Privacy Policy

Last Updated: 09/06/2020

Overview

This Privacy Policy governs the manner in which Skycore, LLC and our affiliates (“Skycore”) collect, uses, maintain and processes data, including Personal Information on our Website, Services and Mobile Apps. The purpose of this privacy policy is to inform you about what kinds of information we may collect, process or store about you, how we may use that information, whether we disclose it to anyone, and your rights regarding the use, access and correction of your personal information. We are committed to safeguarding your Personal Information.

This policy does not apply to companies that we do not own or control, or to the actions of people we do not employ or manage. This includes any companies from whom you may have submitted your data to independently or through our Services, and any companies from whom you may have visited through a link made available to you through our Services.

If you disagree with this Privacy Policy, you should not use or stop using our Websites Services and Mobile Apps. This Website is not directed at children under 13 years of age.

What We Do

Skycore provides rich media mobile messaging products and services (our “Services”) to businesses (our “Customers”) to help them communicate and transact with their customers, employees (their “Users”).  We also provide mobile wallet technology to our Customers to issue mobile wallet objects to their Users. Our Website at “Skycore.com” and other affiliated sites are used to market and advertise our Services as well as serve as a channel for support and feedback for Customers and Users.

Data We Collect and How We Use It

Information that you provide to us when you use the Website

Certain parts of our Website allow you to submit personal information voluntarily to learn more about our Service or for support reasons. We may collect personal information about you (such as full name, email address, country, phone number) so we can fulfill your request. You may also provide information about your employer, such as company name, URL and country. We will use this information to respond to your inquiries and communicate with you about our products.

Information that we collect automatically when you use the Website

When you visit our Website, we collect certain information related to your device, IP address, browser, geographic location (e.g. country or city-level location), and the time that you visited our Website. We may use cookies and similar technologies to help us track your usage automatically. You can choose to opt out of our cookies when visiting our Website. For more information on our use of cookies, please see our Cookie Policy. We will use the information we collect to analyze how our Website is used and to improve the experience. We will also use it to administer our website, troubleshoot issues, route web traffic, provide advertising to you on third party sites and to enable security mechanisms to prevent abuse.

Information that our Customers provide to us to perform our Services

Customers may place JavaScript code or Application code provided by us onto their own Customer website or mobile app in order to enable us to collect information or obtain a User’s consent. We may add JavaScript or an SDK into a webpage or mobile application that we manage for a Customer in order to collect information or consent from a Customer’s User on the Customers behalf. Any mobile SDK may collect phone-related metadata (e.g. battery level, device properties, carrier name, motion and proximity information), IP address, location data, and unique device identifiers. Similarly, we may host an email address, phone number or short code for a Customer in order to receive communication on their behalf. We will collect the customers phone number, carrier and sometimes device information when they submit a message or reply to one of these communication channels.

Information that we collect about our Customers using the Services

We will collect information, including Personal Information, about each Customer when they register for the Service, such as name, email address, phone number company name, company address, support email. We will use that information for correspondence concerning Customer’s use of the Service, regarding such things as product functionality, security updates, billing, support or other service related or marketing reasons. Any recipients of marketing emails will always be able to opt-out of receiving marketing information at any time. If the Customer pays buy credit card, our payment processor will collect payment information in order to process payments for their usage of the Service.

Information we receive from our Customers’ User

Skycore provides rich media mobile messaging products that allows Customers to communicate with their Users. Users may provide sensitive information such as personal and health information in the form of text messages at the direction of the Customer. Skycore is the Customer’s data processor in the context of User data. We will cooperate with the Customer in the event a User requests access to their data.

Your Privacy Under CCPA

If you are a resident of California, you have the right to request access, modification, and deletion of any personal information we process about you under the California Consumer Privacy Act. Our CCPA obligations cover any California resident’s personal information we process through the use of our Website, Services, and Mobile Apps. Data submitted to another company independently or through our Services is not covered under this section and all inquiries regarding your data rights should be directed to them.

When you use our Website, Services, and Mobile Apps we collect certain categories of personal information from you including identifying, contact, payment, geographic and navigational information as well as system usage data. We may disclose these categories of personal information for business purposes in order to provide our services to you, business operational reasons, and to provide internal data analytics information. We do not sell your personal information to any third parties.

You have the right to request the disclosure of all personal information we process about you over the past 12 months, including the right to know what personal information we disclosed to third parties for a business purpose. We will review your request and provide a disclosure which contains the categories and specific pieces of personal information we have processed, the sources of personal information, the business purpose for processing, and any third parties with whom we have shared your personal information. To ensure your privacy and security, we will take reasonable steps to verify your identity before processing your request.
You have the right to request the deletion of your personal information we have processed. We will review your request and will delete your personal information as well as direct all service providers to delete your personal information from their systems. Deletion of personal information is subject to certain exceptions, such as complying with law enforcement request or other legal requests.

If you choose to exercise any of your data rights, we will not discriminate against you or your use of our Services in any of the following ways, including denying goods or services to you, charging different prices or rates for goods or services, providing a different level or quality of goods or services to you, or suggesting any of the above.

You can send an email to privacy@skycore.com to request a disclosure or deletion of your personal information. Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

Your Privacy Under GDPR

You may request access to your information to review, modify or request deletion of any personal information we process about you. We will review your request and will respond in accordance with applicable data protection laws. To protect your privacy and security, we take reasonable steps to verify your identity before processing rights requests. We will also stop sending marketing communications to you by clicking “Unsubscribe” in any marketing e -mail communications we send you.

if you are a resident of the EEA, you can object to processing of your personal information, ask us to restrict processing of your personal information or, if applicable, request the portability of your personal information. You can send an email to privacy@skycore.com to exercise these rights or fill out our Data Privacy Subject Access Request form. If you are a resident in the EEA, you have the legal right to complain to the data protection authorities in the EEA about our collection and use of your personal information.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Data Hosting & Security

Information collected from our Website, the Service and the Mobile App is transferred to and hosted in the United States. Additionally, we may use third-party vendors and affiliates in various countries around the world to process your information. We have taken appropriate safeguards to require that your personal information will remain protected in accordance our obligations.

We have legitimate business interests to collect process and retain personal information for the purposes described in this Policy. We retain personal information we collect from you for as long as we have an ongoing legitimate business reason or requirement to do so. While retaining the data, we will securely store your personal information. We use appropriate technical and organizational security measures to protect personal information against unauthorized access, disclosure, alteration, and destruction.

Data Disclosure to Third-Parties

Vendors

We may use third party vendors, consultants, and other service providers to help us with any of the collection and processing activities described herein. Those providers work on our behalf, as instructed by our team. Prior to sharing data with a third party, we assess the provider’s controls to ensure the data is correctly processed and adequately protected. We require that any information disclosed to a provider is used only to provide services to us and only as allowed by applicable law. For a list of third party vendors we use to process personal information see Exhibit 2 of our Data Processing Addendum https://www.skycore.com/terms/dpa/

Affiliates

We may provide your information with a subsidiary, parent company or company under common control with Skycore LLC. Our affiliates will use your information only as described in this Policy.

Change of Control

If we are involved in a merger, acquisition or sale of all or a portion of its assets, your information may be shared or transferred as part of that transaction, as permitted by law and only for the purposes disclosed herein.

Privacy Shield

Skycore LLC complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union and the United Kingdom countries and Switzerland transferred to the United States pursuant to Privacy Shield.  Skycore LLC has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@skycore.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice (for personal data) or opt-in choice (for sensitive data) before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To request to limit the use and disclosure of your personal information, please submit a written request to privacy@skycore.com.

Skycore’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Skycore remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Skycore proves that it is not responsible for the event giving rise to the damage.

We may be required in certain circumstances to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In the event a customer end user transfers human resources data from the EU in the context of the employment relationship, Skycore will cooperate with the appropriate EU or Swiss data protection authorities.

In compliance with the Privacy Shield Principles, Skycore LLC commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Skycore LLC at: privacy@skycore.com

Skycore LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Cross-Border Data Transfer

Skycore is committed to safeguarding the transfer of your data between the EU and the US. We comply with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework to facilitate cross-border data transfer. We also rely on our Data Processing Agreement (DPA) which includes the European Commission’s Standard Contractual Clauses and is incorporated into our Terms of Service. In the event the Privacy Shield Framework does not apply to your EU Member State, the DPA will cover your data that is processed and transferred between the EU and US.

This Policy

Updates:

We periodically update this Privacy Policy. We will post any changes on this page and, if the changes are significant, we will send an email notification if we have your contact info and permission.

Questions:

If you have any questions concerning our privacy policy, or how we treat your data, please contact us at: privacy@skycore.com or mail us at Skycore LLC 397 Moody St. STE 202 Waltham MA 02453