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Effective as of July 1, 2020.
This Privacy Policy explains how Skypoint Cloud, Inc. (“Skypoint”, or “we”, “us” or “our”) handles personal information that we collect
Skypoint respects your privacy rights and is committed to transparency in how we collect, use and share your personal information. If you have any questions or concerns about your personal information or this Privacy Policy please contact us by email at privacy@www.csgpro.com or by visiting our Privacy Center: https://privacy.skypoint.ai
Skypoint’s Service and Customer Data
Registered users of the Service (“Customers”) are businesses that use it to collect and manage information about their own users (“Customer Data”), including information about how they interact with the Customer’s websites, applications, services and designated third-party partners (“Customer Services”). Customers also use the Service to more efficiently route Customer Data to the other services that they use or to third parties that they work with, and to control how Customer Data is exchanged between these services and third parties.
Customer Data may include, without limitation, information about the identity of Customer users (such as name, postal address, e-mail address, IP address and phone number), as well as information about the pages users visit, the features they use, and the actions they take while using Customer Services. This Privacy Policy does not apply to Customer Data or to Customer Services, and we are not responsible for our Customers’ handling of Customer Data. Our Customers have their own policies regarding the collection, use and disclosure of your personal information. To learn about how a particular Customer handles your personal information, we encourage you to read the Customer’s privacy policy. Our use of Customer Data provided by our Customers in connection with our Service is subject to the written agreement between Skypoint and Customer.
Personal Information We Collect
Information you give us.
Personal information that you may provide through the Service or otherwise includes:
Information from third party sources.
We may combine personal information we receive from you with personal information we obtain from other sources, such as our Customers; data providers; affiliates within our corporate group of companies; business partners, such as joint marketing partners and event co-sponsors; and publicly accessible sources, such as social media platforms.
Data collected automatically.
We, our service providers, and our business partners may automatically log the following information about you, your computer or mobile device, and your activity over time on the Site and other online services:
For more information about the use of these technologies on the Site, see our website data collection policy below:
Skypoint uses data collected by cookies and JavaScript libraries to improve your browsing experience, analyze site traffic, deliver personalized advertisements, and increase the overall performance of our site.
By using our website, you’re agreeing to our Website Data Collection Policy as described below. If you want to update your preferences, you can do so by clicking “Website Data Collection Preferences” at the bottom of this page.
How do we collect data on our website?
We use a variety of tools on our website that collect data using both cookies and JavaScript libraries.
Cookies are small text files that store Internet settings from the websites you visit. They are widely used to make website features work, operate more efficiently, or improve your experience on the site. Cookies are also used to remember your preferences or personalize the content so that it is more relevant to you.
JavaScript libraries are snippets of codes we run on the page that are executed when certain actions take place.
The table below outlines how we use this data by category.
Categories
Sensitive personal information.
We ask that you not share with us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise. If you do anyway, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy.
Changes to your personal information.
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or by visiting our Privacy Center: https://privacy.skypoint.ai
How We Use Your Personal Information
We use your personal information for the following purposes or as otherwise described to you at the time of collection:
Service delivery.
We use your personal information to:
Site operation.
We use your personal information to:
Research and development.
We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and develop other products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing.
We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
Compliance and protection.
We may use your personal information to:
Other purposes with your consent.
In some cases, we will ask for your consent to collect, use or share your personal information for other purposes. For example, we may ask for your consent to send you marketing emails where required by law or to post your testimonial or endorsement.
How We Share your Personal Information
We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:
Your Choices
Access, Update, Correct or Delete Your Information.
Customers may review, update, correct or delete the personal information in their registration profile by logging into their account or by visiting our Privacy Center: https://privacy.skypoint.ai
Access to Data Controlled by our Customers.
Skypoint has no direct relationship with the individuals whose personal information is contained within the Customer Data processed by the Service. An individual who seeks to access, correct or delete this information should direct their request the Customer.
Marketing communications.
You may opt out of marketing-related emails by logging in and changing your account settings or by following the opt-out prompt in the email. You may continue to receive Service-related and other non-marketing emails.
Testimonials.
If you gave us consent to post a testimonial to our site, but wish to update or delete it, please contact us.
Cookies.
You may opt-out of certain cookie-based tracking activities on our Site in our Website Data Collection Preferences section in this document center. Additionally, most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Advertising choices.
You can opt-out of data collection through our Site for interest-based advertising purposes in our Website Data Collection Preferences section in this document center. You can also limit use of your information for interest-based advertising by:
The opt-out preferences described above must be set on each device for which you want them to apply. Not all companies that serve interest-based ads participate in the ad industry opt-out programs described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online, but they may be less relevant to you.
Do Not Track.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide your personal information.
If you do not provide information indicated as required or mandatory within the Service, or that is otherwise necessary to provide a requested service or feature within the Service, that portion or all of the Service may be unavailable to you and we may deactivate your account.
Security
The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
International Data Use
Skypoint is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
Individuals in the European Economic Area should read the important information provided in this document about transfer of personal information outside of the European Economic Area.
Third Party Sites and Services
The Service may contain links to other websites and services operated by third parties, such as social media platforms, advertising services and other websites and applications. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and disclosure of your personal information. We encourage you to read their privacy policies to learn more.
Children
The Service is not directed at, and Skypoint does not knowingly acquire or receive personal information from, children under the age of 16. If we learn that any user of the Service is under the age of 16, we will take appropriate steps to delete that individual’s personal information and restrict that individual from future access to the Service.
Organization-Administered Accounts
Where the Service is provided to you through your employer or another organization, please note that your organization’s administrator may be able to:
Please contact your organization or refer to your administrator’s organizational policies for more information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by email (if you have an account linked to a valid email address) or another manner through the Service that we believe is reasonably likely to reach you.
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes in the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any updated Privacy Policy indicates your acceptance of the update.
Contact Us
If you have any questions or concerns about our Privacy Policy, please contact us.
Skypoint Cloud, Inc. 14631 SW Millikan Way, Beaverton, OR 97003
Attention: Data Protection Officer
Email: privacy@www.csgpro.com
Important Information for California Residents
This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
Your California privacy rights.
You have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
How to exercise your information, access and deletion rights.
You may submit a request to exercise your information, access or deletion rights by visiting emailing us privacy@www.csgpro.com or by visiting our Privacy Center: https://privacy.skypoint.ai . We will need to verify your identity to process your information, access and deletion requests and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.
We do not sell your personal information.
Based on our current understanding of the CCPA, we do not “sell” your personal information as defined in the CCPA. However, like many companies online, Skypoint uses services provided by Google, Facebook and other advertising companies that track website visitor activity to help deliver interest-based ads to those visitors. We describe this in more detail in the section above entitled Interest-based advertising. Use of these services may constitute a “sale” of Personal Information under the CCPA where the user has not opted into the tracking. We no longer permit these services to track your use of the Site for interest-based advertising unless you opt-in, and you can always opt-out in our Website Data Collection Preferences section in this document. However, our past practice of allowing this tracking on an opt-out basis may have resulted in the “sale” of your Personal Information prior to January 1, 2020.
Personal information we collect, use and disclose.
The chart below describes the categories of Personal Information we collect by reference to the categories specified by the CCPA (California Civil Code § 1798.140(o)).
Statutory category of personal information (PI)
We may further disclose each category of Personal Information to our affiliates, to our professional advisors, in connection with our compliance and protection activities and in connection with business transfers as described in the section above entitled How We Share Your Personal Information.
This chart describes our practices as of, and during the 12 months preceding, the effective date of this Privacy Policy.
Additional Information for European Union Users
Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller, Data Protection Officer and EU Representative. Skypoint.io, Inc. is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation and you can contact us and our Data Protection Officer using the contact details listed in the Contact Us section above. Our EU representative is:
Skypoint Cloud, Inc. 14631 SW Millikan Way, Beaverton, OR 97003
Attention: Data Protection Officer
Legal bases for processing.
The legal bases on which we process your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent, or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at privacy@www.csgpro.com
Processing purpose
Legal Basis
Site operation
Processing is necessary to perform the contract governing our operation of the Site or the provision of the Services, or to take steps that you request prior to engaging our Services. Where we cannot process your personal data as required to operate the Site or Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the Services you access and request.
Marketing
Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business.
Research & Development
Processing is based on our legitimate interests in performing research and development to improve our services and develop new services.
Compliance & Protection
Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety or property.
Other purposes with your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when you consent or in the Service.
Use for new purposes.
We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention.
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your rights.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests by email to privacy@www.csgpro.com or by visiting our Privacy Center: https://privacy.skypoint.ai . We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
If we transfer your personal information out of the European Economic Area or Switzerland and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so. Such safeguards may include applying the European Commission Model contracts for the transfer of personal data to third countries described here, or for transfers to third parties in the United States, ensuring they participate in the EU-U.S. Privacy Shield Framework or Swiss-U.S. Privacy Shield Framework. Please contact us for further information about any such transfers or the specific safeguards applied.
Skypoint itself has self-certified to the EU-U.S. and Swiss-U.S. Privacy Shield. For more information, see our Privacy Shield Notice.
Privacy Shield Notice
Effective as of July 18, 2018.
Skypoint Cloud, Inc. (“Skypoint” or “we”, “us” or “our”) complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred to it in the United States from the European Economic Area (“EEA”) or Switzerland, respectively. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield program, the Privacy Shield Principles and to view our certification, please visit www.privacyshield.gov.
Scope. Our certification of adherence to the Privacy Shield Principles applies to the personal data that (a) we collect from our customers and other visitors to our website for account management, billing or marketing purposes (“Skypoint User Data”) and (b) that we process on behalf of our customers in providing online services to them under a service agreement (“Services Data”).
Data processed. The Skypoint User Data that we collect, use and share is described in our Privacy Policy. While our customers decide what Services Data to submit, it typically includes information about their own users and how they use the customer’s sites, applications and services and third-party applications. We process Services Data as instructed by our customers and do not own or control Services Data.
Purposes of data processing. We collect, use and share Skypoint User Data for the purposes described in our Privacy Policy. We process Services Data for the purpose of providing our online services to our customers, which may include accessing and processing the data to provide the services, to correct and address technical or service problems, to follow instructions of the customer who submitted the data, or in response to contractual requirements.
Inquiries and complaints.
If you believe Skypoint maintains your personal data within the scope of our Privacy Shield certification, you may direct any inquiries or complaints concerning our Privacy Shield compliance to privacy@www.csgpro.com . If you are located in the EEA or Switzerland and have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Arbitration.
If you are located in the EEA or Switzerland and neither Skypoint nor our dispute resolution provider resolves your complaint, you may be entitled to invoke binding arbitration under certain conditions more fully described on the Privacy Shield website.
Third parties who may receive personal data.
We share Skypoint User Data with third parties as described in our Privacy Policy. We may share Services Data with third parties under the following circumstances and only in accordance with the applicable customer agreements:
In addition, we may be required to disclose any personal data that we process in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Your rights to access, to limit use, and to limit disclosure.
Individuals in the EEA and Switzerland have rights to access personal data about them, and to limit use and disclosure of their personal data. With our Privacy Shield self-certification, we have committed to respect those rights. We process Services Data only on behalf of our customers in accordance with their instructions. This means that if you wish to access Services Data and request that we correct, amend or delete it if it is inaccurate or processed in violation of Privacy Shield, you should contact that customer with your request. We will then help them to fulfill that request in accordance with their instructions.
If your personal data includes Skypoint Personal Data, you can request access to that data and request that we correct amend, or delete it if it is inaccurate or processed in violation of Privacy Shield by emailing your request to privacy@www.csgpro.com or by visiting our Privacy Center: https://privacy.skypoint.ai . We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
