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Privacy Policy

SKYPATH LIMITED

Privacy Policy

Skypath Limited (“we”, “Us”, “our” or “Skypath”) is Committed to protecting and respecting your Privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, when you visit our website will be processed by us.

It is important that you read this privacy policy together with any other policy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

For the purposes of Data Collection Act 1998 and, when it comes into force, the General Data Protection Regulation ((EU2016/679)(“GDPR”) and all successor legislation to the Data Protection Act 1998 and the GDPR (the “Data Protection Legislation”), the data controller is Skypath Limited (company no. 04092174) of 8C High Street, Southampton, Hampshire, SO14 2DH.

1. Information we collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (known as “anonymous data”).

We may collect, store and transfer the following data about you:

• Information you give us. This is information about you that you give us by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you apply for our services, subscribe to our publications or newsletters, request marketing to be sent to you, complete a survey, when you report a problem with our site, and when you give us feedback. The information you give us may include your name, address, job title, phone number, date of birth, and any of information contained in your CV, if you provide one.

• Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:

o Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

o Information about your visit, including the full Uniform Resource (URL), clickstream to, through and from our site (including data and time), products you viewed or searched for, page response times, download errors, length of visit to certain pages, page interaction information(such as scrolling, clicks, and mouse -overs), methods used to browse away from the page, and any phone number used to call our customer service number.

• Information we receive from other sources. We may receive personal data about you from various third parties including, for example, business partners, sub-contractors in technical services, analytics providers and search information providers, where these third parties consider that your information might be relevant to the services we offer, or where those details are made available for download on job boards and other web recruitment services, in accordance with the terms and conditions of those services.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and fail to provide that data when required, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. Uses made of your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal information

• To carry out our obligations arising from any contracts entered into between you and us or take steps at your request before entering into any contracts;

• To comply with any legal obligations to which we are subject; or

• Where it is necessary for our or third party’s legitimate interests, including for the purposes of preventing fraud, except where such interests are overridden by your interests or fundamental rights and freedoms.

Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email.

3. Purpose for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new client and internal record keeping Identity and contact details, job title Performance of a contract with you

To manage our relationship with you which will include:

a) Notifying you about changes to our terms or privacy policy;

b) Asking you to leave a review or take a survey Identity, contact details, and marketing preferences a) Performances of a contract with you

b) Necessary to comply with a legal obligation

c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisement to you and measure or understand the effectiveness of the advertising we serve to you Identity, contact details, technical data such as IP address, marketing preferences Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical data such as IP address Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or service that may be of interest to you Identity, contact details, usage data and marketing preferences Necessary for our legitimate interest (to develop our products/services and grow our business)

To communicate your details to a prospective employer, where we have first obtained your agreement to making the approach Identity information and contents of your CV With your explicit and informed consent, prior to passing the information over.

Marketing

We stive to provide you with choices regarding certain data uses, particularly around marketing and advertising.

We may use your identity, contact details, usage data, technical data and marketing preferences to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or filled in a form on our website or if you provided us with your details when you entered a survey, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any company outside Skypath for marketing purpose.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Change of purpose

We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosure of your information

We may have to share your personal information with the third parties set out below, or any other third parties notified to you, for the purpose set out in paragraph 3 above:

• Professional advisers including lawyers, bankers, auditors and insures based in the UK.

• Regulators and other authorities who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer or mere parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

• Fraud prevention agencies.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purpose and only permit them to process your personal data for specified purpose and in accordance with our instructions.

5. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

However, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. Retention

We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period of personal data, the potential risk of harm from unauthorised use of disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirement.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purpose in which case we may use this information indefinitely without further notice to you.

7. Your rights

Under the Data Protection Legislation, you may be entitled to the following rights:

• Where you have provide your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting our Financial Director at Skypath Limited, 8C High Street, Southampton, Hampshire, SO14 2DH.

• You can ask us to rectify any inaccuracies in the personal information that we hold about you.

• To request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

• To object to our processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• To restrict our processing of your personal data (a) if you want us to establish the data’s accuracy; (b0 where our use of data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• To request a copy of your personal data from us in a commonly used and machine- readable format or that we transmit your personal data to another data controller.

• Not to be subject to automated decision- making, including profiling, which has legal or other significant effects on you.

• To access information held about you. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You can exercise any of the above rights at any time by contacting our Financial Director at Skypath Limited, 8C High Street, Southampton, Hampshire, SO14 2DH.

8. Links to and from our site

Our site may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

9. Changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changed during your relationship with us.

10. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changed to our privacy policy.

11. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Our cookie policy is available at https://skypath-ltd.staging.krakatoa.eu-2.volcanic.cloud/privacy-policy

12. Contact

Questions, comments and requests regarding this privacy policy are welcomed and also should be addressed to our Financial Director at Skypath Limited, 8C High Street, Southampton, Hampshire, SO14 2DH.

If you have any complaints relating to our privacy policy or our use of your personal data, please contact our Financial Director at Skypath Limited, 8C High Street, Southampton, Hampshire, SO14 2DH.You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Further information can be found at www.ico.org.uk