Last Updated: March 1, 2020
1. Types of information we collect and why
2. How we use the Information
3. How we Share the Information
5. Data Integrity and Access to Your Information
6. Retention Period
7. Children Under 13
8. Notice to EU/UK/Swiss Users
Permitted Purposes for Processing Information
International Transfer of Information
9. Other International Users
10. Notice to California Resident Users
Categories of Personal Information Collected
Exercising your Rights
Response & Timing
Other California Privacy Rights
11. Data Breach
12. Contact Information
1. TYPES OF INFORMATION WE COLLECT AND WHY
o Account Registration: To enable using certain features of onesky.xyz or the OneSky and Systems Tool Kit (“STK”) Software products (“Software”), we collect your name, mailing address, email address, your IP address, the name of your organization, telephone number, your account number, your account password, and your account preferences.
o Feedback/ Support: If you contact OneSky via email or phone, we collect your name, email address, and any additional information that you provide us during that communication.
o Email interconnectivity: If you receive an email from us, we use certain tools to capture information related to when you open the email, click on any links or banners that it contains, and the pages you visit on our website.
o Directly from you: If you register for an event (webinar, training class, conference, expo, etc.) hosted by or in attendance by OneSky, sign up for a contest (sweepstake, challenge, giveaway, etc.), or sign up for our newsletter, we could collect your name, mailing address, email address, telephone number, job title, the name of your organization, your areas of interest, your dietary restrictions (if food is provided), and your T-shirt size. Scanning your badge at an event will provide OneSky with the same or similar information herein. We might also take your picture, which is collected and shared for business purposes.
o Placing an Order: If you request a quotation or place an order for one of our cloud, server or desktop products, we collect your name, billing address, shipping address, email address, telephone number and credit card information when necessary.
o Office Visit: If you visit our offices, we require you to register as a visitor and to provide your name, the name of your organization, your address, and proof of citizenship (including passport information); in addition, sometimes we need to take a photograph of you. If you participate in a meeting that is being recorded, your name, your image and your voice might be captured. Where applicable law permits, our offices’ cameras capture images for security purposes and for crime prevention.
o Website: Our website might collect certain information automatically and store it in log files. The information includes but is not limited to: internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other information about your use of our website, including a history of the pages that you view. We use this information to make our website better suit your needs. We also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
o Job Applicant: If you apply for a job with OneSky or its subsidiaries, we collect: contact details, employment status, employment history, education history, security clearance status, Curriculum Vitae, photographs, social security or national ID number, background check information (including criminal history), information that we obtain from employment screening agencies or staffing agencies, information about you from public websites or social media, and information that you provide to us (or that we could obtain from public websites or social media) in connection with an employment opportunity.
o Employees: please refer to the Employee handbook for further information.
o Internet-based Software features:
· When operating the Software from an internet-connected workstation, you have the option to choose to enable access to hosted data. In that case, for security, marketing, and product research purposes, additional personal information about you will be collected, such as:
o Your Internet Protocol (IP) address: OneSky may use this information to identify you or to analyze data in the aggregate (i.e. collective user characteristics, user traffic patterns, sales information, and user behavior on onesky.xyz);
o Your browser information;
o Information about the device from which the Software is being used or is installed on;
o Some embedded Microsoft features, such as Bing Maps, that connect to Microsoft or other service providers’ systems over the Internet collect personal information. Please note that by using those features you agree to the transmission of this information. OneSky does not have access to this information nor is responsible for Microsoft’s practices. For more information please see https://privacy.microsoft.com/en-us/privacystatement.
o Data indicating the frequency at which portions of the software are accessed or incidents of failures encountered during normal operations. This data is primarily analyzed in the aggregate for the purpose of identifying trends.
o The Software products that you are using, along with the product version number.
o The Software products that your license applies to and the type of license in use.
o The types of objects created and analysis being performed (not including specific parameters).
· OneSky Portal and STK Cloud: When operating the browser-based OneSky Portal and STK Cloud, either for trial or paid usage, the software will log information about your session for performance and usage analysis. The information includes:
o Your account information
o Your IP addresses
o The region or general location where your computer or device is accessing the internet
o Your browser type
o Your operating system
o Your session start time and duration
o Average bandwidth, latency, video bitrate, and framerate, and screen resolution.
o Analysis: We analyze the traffic on onesky.xyz in the aggregate through the use of services, such as Google Analytics and Pardot cookies, which are subject to their own individual Privacy Policies; which we encourage you to review. We use this information to improve your user experience and determine the effectiveness of our website. If you do not want Google to drop a cookie (_ga) in your browser, please get the Google Analytics Opt-out Browser Add-on here: https://tools.google.com/dlpage/gaoptout.
Note that in addition to the information that we collect from you directly or indirectly, we sometimes receive information about you from other sources, including third parties, business partners, affiliates, service providers, or publicly available sources.
2. HOW DO WE USE THE INFORMATION?
In addition to the uses described above, we use your personal information in the following ways:
o To assist in software troubleshooting.
o To better understand product adoption and usage to derive product improvements and inform our product sales and marketing strategy.
o To operate, maintain, monitor, and protect the security and integrity of our services. The information collected may also be used to comply with U.S. Government requirements, ensure appropriate use of licensed Software, provide notification about Software updates, and help provide technical support.
o When you contact us, we keep a record of your communication to help solve any issues.
o If you have submitted personal information to us or have opted-in to receive materials, we use the email address that you provided to notify you regarding product information and services that you requested, marketing information, events, newsletters, or product release announcements that are of interest to you. You can make changes to your subscription preferences at any time by visiting onesky.xyz or by following the steps described in the OneSky correspondence that you receive. You can also unsubscribe from all email lists.
o If we post customer testimonials and comments on our websites, which sometimes contain personal information, we will obtain your consent prior to posting this information.
o We use certain personal information for system administration, auditing the use of onesky.xyz, and statistical marketing purposes, as well as providing our product partners with general statistical information about our users.
3. WITH WHOM DO WE SHARE THE INFORMATION?
o Affiliates and Acquisitions: We may share your personal information with corporate affiliates (e.g., sister companies, subsidiaries, joint ventures, or other companies under common control). If OneSky becomes or plans to become involved in a merger, acquisition, reorganization, or any form of sale or transfer of some or all of its assets, we may share your personal information with the acquiring party, including at the negotiation stage.
o Business Partners: If you attend an event organized or hosted by us, we may disclose your business contact details to others who attend or participate in the joint organization of that event, per your direction. You have the opportunity to opt out of such sharing at any time by sending an email to email@example.com. In the instance that we share your business contact information with our business partners, we will enter into a contract that protects your information from being shared downstream without obtaining your consent.
o Product Partners: If you purchase a product that is a partner product, we may share your personal information with the partner, to provide you with the software, support or for other business purposes.
o International Resellers: We also transfer your contact information to our international resellers and international agents, providing services in your country to meet your needs or to process transactions. These resellers may in turn contact you to perform these functions.
o External Websites and Social Media: onesky.xyz contains links to independent websites, products, or services, including social media features and widgets, which are hosted by third parties and are governed by their privacy practices. If you visit these sites, it is your responsibility to protect your privacy by reviewing the third parties’ Privacy Policies.
o Suppliers and Service Providers: We share your personal information with suppliers and Service Providers to enable such parties to perform functions on our behalf and, under our instructions, to carry out the purposes identified in this policy and those that are necessary to perform the services. This includes, but is not limited to, our IT service providers, data back-up and disaster recovery providers, our financial systems and financial institutions (to carry out credit card and wire transactions), our webinar service, our customer relationship management databases; our website host, our third party identity/background verification supplier, our human resource and recruiting application databases; our auditors, our lawyers and tax advisers, third-party consultants who provide us with support with respect to business analytics and marketing campaigns, and the providers of external venues where we host conferences and events. To the extent that Service Providers have guaranteed to us, they do not further collect, sell, or use your personal information, except as necessary to perform the service for which they were engaged. OneSky requires all Service Providers to continue to safeguard your personal information adequately. Service Providers might anonymize the personal information and use it in the aggregate.
o Public Forums: We offer blogs and community forums that are publically accessible by others who could use the personal information that you have provided in these forums. By submitting your comments and support questions to our forum. You understand that the information you choose to provide becomes public. We might also publish a blog that contains statements or success stories that you may have written. If such publications contain your personal information, we will request your consent prior to publishing. It is up to you to decide whether you want to make your personal information publicly available through these means; OneSky is not responsible for the use, by others, of the information that is publically available.
o Disclosures with your Consent: We share your personal information in any other way for which we obtain your consent or as directed by you.
o Disclosures without your Consent: We may share your personal information if we determine that it may be needed or requested to satisfy any applicable governmental law, regulation, investigation by public authorities, or proceeding. We may also share your personal information if we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend onesky.xyz, or protect the rights, property, and safety of OneSky, our customers, users, and the public.
While no methods of transmission over the Internet, or method of electronic storage is fully secure, and we cannot completely ensure, warrant and guarantee the security of your personal information, we take reasonable measures to protect your information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. All personal information is protected using appropriate physical, technical, and organizational measures. We also use reasonable efforts to prevent unauthorized, third-party access to personal information, of the information that you transmit, and you agree that you do so at your own risk. In the event that we are required by law to inform you of any breach of personal information, we will do so according to the laws and regulations that apply.
5. DATA INTEGRITY AND ACCESS TO YOUR INFORMATION
We rely on you to update and correct your personal information. Some of our websites allow you to modify your account profile. If you want to access the information that is collected about you or believe that any of the information needs updating, correcting, amending, or deleting, please sign in to your profile to edit it at any time or contact us at firstname.lastname@example.org. You can also contact us at the aforementioned address to access the personal information that is not be accessible from your account. Once we have authenticated your identity, we will correct our records upon verification of the requested change. We may decline to process requests that are frivolous, jeopardize the privacy of others, are extremely impractical, or when allowed by law.
6. RETENTION PERIOD
Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy unless longer retention is required or permitted by law. We will decide to delete your data if we believe that it is incomplete, inaccurate, or if we no longer need it. When we delete your personal information, it will be removed from our active database but it could remain in archives where it is not practical or possible to delete it. Furthermore, we will keep your information as needed to comply with our legal obligations, resolve disputes, and/or enforce any agreements.
If you elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable duration from the date that you last expressed interest in our content, products, or services. We retain information derived from cookies and other tracking technologies for a reasonable duration, and in accordance with our internal retention policy, from the date that such information was created.
7. CHILDREN UNDER 13
OneSky does not knowingly or intentionally collect personal information from children under the age of 13. If it comes to our attention that you are under 13, we will terminate your account and take reasonable steps to delete the personal data that you have shared with us. You can also contact us to request deletion if you believe that we have inadvertently collected information about a child under the age of 13.
8. NOTICE TO EU/UK/SWISS USERS
This section applies to you only if you are in the European Economic Area (“EEA”) or the United Kingdom or Switzerland.
Permitted Purposes for Processing Information
We process your personal information for a variety of permitted purposes, including:
o Contractual Reasons: Where it is necessary to perform our contract with you or to begin contract negotiation; whether for our products or services, for employment engagement or application, to become our customer, or to perform a contract we have with you.
o Legal Obligation: Where it is necessary for compliance with legal obligations; whether it is to carry out denied party screening, due diligence, to perform a pre-hiring check, to comply with export control laws, anti-bribery laws, or corruption laws.
o Legitimate Business Interest: Where the processing is in our legitimate interest and not overridden by your data protection interests; whether to ensure compliance with our internal policies, security and business continuity, to improve business processes, training and webinars, advertising, marketing and public relations, to organize corporate events, conferences, or to protect, manage, and improve our websites and other services.
o Consent: Where you provide us your consent; whether it is to deal with your inquiries or requests to obtain more information about our company, to the extent required by laws consent for advertising, marketing, and public relations purposes.
International Transfer of Information
Your personal information is processed in the United States and other countries, where we have offices, servers, and resellers, where privacy laws may be less stringent than the laws in your country and where the government courts or law enforcement may be able to access your information. By submitting your personal information to us, you agree to the transfer, storage, and processing of your information. Where possible OneSky takes steps to treat personal information using the similar privacy principles that apply pursuant to the law of the country in which we first received your information. With respect to transfers originating from the EEA to the US and other countries, we implemented Standard Contractual Clauses approved by the European Commission and other appropriate solutions as required and permitted by Art. 13(1)(f), 46 and 49 of the GDPR. OneSky may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security, law enforcement, or other public interest requirements.
If you are in the EEA, you have the following rights with respect to your personal information, under specific circumstances:
o Access to your personal information;
o Rectify inaccurate or incomplete information or request it to be erased;
o Ask us to move, copy, or transfer your personal information back to you or another;
o Object to the processing of your personal information for marketing purposes;
o Withdraw consent if we are processing your personal information solely on the basis of consent;
o Ensure that any significant decisions affecting you are not made purely by automated means based on an online profile and you have the opportunity to challenge the decision;
o Complain to a supervisory authority about our privacy practices.
If you wish to exercise these rights, please email us at email@example.com For further details about your privacy rights under GDPR, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/my-rights_en
9. OTHER INTERNATIONAL USERS
10. NOTICE TO CALIFORNIA RESIDENT USERS
This section applies to you only if you are natural person residing in California, pursuant to the California Consumer Protection Act of 2018. Upon authentication of your identity, under specific circumstances, you may have the right to:
o Request the categories and specific pieces of personal information being collected, the categories of sources for the personal information we collected about you, how the data is being used, if the information is disclosed or sold, and the categories of third parties with whom we share the personal information;
o Request that your information not be sold per the definition of the CCPA;
o Request deletion of personal information, subject to certain exceptions;
o Not to be discriminated against because you exercised any of your consumer rights.
Categories of Personal Information Collected
The table below indicates the categories of personal information we collect and transfer in a variety of contexts. This table includes the personal information of business customers and leads, job applicants, as well as employees. So, all categories of personal information will not directly apply to you.
Categories of Personal Information Collected by OneSky:
Audio, electronic, visual, thermal, olfactory, or similar information
Bank account number
Characteristics of protected classifications (e.g., age, sex, race, ethnicity, physical or mental handicap, etc.)
Commercial information (e.g., products or services purchased, or other purchasing or consuming histories or tendencies)
Credit card number / Debit card number
Driver’s License Number / State ID
Electronic network activity (e.g., browsing history)
Health insurance information
Identifiers (e.g., name or alias)
Insurance Policy Number
Online identifier (e.g. IP address)
Other financial information
Social Security Number
Exercising your Rights
California Residents can submit a verifiable consumer request to us to exercise their rights either by calling our toll-free number or by emailing us at the contact information below. You can only make a request twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify your identity (or that of an authorized representative) and to properly understand, evaluate, and respond to it. We will not provide you with personal information if you cannot verify your identity in a reasonable time period, and will close the case of your request. You are free to reopen a case if you are ready to verify your identity. Making a verifiable consumer request does not require you to create an account with us.
Response and Timing
We endeavor to respond to your request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You have the right to direct us to not sell your personal information at any time. We may disclose your personal information to our business partners as explained above. If you previously opted in to the sharing of your personal information, you can opt-out of future sales at any time.
To exercise the right to opt-out, submit a request to us by visiting the following Internet page: https://onesky.xyz/contact "Privacy Inquiries" button. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize the sharing of personal information. However, you can change your mind and opt back in to personal information sharing at any time by sending us an inquiry at the same internet page. You do not need to create an account with us to exercise opt-out rights.
For further details about your privacy rights under the CCPA, please visit: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1121
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email to the contact information provided below.
11. DATA BREACH
If a data breach occurs, that is likely to result in a high risk of adversely affecting your rights and freedoms, or where the unauthorized acquisition of computerized data compromises the security, confidentiality, or integrity of your personal information, we will inform you of this, as required by law, without undue delay, or within the period specified under applicable law. Where legally permitted, this notification will be made via email, post, or telephone.
12. CONTACT INFORMATION
If you have any questions, comments, complaints, or would like to submit a request, please contact us at:
OneSky Systems, Inc..
220 Valley Creek Blvd
Exton, PA 19341
Please note that any requests will require verification of your identity, which may require disclosure of additional personal information. Furthermore, we may not be able to comply with your request in certain circumstances, especially if unfounded or excessive.