SKYLINK PRIVACY POLICY
Last updated:11/17/2023
Jarvis Industries, Inc., (“SkyLink,” “we,” “our,” “us”) provides software to help travel agents and businesses (our “Customers”)leverage AI at enterprise scale.
This Privacy Policy explains how we collect, use, and share the personal information that we gather on the subdomains and websites on https://www.tryskylink.com/(“Sites”),that we collect when you contact us directly to become a Customer or to obtain more information, or that we collect directly through our Customer’s use of our travel products and services (“Services”), such as through our chat and customer messaging systems, and through customer service requests.
This Privacy Policy does not apply to the way we process information on behalf of our Customers. We process and safeguard information on behalf of our Customers in accordance with our agreements with our Customers.
If you are a consumer of one of our Customers, please contact your travel agency or business directly for information regarding how they use and share your personal information gathered from our Services.
Please see below to learn more about our Privacy Policy:
- Whose Personal Information We Collect
- Information We Collect
- How We Use Your Information
- How We Share Your Information
- How We Respond to ‘Do Not Track’ Signals
- Cookies
- Children’s Privacy
- Change of Control
- Data Security
- Data Retention
- Policy Updates
- Contact Information
- Privacy Rights & Additional Disclosures for California Residents
- Privacy Rights & Additional Disclosures for EEA & UK Individuals
Whose Personal Information We Collect
SkyLink obtains information from various entities. These entities are defined below by what they are referred to in this Privacy Policy and when their information is collected. Entities may overlap and are not exclusive categories.
- Website Visitors: when you visit this website or contact us directly for information.
- Customers: when you provide information to our chat or customer messaging system, engage SkyLink for a free demo or paid services for training, support, or customization of SkyLink software.
- End Users: when we collect and process information from travelers of a Customer on the Customer’s behalf.
- Service Providers: when you become a service provider to SkyLink.
- Employees and Applicants: through the SkyLink job candidacy process.
The use of “you” and “your” throughout this Privacy Policy will, depending on the context, refer to a SkyLink Website Visitor, Customer, or End User.
Information We Collect
InformationYou Give Us. You may give us information by enteringinformation into our chat or customer messaging system, signing up for anonline account, entering information through our online forms or surveys, inputtinginformation while using our services, or contacting us by phone or email forinformation or customer service.
The categories of information include:
● Identifiers, such asreal name, Internet Protocol address, email address, or other similaridentifiers.
● Categories of personalinformation described in Section 1798.80(e) of the California Civil Code, suchas name, address, telephone number, employment, or employment history.
● Commercial information, includingrecords of travel products or services purchased, obtained, or considered, orother travel purchasing or consuming histories or tendencies.
● Internetor other electronic network activity information, such as information regardinga consumer’s interaction with an Internet website, application, oradvertisement.
● Professional oremployment-related information.
● Inferences drawn fromthe above categories of information.
The categories ofsensitive information include:
· Contents of your chat communications unless we are the intended recipient of the communication.
Information About End Users We Collect from SkyLink Customers.
If your travel agency or business has engaged the services of SkyLink, we may collect information from you on their behalf as a service provider. This information may be passively recorded from interactions on your browser or through integrations with your travel management software. This information may include:
The categories of information include:
● Identifiers, such as realname, postal address, online identifier, Internet Protocol address, emailaddress, account name, or other similar identifiers.
● Categories of personalinformation described in Section 1798.80(e) of the California Civil Code, suchas name, address, telephone number, employment, or employment history.
● Commercial information,including records of travel products or services purchased, obtained, orconsidered, or other travel purchasing or consuming histories or tendencies.
● Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
● Inferences drawn from the above categories of information.
The categories ofsensitive information include:
· Contents of your chatcommunications unless we are the intended recipient of the communication.
For End Users, weprocess and safeguard information on behalf of our Customers. Please contactyour travel agency or business directly for information regarding how they use andshare your personal information gathered from our Services.
Information We Automatically Collect.
Like many website operators, we collect information that your browser sends whenever you visit our Sites. This includes log data, such as your computer’s IP address, browser type, browser version, the pages of our Sites that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them.
Information We Collect From Third Parties. If you access our Sites or Services through third parties (e.g., Facebook or Google), or if you share content from our Sites or Services to a third-party social media service, the third-party service may send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.
How We Use Your Information
We use your personal information for the following purposes:
● To provide you with the Services and Sites, which includes:
- maintaining and servicing accounts,
- providing customer service,
- processing and fulfilling orders andtransactions,
- verifying customer information,
- processing payments, and
- providing advertising or marketing services to you.
● To provide analytic services, such as analyzing customer usage and improving services offered.
● To conduct market research and project planning.
● To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and maintain the overall quality and safety of our Sites.
● To share your website visitor activity, through website cookies, with third-party marketing partners to market our services on our Sites and other websites that you may visit.
● To fulfill our legal and financial obligations.
● To provide you with employment opportunities.
Marketing: We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that maybe of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Information” section below. You will still continue to receive service-related messages concerning products and services you have purchased(unless we have indicated otherwise).
How We Share Your Information
To Users or the Public with Your Consent. We may share your information with other users or the public with your consent. The settings you choose will determine how much information is shared with other users and/or the public.
Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. The service providers we use help us to:
- Run, operate, and maintain our Sites and Services through third-party platforms and software tools;
- Perform content moderation and crash analytics;
- Run email and mobile messaging campaigns;
- Perform marketing analytics;
- Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
- Provide payment attribution; and
- Provide technical and customer support.
Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.
Aggregated Data.We may also aggregate or otherwise strip information of all personallyidentifying characteristics and may share that aggregated, anonymized data withthird parties or publish it. This data does not personally identify you andhelps us to measure the success of our Sites and its features and to improveyour experience. We reserve the right to make use of any such aggregated dataas we see fit.
ThirdParty Marketing and Advertising Organizations. Withrespect to website cookies, we may share your information with third-partymarketing and advertising partners to market our services on our Sites andother websites that you may visit.
DisclosuresRequired by Law. We may be required to disclose yourdata in response to lawful requests by public authorities, including to meetlaw enforcement requirements. We may be under a duty to disclose or share yourpersonal information to comply with any legal obligation, to enforce or applyour terms and conditions and other agreements, to protect our rights, property,or safety, or to protect the rights, property, or safety of others. Thisincludes exchanging information with other companies and organizations for thepurposes of fraud protection.
How We Respond to ‘Do Not Track’ Signals
Some browsers provide you with a way to signal that you do not want your browsing activity to be tracked. The Services may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.
Cookies
To make our Sites and services work properly, we sometimes may place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.
Google Analytics. We may use Google Analytics. We use the information we get fromGoogle Analytics only to improve the Sites. We do not combine the informationcollected through the use of Google Analytics with personally identifiableinformation. Please refer to Google’s Privacy Policy for more information. You may also choose to download the GoogleAnalytics opt-out browser add-on.
You may wish to restrictthe use of cookies. Please be aware that some of the features of our Sites maynot function correctly if you disable cookies. Most modern browsers allow youto change your cookie settings. You can usually find these settings in theoptions or preferences menu of your browser. To understand these settings, thefollowing links for commonly used browsers may be helpful:
- Cookie settings in Chrome
- Cookie settings in Firefox
- Cookie settings in Microsoft Edge
- Cookie settings in Safari web and iOS
Personalized Advertising. We may also use targeted advertising cookies, such as Google Ads, to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.
Children’s Privacy
The Sites are not directed at individuals under the age of16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us using the contact details provided at the end of this Privacy Policy. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.
Change of Control
Personal information may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your personal information.
Data Security
We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of personal information obtained through the Sites, we cannot ensure or warrant the security of any information you transmit to us.
Data Retention
We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
Policy Updates
This Privacy Policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal information to our Sites. The date the Privacy Policy was last updated is indicated at the top of this page.
Contact Information
If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details:
privacy@tryskylink.com
Privacy Rights & Additional Disclosures for CaliforniaResidents
California law provides state residents with certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights. If you would like to exercise any rights or inquire as to whether such rights are available to you, please email us at privacy@tryskylink.com.
Request for Information or Deletion. Residents of California have the right to know whether we are processing your personal information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:
· The categories of personalinformation we collect about you.
· The categories of sources from whichyour personal information is collected.
· The business or commercialpurpose(s) for collecting, selling, sharing, or disclosing your personalinformation, and the categories of personal information disclosed for suchpurpose(s).
· The categories of third parties withwhom we share your personal information.
· The categories of personalinformation we have sold, if any, about you and the categories of third partiesto whom your personal information was sold, by category or categories ofpersonal information for each third party to whom the personal information wassold.
· Thespecific pieces of personal information we have collected about you.
Inaddition, you may have the right to request we delete your personalinformation.
Requestfor Correction.Residents of California have the right to request the correction orrectification of inaccurate information in the resident’s personal information.
Requestfor Portable Data. Residents of California have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.
Opting Out of Cookies and Sale/Sharing Using Online Tracking Technologies. Our use of online tracking technologies may be considered a “sale” or “sharing” under applicable law. Residents of California may have the right to opt out of being tracked by these third parties by clicking the Your Privacy Choices / Do Not Sell or Share My Personal Information link at the bottom of our website and selecting your preferences.
Limiting the Use of Sensitive Personal Information. Residentsof California have the right to direct us to use or disclose sensitive personalinformation only for providing goods or services, or as otherwise minimallypermitted under applicable law. However, we do not use or disclosesensitive personal information for any purpose other than providing our goodsnd services to you, or as otherwise minimally permitted under applicable law.
Third Party Marketing. If you are one of our customers, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. However, we do not disclose your personal information to third parties for the third parties’ direct marketing purposes.
Automated Processing & Profiling. Residents of California have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.
Right to Equal Service & Price. Residents of California have the right to receive equal service and price, evenif you exercise a privacy right.
Verification Process for Exercising Rights. To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.
If you arean authorized agent wishing to exercise rights on behalf of a state resident,please contact and provide us with a copy of the California resident’s writtenauthorization designating you as their agent. We may need to verify youridentity and place of residence before completing your rights request.
Privacy Rights & Additional Disclosures for EEA & UK Individuals
LawfulBases for Processing (EEA and UK Individuals). If you are from the European Economic Area (EEA) or United Kingdom (UK), our legal bases for collecting and using your personal information is as follows:
● The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration.
● Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improvement of our services.
● Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your Personal Information to record your requests to exercise your rights and to verify your identity for such requests.
● Consent you providewhere we do not rely on another legal basis. Consent may be withdrawn at anytime.
● In some limited cases, we may also have a legal obligation to collect personal information from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in the “How We Share Your Information” section.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at the end of this Privacy Policy.
EEA or UK Individuals’ Rights. If you are from the EEA or UK, you have the right, under certain circumstances, to:
● Access your personalinformation;
● Correct inaccurateinformation in your personal information;
● Request erasure of yourpersonal information without undue delay;
● Request restriction of,in certain circumstances, the processing of your personal information;
● Request receiving a portable copy of your personal information held by us, and to have that portable copy transmitted to another controller; and
● To object to the processing of your personal information.
To exercise any of these rights, contact us using the contact details provided at the end of this Privacy Policy, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.
Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.
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