may include:

  1. We may share your personal data with our service providers, suppliers, agents, subcontractors and other associated organizations for the purpose of completing tasks and providing services to you on our behalf. However, when we use these third parties, we only disclose the personal data necessary to provide the services and we have a contract in place that requires third parties to keep your information secure and prevents them from using it for purposes other than those you have authorized us to do.
  2. We may transfer your personal data to a third party as part of a sale of part or all of our business and assets, in an eventual corporate reorganization, or if we are under a duty to disclose or share your personal data, in order to comply with any legal obligation. . However, we will take steps to ensure that your privacy rights remain protected.

Legal Processing

The General Data Protection Law (LGPD) requires that the processing of personal data only be carried out if there is a legal basis that supports the processing, as follows:

Specific Consent

When you provide your free, informed and unequivocal consent agreeing to the processing of your personal data for a specific purpose, before Processing, on our Platform, Website and at events we hold, including, but not limited to when there is your interaction with any third-party content or advertising on a Web Site or in an Application (including third-party plugins and cookies), Skyone Solutions receives your personal data from said third-party providers of such content or advertising.

Execution of a contract

When entering into a contract with you or performing our obligations under it, for your benefit or for preliminary proceedings relating to this contract.

legal obligation

When necessary, so that we can comply with a legal or regulatory obligation to which we are subject, for example, when we are ordered by a Court or Regulatory Authority such as the National Data Protection Authority.

Life Protection

When it is necessary to protect life or health (for example, in the event of a medical emergency experienced by an individual at one of our events) or a safeguarding issue requires us to share information with the emergency services.

legitimate interests

We have a legitimate interest in carrying out the Processing (including our legitimate interests in operating our business, in providing services to you, in alerting you to other services that may be of interest to you, and in maintaining or improving our services) and always we will respect your rights, freedoms or interests.

Skyone processes the following data based on Legitimate Interest, with the purpose of prospecting potential customers to offer services and new business:

  • Name
  • Email
  • City
  • Region
  • Country
  • Telephone
  • Cell
  • company that works
  • Office
  • Area
  • Department
  • LinkedIn

Skyone allows the data subject to request the deletion of their personal data from our database at any time, via email: governance@skyone.solutions

marketing communications

We may use your personal data to provide you with information about the services we provide through the conditions and means below:

Email / text / phone

We will only send you email, text and telephone marketing communications if you have explicitly provided your prior consent. You can choose to opt out of your data from our marketing communications at any time by clicking on the unsubscribe link at the bottom of our marketing emails or in cases of text and phone calls access our Privacy Policy area at: https: //skyone.solutions/privacy-policy/

Your choices

You have the right not to receive information about us.

If you do not want to receive direct marketing communications, you can select your choices in our consent management system .

We are committed to putting you in control of your data so that you are free to change your marketing preferences (including telling us that you do not want us to be contacted for marketing purposes) at any time, as follows:

Online: Consent Management
E-mail: governanca@skyone.solutions
Telephone: (11) 2193-1961
Our DPO: Cristiane Santos – cristiane.santos@skyone.solutions

interest profiles

We may analyze your personal information to build a profile of your interests and preferences so that we can tailor and target our communications in a timely and relevant way to you. We may make use of additional information about you where it becomes available from external sources to help us do this effectively. This allows us to be more focused, efficient and economical with our resources and reduces the risk that you will receive information that you may find inappropriate or irrelevant.

Your rights

Under Brazilian general data protection law, you have certain rights over the personal data we hold about you. We list your rights below:

  1. Access Rights: You have the right to request access to the personal data we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide this to you unless legal exceptions apply. To access your information, send a description of what you want to see and proof of your identity, we will validate and return with your information.
    • Right to correct incomplete, inaccurate or outdated data

You have the right to have your personal data corrected if it is incomplete, inaccurate or out of date. The accuracy of your information is important to us, so we are working on ways to make it easier for you to review and correct the information we hold about you.

    • Anonymization, blocking or deletion of data that is unnecessary, excessive or treated in violation of legislation

You have the right to ask us to anonymize, block or delete data that is unnecessary, excessive or processed in violation of the law.

    • right of deletion

You can ask us to delete some or all of your personal data, and in certain cases and subject to certain exceptions; we will do whatever is necessary. In many cases, we will anonymize this information rather than delete it.

    • portability right

You can ask us to send your personal data to another service provider.

    • Right to object

You have the right to object to processing where we use your personal information (1) based on legitimate interests, (2) for direct marketing, or (3) for statistical/research purposes.

We may be required to ask for more information and/or evidence of identity. We will endeavor to respond fully to all requests within fifteen (15) days of receiving your request, however, if we are unable to do so we will contact you with reasons for the delay.

Please note that exceptions apply to a range of these rights, and not all rights will apply in all circumstances. For more details, we recommend that you consult the guidelines published by the National Data Protection Authority.

If you want to exercise any of the above rights, use the communication channels described in the item Your choices above.

    • Keep your information safe

When you provide us with personal information, we take steps to ensure that appropriate technical and organizational controls are in place to protect it.

Any sensitive information collected and secured with 128 Bit encryption software over SSL and stored with cyber security systems.

Non-sensitive details (your name and email address) are normally transmitted over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we do our best to ensure its security on our systems. Where we have provided (or where you have chosen) a password that allows you to access certain parts of our Platform or on our Web Site, you are responsible for keeping that password confidential. We ask that you do not share your password with anyone.

Links to Other Websites

Our Web Site may contain links to other Web Sites operated by other organizations. This policy only applies to our website, so we encourage you to read the privacy statements on other websites you visit. We cannot be responsible for the privacy policies and practices of other websites, even if you access them using links from our website.

In addition, if you link to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you review that website's privacy policy. Third party website.

Transferring your information outside Brazil

We use systems that store Personal Data located in Brazil or the United States and we can relocate and store these systems in any other country that complies with privacy legislation, always keeping them under our supervision and in a safe way.

By agreeing to this Policy you are consenting to this transfer, storage or processing. If we transfer your information outside Brazil, we will take steps to ensure that appropriate security measures are in place to ensure that your privacy rights continue to be protected as described in this policy.

Changes to this policy

Any changes we may make to this policy in the future will be posted on this Web Site, so please check this page from time to time to ensure that you agree with any changes. If we make any significant changes, we will make this clear on this Web Site.

Revision of this Policy

We keep this policy under constant review. This policy was last updated on 3/26/2021.

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