General
SkyInCorp Inc. (d/b/a SkyLaunch) is committed to protecting your privacy and recognizes the importance of maintaining the confidentiality of the Personal Information (as defined below) that we collect from you.
This Privacy Policy describes the type of Personal Information that we may collect from you, and outlines how we handle such Personal Information. It forms part of SkyLaunch’s Terms of Service (the “Terms of Service”), which governs your access to and use of our Website and Services (each as defined in the Terms of Service), whether as a guest or as a registered user.
Please read this Privacy Policy carefully before you use the Website or our Services. We may make changes to our Privacy Policy at any time. Any such changes will be effective upon posting of the revised Privacy Policy on our Website (www.skylaunch.ca). It is your responsibility to periodically review our Privacy Policy.
By using the Website and/or our Services, you acknowledge that you have read, understood and agree to be bound and abide by our Privacy Policy. In addition, we will treat your continued use of the Website and our Services following any changes to our Privacy Policy as your acceptance of such changes. If you do not agree to our Privacy Policy (or any changes thereto), you must not access or use the Website or our Services.
Consent
You consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy whenever you:
- register an account with us;
- provide us with Personal Information to complete a transaction (such as an incorporation) or subscribe for post-incorporation Services, including Personal Information for purposes of verifying payment;
- interact with our Website; or
- contact us or subscribe to our mailing list.
Where information is already available in the public domain, your consent may be implied for any collection, use or disclosure thereof. In some cases, we may be authorized or required by law to collect, use or disclose Personal Information without your knowledge or consent.
If you provide us with the Personal Information of another individual, you represent that you have the appropriate authority to permit us to collect, use and disclose such Personal Information for the purposes set out in, and in accordance with, this Privacy Policy.
Withdrawal of Consent
You may withdraw your consent to the collection, use and disclosure of your Personal Information at any time on reasonable notice by contacting us at the contact details below. However, your withdrawal of consent to our collection, use and disclosure of your Personal Information may affect our ability to provide our Services to you.
Application of Privacy Laws and the Definition of Personal Information
Organizations engaged in commercial activities in Canada, including SkyLaunch, must comply with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and “substantially similar” provincial legislation.
Personal information is broadly defined in PIPEDA as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person (“Personal Information”). Such Personal Information may include an individual’s name, birth date, mailing and residential addresses, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, and any other identifier that may be used to contact the individual. However, Personal Information does not include business contact information collected, used or disclosed for the purposes of communicating or facilitating communication with you in the context of your interaction with SkyLaunch, including your name, position name or title, business address, business email address, and business telephone or fax numbers.
Collection of Personal Information
Information you Provide to Us
In the course of providing our Services to you, you will be asked to provide certain Personal Information as is reasonably necessary for the legitimate purposes identified. The information we collect directly from you may include:
- information that you submit by filling out forms on the Website, communicating with us via contact forms, engaging with interactive features and functionalities on the Website, providing comments or other feedback, and submitting information when ordering a product or service via the Website;
- information that you submit to us (including upon our request) when you report a problem with our Website;
- records and copies of your correspondence (including email addresses), if you contact us or otherwise communicate with us;
- correspondence received by us on your behalf, if you opt in to our registered office address service as part of the “Complete Compliance Package”;
- your responses to surveys that we might ask you to complete for research purposes;
- details of transactions you carry out through our Website and through the use of our Services; and
- your search queries on the Website.
Information Collected via Automated Technology
When you browse our Website or use our Services, we may utilize automatic data collection technologies (such as server logs) to collect information that helps us understand Website usage patterns (such as the date and time of visits, the amount of time spent on our Website and the pages viewed). We may also collect information about any communications and interactions between your computer and our Website, the type of computer you are using, your computer’s operating system, browser type and internet connection (including your computer’s internet protocol (IP) address location).
The information collected via such automated technology may be considered Personal Information.
Our Website may also use ”cookies,” a technology that installs a small file on your computer to permit our Website to recognize future visits from that computer. Cookies optimize the convenience and use of our Website. You may decline cookies by activating the appropriate setting on your browser; however, doing so may affect or limit your use of our Website and ability to access certain features of our Website. Unless you have adjusted your browser setting so that it will decline cookies, our Website will issue cookies when you direct your browser to our Website.
Our Website uses Google Analytics and Facebook Ads to collect information, in an anonymous form, about how visitors use our Website, including the number of visitors to our Website and the pages they have visited. We use such information in aggregated form to improve our Website. In addition, these services may use cookies, web beacons, and other storage technologies to collect or receive information from you and elsewhere on the internet and use that information to provide measurement services and targeted ads. By using our Website, you agree to such use.
Should you wish to opt out of the use of Google Analytics, please click here. You can opt-out of Google’s personalized advertising features through Google Ads settings here https://adssettings.google.com. Where available, you can opt-out of personalized ads from other advertising networks here https://optout.aboutads.info.
You can adjust how ads are targeted to you through Facebook Ads here: https://www.facebook.com/help/568137493302217. You can also influence the types of ads you see by providing feedback or hiding ads here: https://www.facebook.com/help/146952742043748?helpref=faq_content.
Our electronic marketing communications may contain a small electronic file called a “web beacon” or “pixel” that will indicate to us whether our emails are opened and, combined with other technology, will verify any clicks through to links within the email. We may use this information to determine which of our emails are more interesting to you and to compile aggregated data regarding the preferences and interests of our customers. You can unsubscribe from our electronic marketing communications at any time by using the unsubscribe mechanism at the bottom of our emails or by emailing us at customers@skylaunch.ca.
Information Collected from Other Sources
Sometimes, we may obtain information about you from other sources including, but not limited to:
- a government agency or registry;
- your accountant, upon your authorization; or
- your other advisers, upon your authorization.
The kind of Personal Information we may collect includes, but is not limited to:
- contact information, identity verification information and biographical information; and
- Personal Information provided to us or generated by us in the course of providing our Services.
Use of your Personal Information
We collect, use and disclose Personal Information for the primary purpose of providing our Services to you and for purposes of:
- communicating with you;
- presenting our Website and its contents to you;
- creating and managing your account;
- providing you with information relating to the Services;
- providing you with offers for products and services;
- providing you with information about your subscriptions and products, including expiration and renewal notices;
- responding to inquiries and/or offering technical support;
- requesting user feedback and conducting user surveys;
- administering our business activities and operations;
- monitoring and understanding usage patterns of the Website and our Services;
- detecting and preventing fraud or other illegal activities;
- developing and improving our Website, Services and communications; and
- carrying out our obligations and enforcing our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
We may also use or disclose your Personal Information in any other way as we may describe when you provide the information, or for any other purpose with your consent or as otherwise permitted or required by law.
Disclosure of your Personal Information
We may disclose your Personal Information in the following circumstances:
- to our subsidiaries and affiliates;
- when we are required or authorized by law to do so;
- when the Services we are providing to you require us to give your information to third parties, including when making government filings or where it is necessary to establish or collect payment (see “Disclosure of your Personal Information to Third-Party Service Providers” below for more information);
- to the Law Society of Ontario (the “LSO”) to ensure SkyLaunch’s compliance with the terms of the LSO’s Access to Innovation (“A2I”) program https://lso.ca/about-lso/access-to-innovation (in which SkyLaunch is a participant), and the evaluation of A2I by the LSO;
- to contractors, service providers, and other third parties we use to support our business;
- to our insurers and to regulatory agencies in connection with regulatory or other activities in relation to the provision of our services to customers;
- to any successor or assign in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SkyLaunch’s assets and/or business, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding;
- if requested by a person whom you have expressly authorized us to disclose to, such as your lawyer, accountant or other adviser or agent;
- if the information is publicly available information, as specified under PIPEDA; or
- under any other circumstance with your consent.
Disclosure of your Personal Information to SkyLaw
If you request to be connected to SkyLaw to assist with your legal needs, you will be asked to consent to us disclosing or transferring Personal Information we have collected from you to SkyLaw for the purposes of enabling a member of SkyLaw’s staff to contact you and conduct any required conflict checks. Following such connection, SkyLaw’s privacy policy will apply, as well as any applicable rules and regulations of the Law Society of Ontario to which SkyLaw is subject.
Disclosure of your Personal Information to Third-Party Service Providers
General
SkyLaunch relies on a number of service providers to assist in the delivery of the Website and the performance of the Services. These include:
- government platforms (such as the Ontario Business Registry);
- cloud-based computing, access control (authentication) and data storage services;
- payment processors (see below for more information);
- customer messaging platforms; and
- website hosting service providers.
The third-party service providers that we utilize have their own privacy policies with respect to the information they collect from you for transactions conducted with SkyLaunch. These service providers are given the information they need only in order to perform their designated functions as part of SkyLaunch’s service offering. Our Privacy Policy does not apply to these third-party service providers but we do not disclose nor do we authorize them to disclose your Personal Information to any third party to enable them to market their products or services to you.
We may ask you to permit us to collect data about you from third-party providers to verify your identity, do a credit check and prevent fraud or assess risk. This helps us ensure that you are using our Services legally, that you are eligible for the Services you want to use, and to protect your data and our Services from fraudsters who may put you and your money at risk.
Payment Processing Services
We utilize a third-party payment processor, Stripe, Inc., to assist us with processing payments for our Services. In the course of providing payment processing services, Stripe may collect some Personal Information from you to allow them to process your payments (e.g., your email address, physical address and debit/credit card details) and handle all the steps in the payment process through their systems, including data collection and data processing. Where necessary for processing recurring payments (such as for post-incorporation subscribed Services), your financial information will be stored in encrypted form on Stripe’s secure servers.
Stripe is a Level 1 PCI DSS service provider, which is required to adhere to the latest data security standards as managed by the PCI DSS Security Standards Council. We will share payment data with Stripe only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.
Information regarding Stripe can be found here: https://stripe.com/en-ca.
Retention of your Personal Information
We will retain Personal Information for as long as it is necessary for the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting requirements. We may be required by law to retain certain types of information for certain periods of time. Where the Personal Information collected is no longer required to fulfil the identified purposes or is otherwise required by law to be retained, we may destroy or erase such Personal Information, or otherwise anonymize such Personal Information for other non-identifying uses (such as general Website usage and statistical analyses).
Safeguards and Security of your Personal Information
We take reasonable precautions including physical, organizational and technological measures to ensure that your Personal Information is kept safe from loss, theft, unauthorized access, disclosure, copying, use or modification. However, there is an inherent risk involved in the exchange of information over the internet or through the use of any form of communication, such as email, telephone, fax transmission and courier service. You should take proper precautions when sending us Personal Information, especially by email. We cannot guarantee that all electronic communications will always be received, or that such communications will always be virus-free.
In the event we become aware of any loss of, unauthorized access to or unauthorized disclosure of our users’ Personal Information that resulted from a breach of SkyLaunch’s security safeguards, we will make reasonable efforts to notify the affected individuals if we believe that such event creates a real risk of significant harm to such individual, or if notice is otherwise required by law.
The security of your Personal Information depends in part on the security of the computer or device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.
Accessing and Correcting your Personal Information
You may request access to any of your Personal Information in our possession by writing to us at our contact information below. We may require you to supply enough information to verify your identity and enable us to account for the existence, use, and disclosure of Personal Information, and your right of access to such information.
Your rights to access your Personal Information are not absolute. We may deny you access to your Personal Information when:
- to do so is required or authorized by law;
- to do so would reveal confidential commercial information and the Personal Information cannot be severed from the record;
- to do so could reasonably be expected to harm the life or security of another individual and the Personal Information cannot be severed from the record;
- to do so would reveal information that is protected by solicitor-client privilege and such information cannot be severed from the record;
- the information was generated in the course of a formal dispute resolution process; or
- the information is prohibitively expensive to provide.
If we deny your request for access to your Personal Information, we will provide the reason for such denial.
It is important that the Personal Information we hold about you is accurate and current. By law you have the right to correct the Personal Information that we hold about you. Please keep us informed if your Personal Information changes.
Links to External Sites
Our Website may contain links to other websites, which are not governed by this policy. We do not take any responsibility for the privacy practices of the third parties operating such websites. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every resource that may collect personal information from you.
Contact Information
If you have any questions, wish to request access, or make changes to your Personal Information, or if you would like to provide feedback or withdraw your consent from our use and disclosure of your Personal Information, please write to us at the following address:
SkyInCorp Inc. (d/b/a SkyLaunch)
22 St. Clair Avenue East
Suite 200
Toronto, ON M4T 2S3
Attention: Privacy Officer
We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Privacy Policy, and with applicable privacy laws.
