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    Skywell Software Privacy Policy

    “SKYWELL SOFTWARE” WEBSITE

    The confidentiality of your personal data is important to Skywell Software. Therefore, this Privacy Policy was developed by the Administration of the Skywell Software website specifically for its users.

    This Privacy Policy of personal data (hereinafter referred to as the "Privacy Policy") applies to all information that the Skywell Software website (hereinafter referred to as the "Site"), located on the domain name skywell.software, can receive about the User during the use of the Site, programs and its products.

    DEFINITION OF TERMS

    The following terms are used in this Privacy Policy:

    Site Administration – authorized employees who manage the Site, acting on behalf of "Skywell Software", organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing of personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.

    Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an email, location data, telephone number, or more factors specific to that natural person.

    Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

    Confidentiality of personal data is a mandatory requirement for the Site Administration or for other persons who have access to personal data to prevent their dissemination without the consent of the personal data subject or the presence of other legal grounds.

    The Site user (User) – a person who has access and using the Site "Skywell Software" through the Internet.

    Cookies – a small piece of data sent by the web server and stored on the User's computer that the web client or web browser sends to the web server each time in the HTTP request when they try to open the page of the corresponding site.

    IP-address – a unique network address of a node in a computer network built on the IP protocol.

    1. ACCEPTANCE OF PRIVACY POLICY

    1.1. This Privacy Policy sets forth the obligations of the Site Administration to not disclose and protect the privacy of personal data that the User provides upon the request of the Site Administration on the “Skywell Software” Site when completing the information forms.

    1.2. We need to process your personal information in order to manage our business and provide you with services. By accepting our Terms of Use, you acknowledge that you have read and understood this Policy, including how and why we use your information. If you do not want us to collect or process your personal information in the ways described in this Policy, you must not use the Site services.

    1.3. Using the services, you acknowledge that Skywell Software will use your information in Ukraine and any other country where Skywell Software operates. We will share personal information only with those countries that are permitted by law to transmit personal information, and we will take steps to ensure that your personal information continues to receive adequate protection.

    1.4. This Privacy Policy applies only to the Skywell Software Site. The administration of the Site does not control and does not bear responsibility for the websites of third parties with links available on the Site for the User.

    2. COLLECTING OR RECEIVING PERSONAL DATA

    2.1. During the provision of our services, we collect or receive your personal information by filling out the feedback form on the Site, which includes the following information:

    2.1.1. name and surname of the User;

    2.1.2. contact phone number of the User;

    2.1.3. e-mail of the User.

    2.2. Automatic information collection: Skywell Software receives and records information about the IP address with a large number of attempts to enter the administrative panel incorrectly. This is done to protect the Site from possible hacking attempts.

    2.3. Location information: we can collect information about your use of the services for advertising, analytics, content maintenance and service protection, including your IP address, browser information (including information sources), device information and location information (if turned on by you) provided by your device.

    2.4. Information for analytics: We use data analytics to provide site functionality and improve services. We use analytics software for understanding the Site’s functionality. This software can record information, for example, how often you visit the Site, what happens in applications, aggregated usage, performance data, application errors, debugging information and source of opening the Site. We do not link the information stored in the analytics software with any personal information that you send.

    3. CONTROL OVER PERSONAL DATA

    3.1. We know that Users of our Site value the control over their personal information, so Skywell Software gives you the opportunity to provide, edit or delete certain information, and also choose how we will contact you. You can change, correct or delete information by contacting us at dpo@skywell.software.

    3.2. You can also monitor the receipt of messages from Skywell Software using tools in e-mails. Skywell Software can send you messages about services or our activities. Some of these messages are necessary, since they are service messages (for example, organizational or legal notices). Others are not mandatory messages, for example, newsletters.

    3.3. We cooperate with third parties to manage our advertising on other websites. Our third-party partners may use cookies or similar technology to provide you with ads based on your actions and viewing interests.

    4. USE, EXCHANGE AND DISCLOSURE OF INFORMATION

    4.1. When you use the Site, we collect, use, share and otherwise process your personal information, as described in this Policy. We rely on a number of legal grounds to use your information this way. These legal grounds include:

    • Necessary to fulfill contractual obligations in our Terms of Use and the provision of services to you;

    • You have agreed to processing, which you can withdraw at any time;

    • Necessary for our or third parties’ (such as visitors, members or partners) legitimate interests;

    • You directly publish information.

    Please note that we rely on your consent:

    - To send marketing messages;

    - To third-party data exchange related to advertising, if applicable;

    - Use of location data for promotional purposes.

    4.2. When we process your information on the basis of legitimate interests, we do the following:

    Providing and improving our services: we can use your information to improve and customize our services, including sharing your information for such purposes. We do it in order to improve our services for our Users.

    Keeping our services safe and secure: we can also use your information to ensure safety and security, including sharing your information for such purposes, including strengthening our community's protection from spam, harassment, intellectual property infringement, crime and security risks of all types.

    We respect your privacy. Skywell Software will not disclose your name, email address or other personal information to third parties without your consent, except as provided in this Policy.

    We use your information to provide and improve our services and products, for targeted online and offline marketing, to contact members or interested parties and for general research and comprehensive reporting.

    Law and security: Skywell Software may also collect, store, process or transfer your personal information to a third party in the following limited circumstances: in response to legitimate requests from government authorities, including to meet legitimate national security or law enforcement requirements; for the protection, establishment or exercise of our legal rights or protection from legal action; execute a subpoena, court order, litigation or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, to prevent unavoidable physical damage or financial loss or investigation, to prevent or take action against illegal activities, suspicion of fraud, threat to our property or breach Skywell Software Terms of Use.

    Affiliated companies: Skywell Software is associated with various enterprises and closely cooperates with them for a variety of purposes, including helping us to perform and improve the services.

    Aggregate information: Skywell Software can share information with business partners, but it will be aggregated and de-personalized so that personal information is not disclosed.

    Service Providers: Skywell Software may also engage third-party companies and individuals (such as analysts and security service providers) to help us manage, provide and sell the services. These third parties have limited access to your information, can use your information only to perform these tasks on our behalf and are not required to disclose or use your information for other purposes. Participation of service providers is often necessary for us to provide you with the services. In some other cases, these service providers are not absolutely necessary to provide the Services, but help us do it better, for example, by helping us to conduct research on how we could better serve our Users. In these latter cases, we have a legitimate interest in working with service providers to improve our services.

    Third parties: Third-party plug-ins can also collect information about your use of the Site. For example, when you upload a page to the Site that has a social plug-in from a third-party site or service, such as the "How" or "Send" button, you also download content from this third-party site. This site can request cookies directly from your browser. These interactions are subject to the privacy policy of a third-party site. In addition, certain cookies and other similar technologies on the Site are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognize your computer or mobile device every time you use the services. Remember, when you use third-party sites or services, your own terms and privacy policy will govern the use of these sites or services by you. Skywell Software selects and manages these third-party technologies that are hosted on its sites and applications. However, these are third-party technologies, and they are subject to the third-party privacy policy. We rely on your consent to collect and read non-technical cookies.

    Skywell Software does not control the privacy policy of third parties, including other members who sell using users services or API. Skywell Software is not responsible for maintaining the confidentiality or security of these sellers, API users or other websites on the Internet, even related to or from the Services. We recommend that you read the privacy policy and ask questions to third parties before disclosing your personal information. For the purposes of European law, these vendors and API users are independent data controllers.

    5. SECURITY MEASURES

    5.1. The security of your personal information is important to us. We comply with the generally accepted standards for the protection of personal information provided to us, both during the transfer and after its receipt.

    Skywell Software encrypts your personal information using Secure Socket Layer (SSL) technology. Skywell Software follows generally accepted industry standards for the protection of personal information provided to us, both during the transfer and after its receipt.

    6. DATA STORAGE

    6.1. Skywell Software will retain your information only as long as it is necessary for the purposes set forth in this policy or for providing you with the services. If you no longer want Skywell Software to use your information to provide you with the services, you can write us a request to delete your personal information. We also store log files for internal analysis. These log files are usually stored for a short period of time, except when they are used to ensure the security of the Site, to improve the functionality of the Site, or we are legally bound to keep them for longer periods of time.

    7. YOUR RIGHTS

    7.1. You have certain rights regarding your information, which we process. If you want to manage, modify, restrict or delete your personal information, you can do so by contacting us at dpo@skywell.software. Upon request, Skywell Software will provide you with information on whether we retain your personal information. In some cases, when we process your information, you may also have the right to limit the ways in which your personal information is used. In certain circumstances, you also have the right to request the removal of your personal information. If you need additional help, you can contact Skywell Software via one of the channels listed below in the "Contacts" section. We will respond to your request within a reasonable time.

    7.2. If we process your information on the basis of our legitimate interests, as described above, or in the public interest, you may object to this processing in certain circumstances. In such cases, we will stop processing your information if we do not have a legitimate reason to continue processing or where it is necessary for legal reasons. When we use your data for direct marketing purposes, you can always opt out using a link to unsubscribe from such messages.

    8. CONCENT WITHDROWAL

    8.1. If you have given your consent to our processing of your information and the use of the Services, you have the right to withdraw your consent. For example, you can withdraw your consent to email marketing using a link to unsubscribe from such messages. You can at any time withdraw your consent to our processing of your information and your use of the Services by sending an e-mail to dpo@skywell.software requesting your personal information to be deleted.

    9. CHANGES TO PRIVACY POLICY

    9.1. We may change or update this Policy from time to time. If we believe that the changes are significant, we will notify you by doing one or more of the following:

    - Publication of changes on our Site;

    - Sending you e-mail or messages about the changes.

    We recommend that you regularly check and view any updates.

    10. CONTACTS

    If you have questions:

    Contact Skywell Software info@skywell.software.

    Send an e-mail to Data Protection Officer of Skywell Software, at dpo@skywell.software.

    Write to us at one of the following addresses:

    In Ukraine: 01133, Kyiv, Yevhena Konovaltsia St., 36d, Skywell Software LLC.