Privacy Policy (Data Products and Services)

Skydeo Services

Skydeo values the privacy of its customers and consumers. Skydeo’s customers include clients of Skydeo’s Services (defined below) (e.g., brands, advertising agencies and marketers), third parties (e.g., publishers) that provide data to Skydeo, as well as application developers, media and technology platforms, and others who visit any Skydeo website that links to this policy (“Site”) or otherwise use Skydeo’s Services (collectively “Customers”). “Consumers” include individuals who use Skydeo’s applications or who use applications from which Skydeo receives or collects data (such as applications that are owned and/or operated by Skydeo’s Customers).Skydeo provides mobile insights, analytics, marketing and audience data and marketing technologies services to Customers and offers a variety of services that use this data (“Services”). Part of our Services is designed to provide solutions to help our business Customers manage, understand and gain insights into their Consumer data. Skydeo’s Services also include data marketing products. Some of our Customers use our data marketing products to market and advertise through various advertising channels. Some of Skydeo’s Services rely solely on types of data that do not pertain to an individual or device, while other services involve the use of data collected from or associated with specific Consumer devices (“Device Data” as further defined below). This Privacy Policy describes how Skydeocollects, uses, discloses, and protectsany personal data we process in connection with and relates only to Skydeo’s Services. This Privacy Notice applies only to Skydeo’s processing of information about you in connection with its Services as described below, as well as any other related services that refer or link to this Privacy Notice. This Privacy Notice does not apply to the following activities:

Employment or Contractors. This Privacy Notice does not cover our processing of personal data in connection with employment by Skydeo or contractors that do business with Skydeo.
Skydeo’s Own Websites. If you are looking for information on how Skydeo collects and uses personal data in connection with visitors to our website (Skydeo.com), which includes our clients, prospective clients, business-to-business contacts, please click here to view our Website Privacy Policy.
Services Offered Outside of North America. This Privacy Notice applies only to Skydeo Services offered in North America.
Other Companies. This Privacy Policy does not apply to companies that Skydeo does not own or control, including Skydeo’s Customers. To learn more about how Skydeo’s Customers collect, use, and disclose information about consumers, please visit the Customers’ privacy policies.

If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy. Skydeo complies with the Principles of the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Skydeo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Sections

The Personal Data Skydeo Collects and Uses for its Services
The Purposes of Using Personal Data
How Skydeo Discloses Information through the Services
Consumer Choices and How to Opt Out of Interest-Based Advertising
Data Broker
Minors
Security and Data Integrity
Data Retention
International Visitors
What is the legal basis on which Skydeo relies to process personal data?
Who is Responsible for the data?
Changes and Updates to this Privacy Policy
Links to other (third party) Websites and Apps
Additional Information
Authorized Agents
California Privacy Rights

The Personal Data Skydeo Collects and Uses for its Services

To provide our Services, we must collect, use and disclose some information about you. Skydeo collects personal data through a variety of means, such as by observing your online interactions with advertisements or use of certain mobile applications, through third party data partners, and from public sources.

The categories of personal data we process, and the sources we obtain the personal data from, is provided in more detail below:

Categories of personal data processed:
1. Contact information and other identifiers: e.g., name, email address, telephone number, IP address, mobile ad identifier, device ID.
2. Device Data: e.g., device type (e.g., tablet or smartphone), operating system, IP address, network provider, mobile carrier, mobile browser type (e.g., Firefox, Chrome or Safari), other apps and SDKs installed on the device, timestamp, time zone, information on speed, bearing, orientation and altitude of device, other device identifying information, precise geolocation data pertaining to mobile devices, which may be expressed by latitude-longitude coordinates obtained through GPS tools, WiFi data, cell tower triangulation or other techniques and linked to a device identifier, such as the IDFA for iOS devices or Android ID for Android devices.
3. Commercial or transactions information: e.g., records of personal property, goods or services purchased or considered, or other purchasing or consuming histories or tendencies.
4. Demographical and statistical information: e.g., marital status or gender.
5. Inferences: e.g., data attributes drawn or created from any of the information identified in this section reflecting the consumer’s preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.
6. Internet or other electronic network activity information: e.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement.
7. Professional or employment-related information: e.g., business name, job title, or job history.
8. Consumer or Household information: e.g., age or gender of others in household, including children; however, Skydeo does not knowingly collect personal data directly from individuals under 18 years of age; date of birth; street address.
9. Sensitive personal data

Health data
Political, religious, and philosophical beliefs
Racial/Ethnic Data

Sources of personal data processed:

The categories of information identified above has been collected via various methods and sources:

Indirectly from you: When Consumers use our applications or engage with our Customers (e.g., by using their mobile applications or viewing an ad provided by our Customers, or by using an app that has integrated our software development kit (“SDK”)), we may collect or receive Device Data and other personal data. In addition, we utilize automated technologies, such as cookies, log files, pixels, tags, or other similar technologies to collect information from you when you view or interact with one of the internet advertisements we serve, or when you visit a website that has implemented our automated technologies, such as advertiser or publisher websites.
Directly from You: We may also receive personal data from directly from you, such as when you inquire about our services.
Inferred from other data: We create new personal data attributes or derive a probability percentage (propensity) that a data attribute may be linked to you by using other personal data that we collect using propensity analysis and modeling. The Device Data that Skydeo receives from its Customers or from Consumers may be combined with additional information Skydeo collects or receives from third-party sources. For example, Skydeo may have information about consumer products, events held at specific locations, street addresses, and categories of geographic locations. While such information is associated with a specific device, it is treated as Device Data.
Third Parties: We additionally collect information from you from various other companies. Such third parties can be categorized as follows:

Advertising Networks	Food & Beverage Companies
Advertising/Marketing Companies	Gift Product Companies
Affiliates not under the Skydeo brand	Health and Wellness Product and Service Companies
Apparel & Accessory Companies	Internet Service Providers
Automotive Companies	Lifestyle & Interest Product Companies
Business Service/Agencies	Manufacturing Companies
Business to Business Companies	Marketing Data Companies
Communication Services Companies	Not for Profit Organizations
Consumer Data Resellers	Operating Systems and Platforms
Consumer Packaged Goods Companies	Parenting Product Companies
Consumer Services Companies	Public or Government Entities
Data Analytics Providers	Publishing Product Companies
Educational Institutions & Companies	Social Networks
Electronics Companies	Technology/Computer Software Companies
Energy and Utility Companies	Telecommunications Companies
Financial Services Companies	Travel, Leisure & Entertainment Companies

The Purposes of Using Personal Data

Skydeo collects and uses personal data as part of its Services for the following purposes:

Interest-Based Advertising

We help companies serve personalized advertising across the Internet, including web browsers and mobile applications, in a variety of ways such as banner and video ads. Some of the online ads you are served may be based on the content of the webpage you’re visiting; others may be based on registration or other information you provide to us and our partners; and other ads may be customized based on predictions about your interests generated from your visits to other websites. This practice of customizing and providing online ads is often called interest-based advertising, or targeted advertising, or cross-contextual behavioral advertising.

Some examples of our interest-based advertising activities include:

Helping Customers identify and target ads to online audiences based on common demographics and/or disclosed (actual or inferred) interests or preferences (e.g., consumers interested in winter apparel). When we do this, we handle information provided by our Customers (for instance, their own consumer files) and “match” their information through pseudonymization techniques (such as through coded data “hashing”) with online cookies and other identifiers. We then use these cookies and identifiers to target and measure ad campaigns online across various display, mobile and other media channels.
Assisting clients by creating “identity” graphs, to help locate users across various channels, such as connecting identities based on common personal, device-based, or network-based identifiers (e.g., cookie ID, IP address, or hashed email address).

Data for Marketing and Analytics Purposes

Skydeo collects personal data from the sources identified above and infers personal data to create Consumer databases. Skydeo’s Consumer databases help companies get a full view of their customers and prospective customers to help them predict future buying behaviors and to help them build brand loyalty. Skydeo’s Consumer databases enable marketers to connect with new and existing consumers in both digital and offline channels, such as direct mail and online advertisements. Additionally, Skydeo’s Consumer database can be used by companies for analytics purposes to provide insights on trends in the marketplace or business intelligence related to the company’s industry.

Some examples of the use of our data for marketing and analytics services include (which may overlap with interest-based advertising activities, above):

Providing marketing information to our Customers, generally regarding their marketing, fundraising, customer service and engagement, and outreach activities.
Providing information to companies about customers and prospective customers in order for the companies to provide better service, improved offerings, and promotions.
To build Data Segments.
Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
Analyzing and optimizing our clients’ (or their service providers’) proprietary databases, or helping clients to identify and mitigate potential fraud.
Creating trend reports and business intelligence to be used by companies in the development of new products or financial projections

NOTICE: We/this website may sell your sensitive personal data. This notice is required pursuant to certain state privacy laws. Skydeo does not license personal data collected from visitors to its website; however, Skydeo may disclose your sensitive personal data that Skydeo collects from the sources identified herein or that Skydeo infers to a third party for the purposes listed herein (which may be considered a sale under certain state privacy laws).

Operating Our Services:

For example:

Improving, testing, updating, and verifying our own data and data Services.
Developing new Services.
Operating, analyzing, improving, and securing our Services.

We may aggregate, de-identify and/or anonymize any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data with any other party, including advertisers, promotional partners, and sponsors, in our discretion, unless otherwise prohibited by applicable law.

Other Internal Purposes:

For example: internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.

How Skydeo Discloses Information Through the Services

Disclosure to Third Parties.

We will disclose your personal data for the various purposes described above, both with service providers and with other third parties, such as our Customers. All of the information we process, may have been shared, sold, or used for targeted advertising (based on the US privacy laws’ definition of “sell”, “share” and “targeted advertising”) with the following categories of third parties in the past 12 months:

Advertising Networks	Food & Beverage Companies
Advertising/Marketing Companies	Gift Product Companies
Affiliates not under the Skydeo brand	Health and Wellness Product and Service Companies
Apparel & Accessory Companies	Internet Service Providers
Automotive Companies	Lifestyle & Interest Product Companies
Business Service/Agencies	Manufacturing Companies
Business to Business Companies	Marketing Data Companies
Communication Services Companies	Not for Profit Organizations
Consumer Data Resellers	Operating Systems and Platforms
Consumer Packaged Goods Companies	Parenting Product Companies
Consumer Services Companies	Public or Government Entities
Data Analytics Providers	Publishing Product Companies
Educational Institutions & Companies	Social Networks
Electronics Companies	Technology/Computer Software Companies
Energy and Utility Companies	Telecommunications Companies
Financial Services Companies	Travel, Leisure & Entertainment Companies

Disclosure to Service Providers for a Business Purpose.

We may disclose your personal data to our service providers that assist us with our business purposes. Our service providers are to only process your personal data in accordance with our instructions and only for the purpose listed below. The table below shows with whom we disclose your personal data for the specific business purpose(s).

Category of Personal Data	Categories of Service Providers	Business Purpose
Contact information and other identifiers Commercial or transactions information Demographical and statistical information Inferences Internet or other electronic network activity information Professional or employment-related information Health data Political and philosophical beliefs Precise geolocation Racial/Ethnic Data	Advertising Networks Advertising/Marketing Companies	Maintaining or servicing accounts Processing or fulfilling orders and transactions Verifying customer information Processing payments Providing analytic services Providing storage Providing similar services on behalf of Skydeo
Contact information and other identifiers Commercial or transactions information Demographical and statistical information Inferences Internet or other electronic network activity information Professional or employment-related information Health data Political and philosophical beliefs Precise geolocation Racial/Ethnic Data	Cloud security provider Cloud storage providers	Providing storage on behalf of Skydeo Helping to ensure security and integrity

Disclosing for Other Purposes.

We also may disclose any of the personal data we process for the following purposes:

Disclosing for Legal Purposes: In addition, we may disclose personal data with other parties in order to: (a) comply with legal process or a regulatory investigation (e.g. regulatory authorities’ investigation, subpoena, or court order); (b) enforce our Terms of Service, this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of other parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Disclosing In Event of a Corporate Transaction: We may also disclose personal data in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all our assets, or for purposes of due diligence connected with any such transaction.
Disclosing to Service Providers: We may disclose any personal data we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement, or hygiene, or otherwise assisting us to provide, develop, maintain, and improve our services.

D. Automated Decision Making and Profiling

To the extent that we use processes that involve automated decision making or profiling when processing your personal data, we take steps to ensure that any automated decision making or profiling practices are fair and not discriminatory. Additionally, we do not process your personal data for profiling that produces a legal or similar significant effect, such as a decision to offer to you or decline your request for employment, financial services, housing, or healthcare. We use automated processes to derive inferences and create audiences for interest based advertising and other marketing purpose, including for those clients that may advertise their products or services within the financial, housing, or healthcare industries.

Consumer Choices and How to Opt Out of Interest-Based Advertising

You may have privacy rights based on the laws in the jurisdiction you reside. This section describes how to exercise those rights and our process for handling those requests. You may also be permitted to designate an agent to make the following requests to exercise your rights where the law allows. We will take steps to verify that your agent has been authorized to make a request on your behalf by asking for a copy of your authorization to the agent. Please the Agent Authorization requirements in Section XV below. You may exercise any of the following rights by filling out and submitting our online requestform or by calling toll-free 512-900-8390.

A. Information from our Customers

We acknowledge that you may have certain rights in connection with the personal data we process on behalf of our Customers. If personal data about you has been processed by us as a processor (or as a service provider) on behalf of our client and you wish to exercise any of the rights described below, please provide the name of our client on whose behalf we processed your personal data. We will refer your request to that client and will support them to the extent required by applicable law in responding to your request.

B. Right to request access to and portability of your personal data

If the state/province/country in which you reside provides you with the right to access or know what personal data we process about you, you may request, up to two times each year, access to categories and specific pieces of personal data about you that we collect. To make an access request please visit online requestformor by calling us toll-free at 512-900-8390. Once we receive your form, our identity verification service provider will confirm your identity with a series of test questions to be verified against the service provider’s data. We will provide your report of categories and specific pieces of personal data in a portable format. When we receive and verify your request, we will make best efforts to fulfill your request unless an exception applies.

C. Right to request correction/rectification of your personal data

If the state/province/country in which you reside provides you with the right to correct the personal data we process about you and if you believe we hold inaccurate personal data about you, you may request that we correct that personal data. We will delete your personal data upon receipt of your correction request. When we receive and verify your request, we will proceed to delete the data unless an exception applies. To make a correction or deletion request please visit online requestform or by calling us toll-free at 512-900-8390. Once we receive your form, our identity verification service provider will confirm your identity with a series of test questions to be verified against the service provider’s data.

D. Right to request deletion of your personal data

If the state/province/country in which you reside provides you with the right to delete the personal data we process about you, you may request that we delete any personal data that we obtained about you. However, we may retain personal data for certain important purposes, as set out by law. When we receive and verify your request to delete your personal data, we will proceed to delete the data unless an exception applies. To make a deletion request please visit online requestform or by calling us toll-free at 512-900-8390. Once we receive your form, our identity verification service provider will confirm your identity with a series of test questions to be verified against the service provider’s data.

E. Right to nondiscrimination.

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

F. Right to opt-out of the sale of your personal data.

If the state/province/country in which you reside provides you with the right to opt-out of the sale of your personal data and if you would like to opt out of our use of your personal data for such purposes that are considered a “sale” under privacy laws, you may do so by visiting online requestform or by calling us toll-free at 512-900-8390. Please note that we do not knowingly sell the personal data of minors under 16 years of age without legally-required affirmative authorization. Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal data that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal data for monetary consideration by the business to a third party for the third party to license or sell the personal data to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, you can make the opt-out request by visiting online requestform or by calling us toll-free at 512-900-8390, emailing us at privacy@Skydeo.com, or mailing your request to: Skydeo, 30 N Gould St, Sheridan, WY 82801, USA, Attn: Privacy.

G. Right to opt-out of the share/cross-context behavioral advertising/targeted advertising use of your personal data.

If the state/province/country in which you reside provides you with the right to opt-out of the share/cross-context behavioral advertising/targeted advertising and if you would like to opt out of our use of your information for such purposes that are considered a “share” under privacy laws or cross-context behavioral advertising/targeted advertising (what we refer to above as Interest-based Advertising), you may do so by visiting online requestform or by calling us toll-free at 512-900-8390.

Additionally, you may choose not to receive targeted advertising from ad networks, data exchanges, and other digital advertising providers by opting out of targeted advertising via YourAdChoices (US) or YourAdChoices (Canada) powered by the Digital Advertising Alliance.

To find out more about interest-based advertising in the web environment, and how to opt-out of information collection for this purpose by companies that participate the Digital Advertising Alliance, DAA’s Consumer Choice Page. EEA and Swiss residents, please refer to www.youronlinechoices.com.

H. Right to opt-out of the use of Device Data.

As described above, Skydeo may use or transfer Device Data that it directly collects or that it receives from Skydeo’s Customers, who may use cookies or non-cookie technologies, to enable advertising that is more tailored to Consumers’ inferred interests, preferences, and locations. This practice is known as interest-based advertising. Skydeo may also collect, use or transfer Device Data collected from one device for interest-based advertising on other devices that may be linked to the device where data was collected. This is known as cross-device linking.

Skydeo, and some of Skydeo’s Customers, provide the ability for Consumers to opt out of the collection and use of mobile app data across apps over time on a device, for interest-based advertising purposes, through the DAA’s AppChoices tool. To opt out of Skydeo’s collection, use, and transfer of such app usage data and of Device Geolocation Data, for interest-based advertising purposes, Consumers can download AppChoices onto the relevant mobile device and exercise choice through the app. When such choice is exercised on a device, Skydeo will also stop using and transferring Device Data from that device for interest-based advertising on other linked devices, and will stop using Device Data from other linked devices for interest-based advertising on the device from which choice was exercised. AppChoices is available at the links below:

DAA AppChoices iOS
DAA AppChoices Android
DAA AppChoices Amazon

Please note that Consumers who use more than one mobile device should renew their opt-out choices on each device. Consumers who opt out from use of their Device Data as part of Skydeo’s Services may continue to receive interest-based advertising from other companies.

This will opt you out of many –but not all- of the interest-based advertising activities in which Skydeo or its third party partners engage. Opting out via AppChoices will opt the User out of all Skydeo Targeting Segments that are created immediately and any subsequent Segment distributions. However, there will be a lag for the User’s ID to be removed from previously distributed Targeting Segments that are already active at the time when the opt-out is exercised.

If a User wants to end all targeting immediately, s/he can turn on “Limit Ad Tracking” in his/her device settings. To limit Ad Track on an Apple device, see instructions at: https://support.apple.com/en-us/HT202074.

To limit Ad Tracking on an Android device, see instructions at: https://support.google.com/ads/answer/2662922.

Please note, however, that opting-out will not block general advertisements that are sent at random, and not tied to the perceived interest of the User of a particular device.

Consumers who have downloaded Skydeo’s applications, but who no longer wish to provide information to Skydeo for interest-based advertising purposes, should opt out through AppChoices as described above.

I. Do Not Track.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

J. Right to opt-out of automated decision making and profiling

Your state/province/country may provide you with the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on your or produce a similarly significant effect. If the state/province/country in which you reside provides you with the right to opt-out of automated decision making and profiling, you may opt-out of the processing of your personal data for profiling and other automated decision making by visiting online requestform or by calling us toll-free at 512-900-8390.

K. Right to limit the use of your sensitive personal data

If the state/province/country in which you reside provides you with the right to limit the use of your sensitive personal data, you may request that we limit the use and disclosure of your sensitive personal data by visiting online requestform or by calling us toll-free at 512-900-8390. We may deny your request in part or in full under uses authorized by applicable law.

L. Right to withdraw your consent (Canadian residents)

If you are a Canadian resident, you request to withdraw your consent to our processing of your personal data. To do so, you may select deletion request by visiting online requestform or by calling us toll-free at 512-900-8390. Please note this may affect our ability to communicate with you and we may retain certain data points if permitted by law.

M. Appeal

Certain residents of the United States have the right to appeal our denial of your privacy rights request. Within 60 days of receiving our denial of your request, you may make an appeal by visiting online requestform or by calling us toll-free at 512-900-8390.

N. Disclosure of Financial Incentives

California law also gives residents the right to: (1) request that we provide you with information about the financial incentives that we offer to you and (2) not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Skydeo does not provide financial incentives in exchange for personal data.

O. Data Broker

THE ENTITY MAINTAINING THIS WEBSITE IS A DATA BROKER UNDER TEXAS LAW. TO CONDUCT BUSINESS IN TEXAS, A DATA BROKER MUST REGISTER WITH THE TEXAS SECRETARY OF STATE (TEXAS SOS). INFORMATION ABOUT DATA BROKER REGISTRANTS IS AVAILABLE ON THE TEXAS SOS WEBSITE.

VI. Minors

Skydeo does not knowingly collect personal information from children under 13 years old or from websites or online services directed to children under 13 years old. Users should not create Skydeo accounts unless they are legally old enough to form a binding contract and in any case are 13 years of age or older. In the unlikely event that you are the parent or legal guardian of a child under 13 who has registered with the Site or Services, please contact us at https://skydeo.com/contact to have your child’s personal information deleted.

VII. Security and Data Integrity

Skydeo uses reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Users’ personal information.

We take commercially reasonable efforts to maintain security protections in accordance with industry practices to protect data we collect from loss, alteration, destruction, misuse and unauthorized access or disclosure.

To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the personal information we collect, we have implemented physical, electronic, and administrative procedures. We utilize hashing, encryption and de-identification techniques to help ensure your privacy is safeguarded.

We have policies to help maintain control and physical security of the facilities used to store data and only allow access to authorized personnel, restrict access to data to those employees, contractors and agents that have a need to know the information in order to provide and support our services. All our employees are bound by confidentiality obligations and may be subject to disciplinary or legal action if they fail to meet these responsibilities.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

VIII. Data Retention

DATA USE	RETENTION PERIOD
INSIGHT	We retain data for as long it is necessary or permitted by law to establish and/or maintain business relationships with our clients.
CONTACT	As permitted by law, we retain data for as long as we have reasonable grounds for believing that it is accurate and can be relied upon in establishing and maintaining our business relationships with our clients.

IX. International

For Users visiting the Site or Consumers whose data is collected through the Services from non-U.S. territories, please note that any data entered into the Site or that is collected through the Services will be transferred outside such non-U.S. territory for use by Skydeo and its affiliates for any of the purposes described herein. In addition, because Skydeo operates globally, it may make information it gathers available to worldwide business units and affiliates. By providing and/or using any data on the Site or through Skydeo’s Services, individuals hereby expressly consent to such transfers of data to the United States or other countries.

Skydeo’s Mobile SDK ensures that user’s privacy is being respected and compliance is met with the regulations in place. Skydeo only receives data after user consent is granted.

Skydeo app partners present users with an updated consent form prominently disclosing the privacy policy, the data being collected and its uses. If the user declines to participate, they will still be able to access the mobile application, but Skydeo does not receive any information. After opting into the data collection, EU users have the right to update their Personal Information or choose to opt-out and have their active data deleted in a timely manner.

More Information for Individuals from the European Economic Area (“EEA”) and Switzerland

EU-U.S. Privacy Shield
Skydeo complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from EEA member countries, as that term is defined in the Privacy Shield Framework. Skydeo has certified that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Residents of the EEA and Switzerland have the right to access the personal data that Skydeo maintains about you, as that term is defined in the Privacy Shield Framework, and you may be able to correct or amend that information if it is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, please email privacy@Skydeo.com.

Skydeo is accountable for information that it receives under the Privacy Shield and subsequently transfers to a third party. In particular, Skydeo is responsible under the Privacy Shield Principles if third-party controllers to whom it transfers information or third-party agents it engages to process this information on its behalf do so in a manner inconsistent with the Principles.

In compliance with the Privacy Shield Principles, Skydeo commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Skydeo at:

privacy@Skydeo.com
Skydeo Inc.
98 San Jacinto Blvd., Suite 400

Austin TX 78701 USA

Skydeo has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States at 620 8th Ave, 34th Floor, New York, NY 10018. (212) 751-2700. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit JAMS for more information or to file a complaint. The services of JAMS are provided at no cost to you. A binding arbitration option may also be made available to you in order to address complaints not resolved by any other means. Skydeo is subject to the investigatory and enforcement powers of the United States Federal Trade Commission

X. What is the legal basis on which Skydeo relies to process personal data?

On some occasions, Skydeo may process personal data with the individual’s consent (for example, when a User agrees that Skydeo may place cookies, or process information that the User inputs into the Skydeo website).

On other occasions, Skydeo may process personal data when Skydeo needs to do this to fulfil a contract (for example, for billing purposes) or where Skydeo is required to do this by law.

Skydeo also processes a User’s/Consumer data when it is in Skydeo’s or its Customer’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include providing services to enable Skydeo’s Customers to provide more relevant ads and content.

XI. Who is responsible for the data?

For the majority of the Services it offers, Skydeo, Inc. is a data processor who processes data on behalf of its Customers.

For certain other services for which Skydeo is a data controller and for processing of personal data derived from the Site, Skydeo, Inc. is the data controller of the data.

If you have any questions or comments please contact Skydeo at: privacy@Skydeo.com
Skydeo Inc.
98 San Jacinto Blvd., Suite 400

Austin TX 78701 USA

XII. Changes and Updates to This Privacy Policy

This Privacy Policy may be revised periodically without further notice. To stay aware of any changes, please revisit this page regularly.

XIII. Links to Other (3^rd Party) Websites and Applications

We may provide links to content or advertisements that may be created, offered, sponsored or affiliated with other entities. Your access to and use of such content and advertisements – even when you have clicked on a link on this website to get there – are not governed by this Privacy Policy. Instead, they are governed by the privacy policies of those linked websites or mobile applications. Skydeo is not responsible for your access to and use of such websites or apps, which includes any use of personal information that may be collected while you visit such websites or apps or when you engage in any transactions with the entities that operate those sites or apps. We strongly recommend that you carefully review these entities’ privacy policies and Terms of Use/Acceptable Use Policies before submitting personal information to them.

XIV. Additional Information

Skydeo’s Site may include links to other websites, apps, and services whose privacy practices may differ from Skydeo’s practices. Information collected from by those companies is governed by their privacy policies or statements.

Skydeo’s Site may offer a publicly accessible blog and/or a support forum. Any information provided in any such areas may be read, collected, and used by others including the general public.

Skydeo’s Site may include social media features. These features may collect information such as IP address or pages(s) visited on Skydeo’s Site, and may set a cookie to enable the feature to function properly. Such features may also collect or share other information as permitted by their privacy policies and a User’s settings with the third-party social media company. Social media features are either hosted by a third party or hosted directly on the Site. Interactions with these features are governed by the privacy policy of the company providing it.

XV. Authorized Agents:

“Authorized agents” may submit opt out requests on a consumer’s behalf. The authorized agent may do so through our online consumer portal found here. Before Skydeo will accept requests from an authorized agent, the authorized agent must provide certain information.

The CCPA allows California consumers to use “authorized agents” to submit requests to Skydeo on their behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer.

For the safety and security of the consumer’s information, “requests to delete” and “right to know” requests submitted to Skydeo by an authorized agent will require a direct method of communication with the consumer, preferably a valid email address, to fulfill the request.

All authorized agents will be required to successfully establish the minimum requirements for qualification as stated prior to being authorized by Skydeo to submit requests on behalf of a consumer.

AGENT AUTHORIZATION REQUIRMENTS & VERIFICATION

In order to qualify as an authorized agent, businesses or individuals will be required to submit the following documentation:

Businesses – if you are operating as a business, the following documentation is required:

Certificate of good standing with your state of incorporation;
Written authorization document that includes each consumer’s name, address, telephone number and valid email address, signed and dated by each consumer authorizing you, as the authorized agent, to act on behalf of each consumer in making the request, (*Proof of written consumer consent for opt outs are generally not required, except upon request by Skydeo to confirm authorization); and
Valid email address for each consumer for Skydeo’s direct correspondence with each consumer, including an identity verification process to be conducted by Skydeo directly with that consumer. ^*

Individuals – if you are an individual and acting as an authorized agent on behalf of a consumer, the following documentation is required:

A “power of attorney” signed and dated by the consumer and notarized by a notary public naming you as the consumer’s authorized representative, which includes the consumer’s full name and physical California address and the consumer’s month/year of birth;
If you do not have a power of attorney signed by the consumer, then we require a written authorization document that includes the consumer’s name, address, telephone number and valid email address, signed by the consumer authorizing you, as the authorized agent, to act on behalf of the consumer in making the request; and
Valid email address for the consumer for Skydeo’s direct correspondence with the consumer, including an identity verification process to be conducted by Skydeo directly with that consumer.

Parent/Guardian of Minor Child* – Skydeo does not knowingly sell information about minors. Please see Skydeo’s privacy notice concerning A data collection, sale and disclosure practices described above. If you are a parent or guardian of a minor child under 16 and would like to make a request for a right to know or deletion on behalf of the minor child, the following documentation will be required:

The minor’s verification documents, which include all of the following:
- A certified copy of the minor’s birth certificate or adoption decree
- Health insurance card (issued by the insurance company)
  - Medicare/Medicaid are accepted
- The minor’s Social Security card
- Certified school record or transcript or home school notice of intent form that includes minor’s permanent address
Proof of parental/guardianship identity document that matches the minor’s permanent residence, which includes one of the following:
- Minor’s court order establishing custody
- Minor’s order establishing guardianship
- Court issued parental responsibility (for example, court documents on file with presiding court)
- Current month’s utility bill with parent/guardian’s name and address shown

*For the safety and security of the minor child, no location information will be provided in any Consumer Access Report issued.

SKYDEO CONTACT INFORMATION

Please contact Skydeo, Inc. with any questions or comments about this Privacy Policy or the company’s practices at: Skydeo Inc., 98 San Jacinto Blvd, Suite 400, Austin, TX 78701, by email at privacy@Skydeo.com, or by completing the contact us form at https://skydeo.com/contact

XVI. California Privacy Rights

California Do Not Track Policy

California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a User visits, indicating that the User does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal. Users may also turn on “Limit Ad Tracking” which will zero their advertising IDs as a means of opting out of tracking.

DAA AppChoices iOS
DAA AppChoices Android
DAA AppChoices Amazon

Additional California Privacy Rights

California residents may request and obtain once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. California residents may also choose to opt out of such disclosures, if any. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. California residents may make such a request in writing by emailing Skydeo with your name and address, and noting “California Shine the Light Request” in the subject line of the email.

If you are a California resident, the California Consumer Privacy Act (“the CCPA”) provides you with certain rights relating to the data that Skydeo has collected about you. Those rights include:

The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information.
The right to opt out of our sale of your personal information.
The right to request that we delete the personal information we have collected directly from you. We use a two-step process for online requests to delete. You will be asked to clearly submit your request to delete and to separately confirm your choice.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
Skydeo is a registered data broker with the State of California here.