Introduction

 

Sky.One is a company that operates in the information technology branch, specializing in cloud computing, management, and migration services. It partners up with several different CLOUD PROVIDERS that offer services and solutions based on cloud computing for companies and/or individuals, and make them available for usage, processing, storage, security and more, establishing and maintaining a connection to the Internet.

 

We at Sky.One are committed to respecting your privacy, personal data and personal data protection, and to treat such information in accordance with legislative requirements regarding privacy and protection of personal data, as established by Lei nº 13.709/2018 (Lei Geral de Proteção de Dados, or General Data Protection Law).

 

This policy applies to (i) the employees at Sky.One; (ii) the clients at Sky.One, both natural and juridical persons; (iii) third parties that work with or for Sky.One in processing such data, be they natural or juridical persons; and (iv) the individuals owners of the personal data processed by Sky.One.

 

Through this privacy policy, Sky.One aims to clarify in an objective and transparent manner how we process the personal information collected and also:

 

  • what data we collect;
  • how and why we use it;
  • who we disclose this information to; and
  • how we protect your privacy when you use our services and platforms.

 

Sky.One executes many different data processing operations, and could be defined as a Personal Data Controller or Operator. For example: in our relationship with our clients, Sky.One acts as a Personal Data Operator, processing the data lodged in our platforms. To our partners, and to individuals whose data we acquire through marketing activities and website traffic, Sky.One operates as a Personal Data Controller, respecting their privacy while defining the purposes for which and the means by which their personal data is processed.

 

Principles

 

Sky.One will honor the following data protection principles when handling personal data:

 

  • PURPOSE LIMITATION: Sky.One will process personal information solely for specified, explicit, and legitimate purposes that have been informed to the data owner, and not further process it in a way that is incompatible with such purposes;
  • ADEQUACY: Sky.One will process personal data in a way that is consistent with the purposes informed to the data owner, and in accordance with the context of such processing;
  • DATA MINIMIZATION: the processing of data by Sky.One is limited to the minimum amount necessary to fulfil its purpose. We will hold on to adequate, relevant and limited data in relation to the purposes for which they are processed;
  • FREE ACCESS: Sky.One grants individuals easy and free access to examine the duration and the way in which their data is being processed, as well as the entirety of their data;
  • DATA QUALITY: Sky.One grants, to the owners of the personal data used, accuracy, clarity, relevancy and renewal of data, in accordance with our necessity and in order to fulfil processing purposes;
  • TRANSPARENCY: Sky.One guarantees the data owner clear, precise, and easily accessible information about the processing of individual data and the respective agents responsible for such processing;
  • SECURITY: Sky.One will take appropriate technical and administrative measures to protect personal data from unauthorized access, as well as accidental or illicit situations of destruction, loss, alteration, communication or diffusion;
  • PREVENTION: Sky.One will take measures to prevent damage in virtue of personal data processing.
  • NON DISCRIMINATION: Sky.One guarantees data owners incapability to process personal data with discriminatory, illicit, or abusive intent;
  • RESPONSIBILITY AND ACCOUNTABILITY: Sky.One vows to demonstrate the adoption of efficient measures capable of observing and testifying to the enforcement of personal data protection norms, as well as to the efficacy of such measures.

 

Minors and personal information

 

It’s important to remember that although we strive to protect all personal data, our services were not designed for or meant to be used by anyone under 18. For that reason, we do not collect or consciously request information from minors, and such data will be deleted and removed from our database if acquired. If there is any suspicion that a minor might be using Sky.One’s services, please send an email to: governança@skyone.solutions

 

By clicking on “AGREE” during the registration process on our Platform, hereafter referred to as Platform, you willingly give us your informed consent to collect, process and share this data in ways established by our Privacy Policies.

 

Regarding the users who only navigate our websites https://www.skyone.solutions or http://www.skyone.cloud or https://support.skyone.cloud/ or https://latamsuporte.skyone.cloud/ or https://suporte.skyone.cloud/, hereafter referred to as Websites, the processing and sharing of personal data will follow the cookie policy generated by Sky.One, as well as this Privacy Policy. Therefore, we suggest you read this document carefully, as we suggest you do with any eventual updates, before making a decision to use or continue to use the Platform and/or navigate our Websites.

 

What personal data do we collect?

 

  • Platform 

This includes all the information needed for access and running of the Platform, including your personal data, technical information, the type of device you are using, your IP address, browser type, and operating system being used to connect you to the internet. This information might be used for specific operations within the Platform or to better the services we provide.

 

  • Websites

This includes all the information that Sky.One collects from users who visit and  navigate our website, such as browser type and IP address, average session duration, date and city, pages visited, activity and average time on those page, as well as the services you looked at and researched, and traffic source (for example, how you found our Websites).

 

  • Cookies

As described above, we collect your personal information by using cookies on our Websites https://www.skyone.solutions or http://www.skyone.cloud or https://support.skyone.cloud/ or https://latamsuporte.skyone.cloud/ or https://suporte.skyone.cloud/. It is possible to disable cookies by changing your browser settings or managing your cookie preferences on https://skyone.solutions/pb/cookies/ 

 

  • Social Media

When you interact with us on social media platforms such as Facebook, LinkedIn profile, Instagram and Twitter, we might obtain information about you (for example: if you publicly tag us on a picture of an event). The data we receive will depend on your privacy settings for each one of these platforms.

 

  • Public Information

We complement your data with information from public sources, such as corporate websites and public social media accounts, on account of creating a better understanding of your interests. 

 

Personal data we may collect, hold and use include:

 

  • Full name, CPF (Brazilian taxpayer registry ID), email address, phone number, postal address, birth date and other information when necessary.
  • Information about your activity on our Websites and about the device used to access them, e.g. your IP address and geographical location.

 

However, it is important to note that we do not usually collect confidential information about you. The Lei Geral de Proteção de Dados (LGPD) recognizes certain categories of personal information as sensitive data, thus needing more protection. Examples of that include data on your health, ethnicity and religion, which is not collected by us.

 

How and why do we use your data?

 

We may use your information for many different purposes, which include:

 

  • Providing information about our services upon request;
  • Order demands submitted by you;
  • Carrying out our obligations under any contracts between you and us;
  • Maintenance of the registration of your relationship with us;
  • Analyses and market research to understand how we can better our services and information;
  • Asking for opinions or comments on the services we provide;
  • Notifying you of changes to our addresses and services;
  • Sending communications that you have requested and might be of your interest. This might include advertising campaigns, activities and service promotion; and
  • Processing subsidies or job applications;

 

SUMMARY

 

SOURCE OF ENTRY PURPOSE PERSONAL DATA LEGAL 

BASIS

Forms Registration Name and lastname, email address, phone number, job title, department/area Contract execution
Marketing Hub Registration and sending communications Name and lastname, city, region, country, LinkedIn profile, email address, phone number, job title, department/area Legitimate interest
Sky.Simple Registration and login Name and lastname, date of birth, gender, email address, phone number, job title, CPF, RG, postal address Contract execution
Survey Research Name and lastname, email address, phone number, job title, department/area Contract execution
Twilio Communication Name and lastname, email address, phone number Contract execution

 

How long do we keep your personal data for?

 

We will keep your personal data only for the time strictly necessary for the purposes determined in this privacy statement, though the established period for retaining such data might be determined by lawful and contractual requirements.

 

All personal information is stored in systems in Brazil or the United States, and we are allowed to keep this information or relocate it to any other country that acts in accordance with this privacy legislation, though always maintaining a safe and secure supervision.

 

We will keep your information for as long as you remain a Sky.One client, and for the time necessary to fulfill legal obligations. The period during which personal data is retained varies according to the purpose for which it was collected, in case there are no specific legal demands. 

 

We review our retention periods regularly every year. 

 

Who has access to your personal data?

 

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

 

However, we might disclose your personal information to third parties in order to reach other purposes established here. These third parties might include:

 

  • Service providers, suppliers, agents, subcontractors and other organizations associated with the purpose of completing tasks and providing services to you in our name. However, we disclose only the information necessary for these third parties to perform and provide services, and we have a contract that demands these parties keep your information safe, prohibiting them from using it for any purpose other than the purposes authorized by you.

 

  • We may transfer your personal information to third parties in case of a partial or total sale of our operations, in an eventual corporate reorganization, or in case we are legally required to disclose or share your personal data. Nevertheless, we will take measures to guarantee your right to privacy remains protected.

 

LEGAL PROCESSING

 

The Lei Geral de Proteção de Dados (LGPD) demands we process personal data only if there is an existing legal basis that allows us to process it, as follows:

 

Specific consent

If you provide informed, unambiguous and freely given consent to the processing of your data for a predetermined purpose, before the processing on our Platform, Websites or at events host, and including but not limited to any interactions with third party content or advertising through Websites or Apps (including plugins and third party cookies), Sky.One Solutions receives personal information provenient from such parties.

 

Contract Execution

We sign a contract with you and follow all contractual obligations for your benefit or for the benefit of preliminary procedures related to the contract.

 

Legal Obligations

When necessary, legal and regulatory obligations we are bound to, for example when we are ordered by a Court or a Regulatory Authority such as the Autoridade Nacional de Proteção de Dados (National Data Protection Authority).

 

Protection of Life

When necessary to protect life or health (for example, in case of a medical emergency suffered by an individual at one of our events) or in the event of safeguard measures that obligate us to share information with emergency services.

 

Legitimate Interests

We have legitimate interests in data processing (including our legitimate interests to operate our businesses, provide services, provide information on other services that might be of interest, and maintain or better our services) and we will always respect your rights, liberties or interests.

 

Sky.One treats the following data according to the basis of Legitimate Interests, with the purpose of prospecting potential customers to offer our services and new :

 

  • a) Name
  • b) Email address
  • c) City
  • d) Region
  • e) Country
  • f) Telephone number
  • g) Mobile number
  • h) Company you work for
  • i) Job title
  • j) Area
  • k) Department
  • l) LinkedIn profile 

 

Sky.One allows the owner of the data to request, at any moment, the elimination of their personal information from our database, by contacting: XXXXXX

 

Marketing Communications

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

 

Emails / text messages / phone numbers

We will only send marketing communications through emails, text messages and phone numbers if you previously and explicitly give us permission to. You may opt to eliminate your data from our marketing communications at any moment by clicking on the cancellation link at the bottom of our marketing emails. In case of text messages or phone calls, access our Privacy Policy at: https://skyone.solutions/en/privacy-policy/

 

Your options

You have the right to not receive information about us.

If you do not wish to receive direct marketing communication from us, you can manage your settings on our consent management system. 

XXXXXX

 

We are committed to putting you in control of your own personal data so that you are free to alter your marketing preferences (which includes telling us you do not want to be contacted for marketing purposes) at any moment, in the following ways:

 

Online: XXXXXX

 

Email: governanca@skyone.solutions

Phone number: (11) 2193-1961

 

Our DPO: Cristiane Santos – cristiane.santos@skyone.solutions

 

Customer Profiles

We may analyse your personal information to create a profile according to your interests and preferences so that we can adapt and redirect our communication in a relevant and opportune way. We may use additional information about you when it is made available through external sources to help us do this in an effective manner. This allows us to be more focused, efficient and economical with our resources, and decreases the risk of you receiving information that might be irrelevant or inadequate. 

 

Your rights

According to the Brazilian law of general data protection, you have certain rights over the personal information we hold about you. We listed your rights below:

 

  • Right to access data

You have the right to request access to the personal information we hold about you. You also have the right to request a copy of the information we hold, and we will provide you with one unless legal exceptions apply. To have access to your information, send us a brief description of what you wish to receive, along with proof of identity, and we will validate your request accordingly.

 

  • Right to correct incomplete, incorrect or outdated data
    You have the right to have your personal information be corrected, in case your data is incomplete, incorrect or outdated. The precision of your information is important to us, and that is why we are working on ways to make it easier for you to review and correct the information we have on you. 
  • Anonymization, blocking or erasure of unnecessary, excessive or unlawfully processed data
    You have the right to ask for the anonymization, blocking and erasure of unnecessary, excessive and unlawfully processed data.
  • Right to data erasure
    You may ask us to erase some or all of your personal data and, in some cases and certain exceptions, we will do what is necessary. In many cases, we will anonymize this information instead of erasing it.
  • Right to data portability
    You may ask us to transfer your personal data to another service provider.
  • Right to oppose processing
    You have the right to oppose processing where we have used your personal information (1) with a basis on Legitimate Interests, (2) for direct marketing or (3) for research/statistical purposes

 

We might be obligated to ask for further information and/or proof of identification. We will attempt to fully answer all requests within 15 (fifteen) days after receiving your request; however, if we are unable to do so, we will contact you informing you of the reasons for our delay.

 

Note that the exceptions apply to a series of these rights, and not all rights are applicable in all circumstances. To obtain more details, we recommend that you consult the orientations published by ANPD (Autoridade Nacional de Proteção de Dados). 

 

If you wish to exercise any of the rights above, you may use any of the communication channels described above in “Your options”.

 

  • Keep your information secure

When you provide us with your personal data, we take measures to guarantee appropriate technical and organizational governance to protect you. Any sensitive information collected is protected by a 128-bit SSL cryptography software, and kept in cybersecurity systems. 

 

Non-sensitive details (your name and email address) are transmitted normally through the internet, and that is never guaranteed to be 100% secure. As a result, while we do try to protect your personal data, we cannot guarantee the security of any information you give out to us, and you do so at your own risk. When we receive your data, we do our best to guarantee that it is kept safe in our systems. The passwords you receive (or pick out) will grant you access to certain parts of our Platform or our Website, and you are responsible for keeping those passwords confidential. We ask that you do not share your password with anyone.

 

Links to other Websites

Our Website may contain links to other sites administered by other organizations. This policy applies only to our Website, so we encourage you to read the privacy policies of the other websites you visit. We cannot be held responsible for the privacy policies and practices of other websites, even when you access them through links on our Website.

 

Furthermore, if you come to our Website from a third party website, we cannot be held responsible for the privacy policies and practices of the owners and operators of that third party website, and we recommend you verify the privacy policies of such websites as well.

 

Transferring your information outside of Brazil

We utilize systems that store personal data in Brazil or in the United States, and we may choose to relocate and store these systems in any other country that acts in accordance with this privacy legislation, though always maintaining a safe and secure supervision.

 

Changes to this policy

Any alterations we might make to this policy in the future will be posted on this Website, so please check this page occasionally to guarantee that you agree with any changes. If we make any significant changes, we will make that clear on this Website. 

 

Policy Revision

We keep this policy under constant review. This policy was last updated on 03/26/2021.

 

________________________________________________________________________

 

Código de Ética e Conduta – https://skyone.solutions/codigo-de-etica-e-conduta/

 

Code of Ethics and Professional Conduct

 

Document Control

 

Controlled versions and alterations

 

Version Emission Description

 

Date Person responsible
1.9 11/27/18 Lauro de Lauro Finalizing early draft
2.0 12/03/18 Rodrigo Burjato Final review before release
2.1 03/20/19 Aila Braga Final version

 

Today’s consumer has vast access to information of all kinds, becoming more demanding and aware of what they are searching for. Consequently, companies now face the challenge of understanding and suiting these needs, but more importantly, satisfying their clients and building customer loyalty. The fight for customer loyalty is a constant, which means companies have to commit more and more to the quality of their products and services.

 

With that in mind, Sky.One aims to position itself and be recognized in the market as a company guided by ethics, human respect and social responsibility.

 

Our code of ethics and conduct represents the values that we praise and live by in our day to day lives at the office. We are certain that its application will contribute to a healthy, dignified, respectable and successful work environment, making it clear that our commitment to others isn’t just about what we do, but more importantly about how we do it.

 

Come experience it with us!

 

Welcome to the SKY.ONE FAMILY!

What is a Code of Conduct?

The Code of Conduct describes the company’s attitude and behavior, guiding the actions of their contributors in accordance with the organization’s principles. 

 

All contributors must act in a correct, just and efficient manner when striving for results, incorporating the values expressed in this code of conduct and obeying internal regulations and policies.

 

All of our values must be preserved in Brazil and abroad, as we believe ethics and principles are not mutable. The culture might change, but the beliefs and values remain the same.

 

Objectives of the Code of Conduct

Sky.One’s Code of Conduct was developed with the following objectives in mind:

 

  • Promoting company values so that all contributors know to respect and practice them daily.
  • Being a reference for attitudes and behaviors of every employee
  • Making sure these values are respected in and out of the workplace, also having an outlook for society.
  • Establishing Sky.One’s values through constant practice
  • Facilitating the creation of healthy competition among competitors
  • Consolidating customer loyalty
  • Creating value and strengthening the company’s image

 

Who does it apply to?

This code of conduct applies to everyone that works at Sky.One and it must regulate the relationships these contributors have in and out of the workplace:

 

  • with other company contributors
  • with suppliers, clients, third parties, partners and competitors
  • with the community and society in general

 

About Sky.One

 

With each passing day, companies need more agility, efficiency and cost-benefits. 

 

The journey to digital transformation is often complex, as it belongs to a scenery that is constantly changing due to new technologies.

 

As specialists in planning, building and maintaining cloud environments, Sky.One gained notoriety in the Latin American cloud market with its more than 1000 clients and 1500 project implementations since 2013. Sky.One sees each project as unique, offering safe and consistent services that are based on results and upheld by strategic partners.

 

Relax and leave all of the complexity of the cloud to us!

 

Learn more about our history at: SITE

Terms and expressions used

To guide proper understanding of this Code of Conduct and Ethics, the following terms will have the following meanings, regardless of being in its plural or singular form.

 

  • Sky.One, Auto.Sky, Sky.Saver, Guru.Sky: company denominations, our products and services;
  • Public agents: any agent, representative, employee, director, consultant or any person that, even if temporarily or unpaid, executes a job, role or function, be it elected or appointed, at any entity, department or government agency, including any entities related to Executive, Legislative and Judiciary powers, direct or indirect public administration, mixed economy systems, national or foreing public institutions, international public organizations, or any other political party, including candidates running for office in Brazil or abroad;
  • Code: Sky.One’s current Code of Conducts and Ethics;
  • Contributor: any person who works at Sky.One, including directors, employees, interns and apprentices;
  • Anti-Corruption Law: law n.º 12846, from August 1st, 2013, and its respective regulations;
  • Bidding Law: law n.º8666, from July 21st, 1993;
  • Administrative Improbity: law n.º8429, from June 2nd, 1992;
  • Money laundering Law: law n.º9613, from March 3rd, 1998; and
  • Third parties: meaning any person, natural or juridical, that acts in Sky.One’s name, interest, or for our benefit, providing services or other assets, such as commercial partners, and including limitations, agents, consultants, suppliers, resellers or other service providers. 

 

Fundamental Rights of our Contributors

All contributors at Sky.One, regardless of role, title, tasks or salary, will be treated with respect and attentiveness, being offered proper conditions to develop professionally and individually. Health and safety conditions at work must be a permanent target of attention, as to guarantee our contributors the lowest possible risk while performing tasks.

 

Thus, all contributors must abide by general health and safety norms, and participate in trainings, orientation activities and CIPA (Internal Commission for Accident Prevention, or Comissão Interna de Prevenção de Acidentes).

 

Personal Conduct and Conflict of Interests

 

Personal activities and relations that clash with the company’s interests must be avoided. The following is recommended:

 

  • If there is any doubt on whether or not there are conflicting interests, consult your immediate superior and the Human Resources department
  • Third parties should also act and take decisions thinking of Sky.One’s best interests and avoiding conflict
  • If conflict evolves, look for the director of your area and the Human Resources department, seeking the best solution for the company
  • Contributors involved in decision-making processes cannot resolve matters in which there are personal interests involved, as such interests might influence their impartiality.
  • If working for other companies, do not accept jobs or roles with conflicting schedules.
  • Previously inform your director, who must then consult the Human Resources department, when a company owned by you, a family member, or someone you have a close relationship with is hired by Sky.One to provide services or products to the company.
  • Recommending friends and family members for open positions is a traditional and accepted practice. It is up to the responsible areas to decide if they wish to move forward with the selection and hiring process, and it is considered unacceptable to pressure or influence the admission, promotion or dismissal of collaborators.
  • The acceptance of gift-cards is limited to low-value items that must be associated with the brand offering it and must not be used to influence any decisions related to the company’s business. Gifts that do not fit this description must be returned. For better understanding, the value of these items cannot be higher than ½ (half) of the present minimum wage, and the offering or receiving of gifts must present a 12-month rolling period in between occurrences. 
  • It is prohibited to Sky.One collaborators to offer or receive gifts that serve a purpose of obtaining advantages or were in favor of considerations like offered or received goods
  • Invitations to events, trips and others must be notified to the Human Resources department to assess together with the area director. 
  • The approval of individual professional expenses is the responsibility of immediate superior and directors, according to the company’s strategic planning. 

 

Communication vehicles

 

Only collaborators selected to exercise the role of spokesperson are authorized to speak in the name of the company. If any collaborator is asked to provide information, write articles or give out interviews as a representative of Sky.One, they must notify their immediate superior, as well as the Human Resources and Communication departments.

 

Sky.One considers the work done by the press and other communication vehicles essential to establish an organizational image, and seeks to provide information and attend to requests, but may choose not to speak on subjects that go against company interests or in order to preserve classified strategic information.

 

Company assets

 

All collaborators at Sky.One have the responsibility to correctly use and preserve goods and assets belonging to the company and that are part of their work. This rule also applies to client, partner or third party goods and assets used for company activities. Such goods and assets must not be used to personal gains, except when expressly authorized by the company.

 

These goods and assets include: equipment, installations, properties, furniture, business plans, technical and market information, computer programs, models, work papers and documents, and other goods and assets that belong to the company.

 

Improper appropriation or utilization, including copying, selling or distributing to third parties, is considered a serious offense and it might result in labor or legal sanctions.

 

Innovation developed by professionals through their work for the company, as well as resulting patents and ownership rights, are incorporated into the organization’s assets and remain under corporate control even after the collaborator’s termination. 

 

The utilization of equipment and communication means and devices (phone, email, internet, Skype, Slach, and others) for personal use must be restricted to a minimum. The internet cannot be used to forward or receive content that is offensive, aggressive, pornographic, political or religious. On a similar note, any content created for company communication vehicles might be verified and analyzed by the Human Resources department, if necessary.

 

Information may only be disclosed, both internally and externally, by those authorized to do so precisely, objectively and adequately. Each collaborator is responsible for the custody of the information possessed and must notify their immediate superior of anything that seems odd or incompatible with Sky.One’s values. False, slanderous or ill-intentioned information about colleagues, the company, the business, partners, suppliers or clients might result in labor or legal sanctions.

 

Accounting records must be elaborated and tracked closely by the person directly in charge