Privacy Policy

Updated and Effective Date: MAY 20, 2024

Scope and Purpose of This Policy

 

This Privacy Notice (“Notice”) describes the manner in which SkySpecs, Inc. and its subsidiaries (collectively “SkySpecs”) collect, process, use, maintain, and disclose information from users of our websites and related services including Horizon Blade Management, Horizon CMS, and Horizon FAM, the Horizon mobile app, (together, “Solutions”), event participants, prospective customers, or other situations in which SkySpecs is a data controller. For purposes of this Notice, the terms “user,” “customer,” “you,” and “your” are meant to refer to the individuals about whom we may collect personal information, and at times may be used within the Notice interchangeably. “Personal Information” is any information that can be used to identify you as an individual.  This Notice also describes your rights with regard to Personal Information.

 

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the bottom of this Privacy Notice. If you are a job applicant, please refer to our Candidate Privacy Notice.

What Personal Information SkySpecs Obtains

To fulfill the purposes described in this Notice, SkySpecs may collect personal information such as your name, email address, or other business contact information, technical unique identifiers, authentication credentials, or other personal information you choose to provide to SkySpecs. For example, as described in specific sections of this Notice, personal data collected may include, among other things, the Internet Protocol (IP) address, browser information, device ID, the type of computer, and technical information about a user’s means of connection to our websites or web Portals, such as the operating system and the Internet service providers utilized and other similar information. When users are required to login to gain access to a particular website feature or web Portal, we collect usernames, passwords, and other login credentials to authenticate access to the feature or Solution.

SkySpecs’s websites and offerings are not directed at children, and SkySpecs does not knowingly collect or sell personal information from individuals under the age of 16.

How SkySpecs Obtains Personal Information

SkySpecs provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):

  • Vendors: SkySpecs works with third-party service providers to provide, support, and improve SkySpecs products and services and technical infrastructure, and for business services such as data analytics, data storage, payment processing, customer support, customer relationship management, order fulfillment, event registration, and website hosting. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to SkySpecs or as required by law. SkySpecs may integrate third-party technology to provide more advanced features.
  • For Legal Reasons: SkySpecs may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (3) meet our corporate and social responsibility commitments; (4) protect our and our customers’ rights and property; and (5) resolve disputes and enforce agreements.
  • Marketing and Analytics Partners: SkySpecs uses third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using SkySpecs websites, products and services; and to provide marketing for SkySpecs products and services. These third-party partners may receive information about you and your activities on SkySpecs’s website through third-party cookies placed on SkySpecs’s website. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool, available in the cookies settings in the Cookie Policy. Where required by law, SkySpecs will first obtain your consent before engaging in the marketing or analytics activities described.
  • Corporate Affiliates and Subsidiaries: SkySpecs shares personal information with corporate affiliates and subsidiaries to provide integrated and consistent experiences across SkySpecs products and services and to detect, investigate, and prevent fraud, abuse, and threats to public safety.

Change of Control or Corporate Transactions: SkySpecs may share personal data with actual or prospective acquirers, their representatives and other relevant participants in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

How SkySpecs uses your Personal Information

We may use collected information, including Personal Information, that you provide to us or that is provided to us by third-party sources for a variety of purposes, including but not limited to the following purposes:

Business and Operational Purposes – We may use the personal information in order to provide SkySpecs Services and Solutions, including in the course of running and maintaining our websites and webpages and infrastructure; troubleshooting our websites and Platforms; improving customer and user experience; providing technical support; improving current and developing new features, products, and services; order processing including payments and agreements; analyzing trends; to achieve other legitimate interests as well as where you have provided consent; conducting data analysis, identifying usage trends, and to evaluate and improve our Service, products, services, and your experience; and other business and operational-related purposes, including running and maintaining our Platforms. 

Marketing and Commercial Purposes – We may use the personal information to send marketing and other communications to you; to conduct joint marketing efforts with our partners; to conduct digital and direct marketing; determining the effectiveness of our promotional campaigns and improve our marketing efforts; to connect you with our partners and resellers; and other marketing and commercial related-purposes.

Security Purposes – We may use the personal information to help ensure the security and integrity of our websites and web Portals, our physical office locations, and of our offerings; to help prevent fraud; to maintain endpoint and network security; and other security-related purposes. 

Legal and Compliance Purposes – We may use the personal information to comply with our legal obligations; protect our intellectual property; enforce our legal rights; and other legal and compliance-related purposes. 

How SkySpecs Shares Personal Information

SkySpecs provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):

  • Vendors: SkySpecs works with third-party service providers to provide, support, and improve SkySpecs products and services and technical infrastructure, and for business services such as data analytics, data storage, payment processing, customer support, customer relationship management, order fulfillment, event registration, and website hosting. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to SkySpecs or as required by law. SkySpecs may integrate third-party technology to provide more advanced features.
  • For Legal Reasons: SkySpecs may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (3) meet our corporate and social responsibility commitments; (4) protect our and our customers’ rights and property; and (5) resolve disputes and enforce agreements.
  • Marketing and Analytics Partners: SkySpecs uses third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using SkySpecs websites, products and services; and to provide marketing for SkySpecs products and services. These third-party partners may receive information about you and your activities on SkySpecs’s website through third-party cookies placed on SkySpecs’s website. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool, available in the cookies settings in the Cookie Policy. Where required by law, SkySpecs will first obtain your consent before engaging in the marketing or analytics activities described.
  • Corporate Affiliates and Subsidiaries: SkySpecs shares personal information with corporate affiliates and subsidiaries to provide integrated and consistent experiences across SkySpecs products and services and to detect, investigate, and prevent fraud, abuse, and threats to public safety.
  • Change of Control or Corporate Transactions: SkySpecs may share personal data with actual or prospective acquirers, their representatives and other relevant participants in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

Retention of your Personal Information

We will retain your personal information for as long as needed to fulfill the purpose for which we collected it and for a reasonable period thereafter in order to comply with audit, contractual, or legal requirements, or where we have a legitimate interest in doing so. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may retain aggregated or de-identified data indefinitely or to the extent allowed by applicable law. We may retain personal information preserved in automatically generated computer back up or archival copies generated in the ordinary course of our information technology systems procedures.

Data Subjects Rights and Information for EEA, UK and Swiss Residents

If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California or another U.S. state with an applicable privacy law, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:

  • Inform you of what personal data we have about you that is under our control;
  • Amend or correct such personal data or any previous privacy preferences you selected, or direct you to applicable tools; and/or
  • Delete such personal data or direct you to applicable tools.

European Economic Area, United Kingdom, and Switzerland Residents

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

  • Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another service provider;
  • Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
  • Right to object to processing: This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes;
  • Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
  • Right to Withdraw consent: If SkySpecs has collected and currently processes your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

To exercise your rights as an EEA, UK or Swiss Resident, please click here. If you have any other questions about our use of your personal data, please send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

Legal Basis for Processing Personal Data (EEA, UK, and Swiss Visitors Only)

Depending on the specific personal data concerned and the factual context, when SkySpecs processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

  1. As necessary to perform a contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing SkySpecs products and services, creating and managing accounts, providing features and services to account owners, their users, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products and services.
  2. Where you provide consent: We rely on your prior consent in order to utilize cookies to engage and analytics partners to improve our websites via analysis of our website usage. you have the right to withdraw your consent at any time by visiting the cookie settings in our Cookie Policy. We also rely on your consent to facilitate conferences, webinars, communicate with you, conduct marketing services and coordinate your participation in other SkySpecs events.
  3. As necessary for SkySpecs’ legitimate interests and not overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the products and services (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our products and services and troubleshoot products and services; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and products and services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications related to the products and services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.
  4. Occasionally, your personal information may be collected in order for us to comply with a legal obligation, to perform a task for the public interest, or for the protection of your or another’s vital interests.

International Data Transfers

SkySpecs operates globally, which means Personal Information may be transferred to or accessed by SkySpecs in the United States of America, any SkySpecs subsidiary worldwide (see list of SkySpecs entities in the “SkySpecs Subsidiaries” section), or third parties and business partners as described above (and which are located in various jurisdictions around the world).

Therefore, by using SkySpecs products and services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.

SkySpecs protects and enables the global transfer of Personal Information in compliance with legal requirements, including by relying on contractual clauses and safeguards such as SkySpecs’ intercompany agreements and customer and vendor contracts which incorporate the European Commission’s Standard Contractual Clauses and UK International Data Transfer Addendum, as applicable and required.

Notice to California Residents

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to Us.

Categories of Personal Information SkySpecs Obtains

SkySpecs may collect, or process on behalf of our customers, the following categories of personal data, as described above:

  • identifiers (such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name in Contact Information and Registration Information);
  • commercial information (such as in Account Information); Examples: Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • internet or other electronic network activity information (such as interaction with our service, Device Information, Usage Information, webinars, Message, Collaborative Features, and the website);

Sources: We obtain the categories of personal information listed above from the following categories of sources: Directly from you. For example, from the forms you complete on our Products and Services including our websites. Indirectly from you. For example, from observing your activity on our Products and Services; Automatically from you. For example, through cookies that we or our Service Providers set on your device as you navigate through our Service; From Service and Analytics Providers. For example, third-party vendors to monitor and analyze the use of our Service, or other third-party vendors that we use to provide a Product or Service to you.

SkySpecs’ business and commercial purposes for use: SkySpecs uses personal data for the following business and commercial purposes: to provide SkySpecs Products and Services; for Product Research and Development; for Marketing and Promotions; Authentication, Integrity, Security, and Safety; to Communicate with you; and for Legal Reasons. We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA/CPRA), which may include the following examples:

  • To operate our Service and provide you with our Service.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Service.
  • To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Service, we will use that personal information to respond to your inquiry.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

 

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “How SkySpecs Uses your Personal Data” section.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.

Sharing: Categories of third parties to whom we disclose Personal Information for business purposes are also described in “How SkySpecs Shares your Personal Information.” We may share your personal information in the following situations:

  • With Service Providers:We may share your personal information with Service Providers to monitor and analyze the use of our Service and to contact you.
  • For business transfers and transactions:We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of SkySpecs assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates and Subsidiaries:We may share your information with our affiliates and subsidiaries, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include SkySpecs’ parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • With business partners:We may share your information with our business partners to offer you certain products, services or promotions.
  • With your consent: We may disclose your personal information for any other purpose with your consent.

SkySpecs may permit analytics services that are intended to analyze your interactions, based on your interactions with our website which may constitute a “sale” or “sharing” of data under certain state privacy laws. See “California & Other U.S. State Privacy Rights” for more information regarding your right to opt-out.

Retention: Retention criteria can be found under Retention, above.

California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:
  • The right to notice.You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
  • The right to know/access.Under CCPA/CPRA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you: The categories of personal information we collected about you; The categories of sources for the personal information we collected about you; Our business or commercial purposes for collecting or selling that personal information; The categories of third parties with whom we share that personal information; and The specific pieces of personal information we collected about you.
  • The right to deletepersonal information under certain circumstances.
  • The Right to Correct personal data you have the right to correct or rectify any inaccurate personal information about you that we collected. Once we receive and confirm your request, we will use commercially reasonable efforts to correct (and direct our Service Providers to correct) your personal information, unless an exception applies.
  • The Right to Opt out of the “sale” of personal data or “sharing” of personal information. We do not sell your personal data in the conventional sense. However, like many companies, we may use analytics services that are intended to analyze your interactions with our website, based on information obtained from cookies or other trackers. You can get more information and opt out of the use of cookies and other trackers on our website and app by clicking the cookie settings in our Cookie Policy. You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings. California residents may also set the Global Privacy Control (GPC) to opt out of the “sale” or “sharing” of your personal information for each participating browser system that you use.
  • The right to limit the use or disclosure of your sensitive personal data. SkySpecs does not collect, share, or sell sensitive personal data as defined by the California Consumer Privacy Act of 2018 as amended by The California Privacy Rights Act of 2020 (together with its implementing regulations, the “CPRA”). Accordingly, we do not use, disclose, sell, or share “sensitive personal information.”
  • The right to Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. you can do so by replying directly to our denial or emailing privacy@skyspecs.com
SkySpecs will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law. To exercise your rights, please click here. Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.  California residents may also call +1 734 413 7346. To opt out of the use of cookies on our sites, follow the instructions above. These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. To verify your identity, we may require you to log into your existing SkySpecs account (if applicable), give a declaration as to your identity under penalty of perjury, and/or provide additional information, such as providing at least two pieces of personal information relating to your account (which will be compared to information we have, such as profile information) or as we otherwise may already have in our possession, such as your email address and phone number. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

Changes to this Privacy Notice

SkySpecs may update this Privacy Notice and its last modified date at any time to reflect changes to our information practices. If we make significant changes in how we use your personal information, we will notify you by email if feasible or by means of a notice on this Website. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Us If you have any questions, inquiries, or complaints about this Privacy Notice or our privacy practices, please contact us at privacy@skyspecs.com. You may also contact us in writing at the following address:

Legal Team
SkySpecs, Inc.

312 S. Ashley St.
Ann Arbor, MI 48104
USA