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PRIVACY POLICY

Terms and definitions
My Sky Group - means My Sky SA, its major-owned affiliates and/or subsidiaries, and any company controlled by or controlling My Sky SA or under common control with My Sky SA.
My Sky - means My Sky SA, a company incorporated and existing under the laws of Switzerland, VAT: CHE 187.189.561 registered address at: Chemin de Budron A 14, 1052 Le Mont-sur- Lausanne, Switzerland.
Services - means Websites as well as any services provided by My Sky to the Client through Websites as well as provision of any My Sky products and services.
User (or "you") - means any individual who visits or directly works with Websites and uses the Services on behalf of Client as well as any individual which Personal Information could be accessed and/or processed by My Sky during the provision of My Sky Services to the Client.
Website- means websites mysky.com, lite.mysky.com and/or client.mysky.com together with any sub-sites, sub-domains, mobile and software applications, services, features and/or content associated therewith.
Client - means any individual or legal entity, to whom the Services are provided.
Personal Information - means any information related to an identified or identifiable individual, including but not limited to your name, address, passport information, date of birth, e-mail address, telephone number, billing address, job title, job industry, company/organization name, Account Information, account password, IP address and any other information you voluntarily provide or our Client/Operation company could provide to us, as well as any other non-public information that we associate with you that can identify you as an individual, including but not limited to: your location, salary scale, information on your expenses related to the business of the Client, information on your flights as part of your relations with Client (departure time, route, destination time, etc.), your certain credit card information.
Account Information - means Personal Information that we may collect during registration for a Service that we provide including without limitation: name, e-mail address, e-mail preferences, account password, job title, job industry, company/organization name, mailing address, and billing address.
Data Protection Laws - means laws and regulations of different jurisdictions relating to data protection, privacy, and/or information security, including all such laws governing use of Personal Information which applies to the respective party, processing Personal Information under the Agreement.
Subject matter
The purpose of the Websites is to provide Services to interested Clients. This Privacy Policy explains how personal information submitted to My Sky is processed according to the applicable Data Protection Laws.
This Privacy Policy covers Personal Information that My Sky collect whenever User interacts with My Sky, including when User visits Website or use the applications featured on it and when User corresponds with My Sky (such as by email or over the phone). It also covers personal data of User that My Sky may receive from third parties (i.e., from My Sky Clients or Operational companies).
Privacy Commitment
My Sky understands that privacy is important to you. My Sky is committed to preserving the privacy and confidentiality of your Personal Information. In conformity with that commitment, My Sky has developed this Privacy Policy to explain how My Sky collects, uses, and discloses such information.
User Acknowledgements
By using Services, you acknowledge that you have read and understand this Privacy Policy.
My Sky provides the Services in different jurisdictions. Please, be advised that, through your use of Services, which is governed by applicable Data Protection Laws of different jurisdictions and this Privacy
Policy, you are transferring your Personal Information to the country where Services are provided (or other jurisdictions as necessary for us to provide the Services), and you consent to that transfer.
Additionally, you acknowledge by use of Services or continuing work with Website that you understand that your Personal Information may be processed in countries where Data Protection Laws may be different or less stringent than in your home jurisdiction.
Finally, you acknowledge that Personal Information may become accessible as permitted by law, including to law enforcement and/or national security authorities.
When you contact My Sky by sending My Sky an e-mail, fax, or letter, My Sky will collect your address, fax number, or e-mail address and any Personal Information contained in the e-mail, fax, or letter you send My Sky.
Personal Information Collected via Technology
My Sky also uses tools that passively collect certain information when you access our Website ("Cookies"). Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a Website and stored on your computer's hard drive. Like many sites, My Sky uses Cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of Website.
The information that Cookies collect include: your IP address, unique device identification information, regional and language settings, browser type, and operating system, the network used to access Website, and information about your use of Website (such as how you navigate and move around Website). Depending on the applicable Data Protection Laws, this information may be considered as Personal Information.
While Cookies are often only used to measure website usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any personal information, they are also used at times to personalize a known visitor's experience of a website by being associated with profile information or user preferences. Over time this information provides valuable insight to help improve the user experience.
Personal Information from third-party sources
My Sky may receive Personal Information about you from other third-party sources, including My Sky's clients, operation companies, service providers and business partners. Anything we receive from these partners may be combined with information provided by you.
We also integrate with third party service providers to facilitate payments for My Sky Services or to access information on your transactions related to the business of My Sky`s Client.
Purposes of the data collection
Your Personal Information is only processed by My Sky for the following purposes:
- Provision of My Sky Services
  First and foremost, we use your personal data to provide our Clients with MySky Services related to the analysis and verification of Client`s costs and expenses incurred in connection with ownership and\or maintenance of the Aircraft. MySky Services inter alia implies analysis of Client`s crew maintenance costs as well as other expenses related to the aircraft operation.
- Access and use of Website or Services
  We will record information necessary to provide you with access, for the operation of Website and for us to comply with security and legal requirements in relation to operating Website, such as passwords, IP address, location and browser settings. We also collect information about your activities during your visit in order to personalize your website experience, such as recording your
  preferences and settings, and to collect statistics to help us improve and further develop Website, our products and services.
- Marketing purposes
The Personal Information you provide to My Sky, as well as the Personal Information My Sky has collected about you indirectly, may be used by us for marketing purposes, i.e., to keep you informed about events, products, services and solutions that My Sky provides and which may complement an existing product portfolio. You may at any time choose not to receive marketing materials from My Sky by following the unsubscribe instructions included in each e-mail My Sky may send, by indicating so when My Sky call User, or by contacting My Sky directly.
- Responding to your request for information, order, or support
  When you contact us (online or offline) in connection with a request for information, to order a product or service, to provide you with support, My Sky collects information necessary to fulfill your request, to grant you access to the product or service, to provide you with support and to be able to contact you. When you provide your name and contact information to register in connection with such a request, the registration may serve to identify you when you visit Website, answering billing, account, or technical inquiries from you.
- Meeting legal and regulatory requirements and protecting the rights and property of My Sky Group and others
  My Sky may also use or share your Personal Information to protect the rights or property of My Sky, My Sky Group, My Sky's contractors or others when My Sky has reasonable grounds to believe that such rights or property have been or could be affected. In addition, My Sky reserves the right to disclose your Personal Information as required by law, and when we believe that disclosure is necessary to protect My Sky's or My Sky Group`s rights, or the rights of others, to comply with a judicial proceeding, court order, or legal process served on Website.
- Contacting employees of our Clients
Client could also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors, and authorized users) for purposes such as contract management, fulfillment, delivery of Services, provision of support, invoicing and management of the services or the relationship.
Transfer of Personal Information within My Sky Group
As a global company, we may share information about you with our subsidiaries world-wide (within My Sky Group) and transfer it to countries in the world where we do business in accordance with this Privacy Policy.
Between My Sky controlled subsidiaries, we only grant access to Personal Information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, My Sky uses suppliers located in various countries to collect, use, analyze and otherwise process Personal Information on its behalf.
Protection of Information
My Sky intends to protect your personal information and to maintain its accuracy. My Sky implements reasonable physical, administrative and technical safeguards to help us protect your personal information whether stored electronically or in paper format from unauthorized access, use and disclosure. For example, we encrypt certain sensitive personal information where we deem appropriate when we transmit such information over the Internet and we periodically test, assess, and evaluate the effectiveness of our safeguards. My Sky also require that its suppliers protect such information from unauthorized access, use and disclosure.
The security of your Personal Information is important to My Sky, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While My Sky strives to use commercially acceptable means to protect User's Personal Information, we cannot guarantee its absolute security.
No method of safeguarding information, however, is completely secure. While we use measures designed to protect Personal Information, we cannot guarantee that our safeguards will be unconditionally effective or sufficient. In addition, you should be aware that internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing our Services is or will be completely secure.
Your Rights
You have a variety of legal rights regarding the collection and processing of your Personal Information. You may exercise these rights to the extent they apply to you under applicable Data Protection Laws.
You have the following rights and options:
- Information and rectification
  You can receive information at any time and at no charge about whether we are processing personal data related to you and also about which information we are specifically storing about you. You are also entitled to receive a copy of the stored information. You can also have errors in your data corrected and missing information completed.
  In order for us to provide you with information, please send us a brief email to: info@mysky.com or call us on: +41 22 575 2554.
- Erasure, restriction of processing and "right to be forgotten"
  You can request that your data be erased and its processing restricted.
  For the deletion of your data please send us a brief email to: info@mysky.com or call us on: +41 22 575 2554.
  - Data portability
  Where applicable, you also have the right to have your Personal Information transmitted to you or to another data controller in a structured, standardized and machine-readable format, as long as processing is performed on the basis of consent or contract using automated procedures. This does not apply, however, where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. You also have the right to have the Personal Information transmitted directly from one data controller to another, provided that it is technically feasible to do so and does not infringe upon the rights and freedoms of other persons.
- Withdrawal of consent, objecting to processing
  You can withdraw your previously-given consent at any time with effect for the future by contacting the aforementioned address.
  Moreover, you have the right to object to the processing of your Personal Information at any time (where such processing is based on a legitimate interest) for reasons arising from your particular circumstances. This also applies to profiling activities based on these provisions. If such an objection is received, we will cease to process the Personal Information unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, of if the processing is for the establishment, exercise or defense of legal claims.
  If we are processing personal data for the purpose of direct marketing, you have the right to object to the processing of your personal data at any time for the purpose of such marketing by contacting the aforementioned address. This also applies to profiling insofar as it is connected with such direct marketing. You also have the right to file an objection for reasons arising from your particular
  circumstances against processing of your personal data that we are engaged in for scientific, historical research or statistical purposes, unless such processing is required to perform a task that is in the public interest.
- Right of complaint
  You also have the right to submit a complaint to the competent supervisory authority and to seek legal remedies. The supervisory authority to whom the complaint was submitted will notify the complainant about the status and result of their complaint, including the option of seeking a legal remedy through a court of law.
Notification of changes
This Privacy Policy is effective as of 01, January, 2021.
My Sky may change this Privacy Policy from time to time. The revised Privacy will be posted here with an updated revision date. My Sky encourages Users to check back periodically for any changes or updates.
My Sky suggests that you check this Website section for updates, as My Sky will update this Privacy Policy from time to time. By continuing to use Website after such changes have been made, you acknowledge and agree that you have read, understood and accepted the changes.
Retention
We will not retain your Personal Information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g., audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.
Personal Information will be retained for as long as Client Account is active or as needed to provide the Services.
We also have procedures in place to prevent unauthorized access to, and the misuse of Personal Information available at the link: https://mysky.com/privacy_policy
If you wish to request that we no longer use Account Information to provide you Services, contact us by email address: info@mysky.com or call us on: +41 22 575 2554.
Personal Data Stored in the Client`s Account
With dedicated logins provided to User for My Sky's Client Account, Client may manage its contacts towards My Sky. It is in Client's responsibility to ensure that the Personal Information Client process in this context as a data processor have been lawfully collected by Client. The administration tools available to Client in the Client Account allow Client to comply with his or her obligations as a data processor of this data, i.e. ensuring that the data subjects' right, whose personal data User Client, can be executed by Client.
Contact Information
Where this is relevant, the controller of your personal information is My Sky SA, a company incorporated and existing under the laws of Switzerland, VAT: CHE 187.189.561 registered address at: Chemin de Budron A 14, 1052 Le Mont-sur-Lausanne, Switzerland, unless indicated otherwise.
Where My Sky or a subsidiary it controls (not established in the European Economic Area (EEA)) is required to appoint a legal representative in the EEA, the representative for all such cases is
My Sky SA, a company incorporated and existing under the laws of Switzerland, VAT: CHE 187.189.561 registered address at: Chemin de Budron A 14, 1052 Le Mont-sur-Lausanne, Switzerland.
Please note that My Sky is not the controller in situations such as:
- Personal Information processed in connection with a contractual relationship, or with entering into a contractual relationship with a specific My Sky subsidiary. In this case the controller of personal information is the My Sky contracting subsidiary, which is the legal entity with which you or your employer have, or will have, the contract.
- Personal information collected on the physical site or location of an My Sky subsidiary. In this case that subsidiary is the controller of the personal information.