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Privacy Management Policy

Version 1.0.4 of 03/26/2021

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

c) City

d) Region

e) Country

f)  Telephone Number 

g) Cellphone

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.

 

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.

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:

Email: governanca@skyone.solutions

Phone number: +55 (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.