Privacy Policy

1. Introduction:

Skylock respects your privacy and is committed to protecting your personal data. This privacy policy (“Policy”) will inform you how we look after your personal data when you visit our website. If you have any questions about this policy, please contact us at: office-skylock@skylock1.com

2. Information about who we are:

Purpose of this policy: This Policy aims to give you information on how Skylock collects and processes your personal data through the use of this website, including any data you may provide through this website when you sign up to our website or browse through it.
It is important that you read this Policy together with any other policy or notice we may provide so that you are fully aware of how and why we are using your data. This Policy supplements other notices and is not intended to override them.

3. Our full contact details:

Skylock Europe: Chitila City, 14 Banatului Road, Block 28, Ground floor, Flat 293, Ilfov County, Romania
Skylock Asia: 1 Fullerton Road, #02-01 One Fullerton, Singapore 049213
Email address: office-skylock@skylock1.com

4. Controller:

Skylock is made up of different legal entities. This Policy is issued on behalf of Skylock so when we mention “Skylock”, “we”, “us” or “our” in this Policy, we are referring to the Skylock company responsible for processing your data.
Third-party links:
This website may include links to third-party websites, plug-ins, and applications. We do not control these third-party websites. When you leave our website, we encourage you to read the privacy notice of every website you visit.

5. The data we collect about 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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you. We have categorized these as follows:

Identity includes first name, last name, and company name.
Contact includes email address and contact numbers.
Technical includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage includes information about how you use our website.
Marketing and Communications includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. 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 the combined data as personal data which will be used in accordance with this privacy notice.
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 offenses.
Where we need to collect personal data by law, or under the terms of a contract we may have with you and you do not provide that data, we may not be able to perform the contract (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you.

6. How do we collect your personal data?

We collect data from and about you as follows:

Direct interactions. You may give us your Identity, Contact Data by filling in forms or by corresponding with us by post, phone, or email. This includes personal data you provide when you: (a) apply for our products or services; (b) create an account on our website; (c) subscribe to our service or publications; (d) request marketing to be sent to you; or (e) give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies.
How we use your personal data
We only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances
Where we need to perform the contract, we are about to enter or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than when we send third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at office-skylock@skylock1.com

Purposes for which we will use your personal data

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity; Contact	Performance of a contract with you
To manage our relationship with you which includes notifying you about changes to our terms or privacy policy	Identity; Contact; Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated)
To administer and protect our business and this website (including troubleshooting, data analysis, system maintenance, support, reporting and hosting of data)	Identity; Contact; Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
To deliver relevant website content	Identity; Contact; Usage; Marketing and Communications; Technical	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, marketing, customer relationships and experiences	Technical; Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Opting out. You can ask us to stop sending you marketing messages at any time by contacting us at office-skylock@skylock1.com where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a product/service purchase or other transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of Purpose. We will only use your personal data for the purposes for which we collected it, unless 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 office-skylock@skylock1.com.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.

Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.

Internal Third Parties: other companies in the Skylock acting as joint controllers or processors.

External Third Parties including:
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide services to us.
  Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge 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 notice.
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit our service providers to process your personal data for specified purposes and in accordance with our instructions.

International transfers
We share your personal data within Skylock. This will involve transferring your data outside the General Data Protection Regulation (GDPR). In addition, many of our external third parties are based outside the GDPR so their processing of your personal data will involve a transfer of data outside the GDPR.

Whenever we transfer your personal data out of the GDPR, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe

Data security
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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

Your legal rights under data protection laws in relation to your personal data.

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your 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.
Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the 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
Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Right to withdraw consent where we are relying on consent to process your personal data.