Personal Identification Information
To perform our services, Skysail may collect personal identification information (“Personal Data”) from users in a variety of ways, including, but not limited to, when users visit our Sites, register on our Sites, view a page or transaction, download documents related to a page or transaction, subscribe to a newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Sites. Users may be asked for, as appropriate, name, company, email address, mailing address, and phone number.
Non-personal Identification Information
To ensure the quality and reliability of our services, we may collect non-personal identification information about users whenever they interact with our Sites. Non-personal identification information may include the browser name, the type of computer and technical information about users means of connection to our Sites, such as the operating system and the Internet Service Providers utilized and other similar information.
Web Browser Cookies
Our Sites may use "cookies" to enhance user experience. A cookie is a small data file transferred to your computer. Some cookies are “session cookies” which means they are deleted when you close your browser; other cookies are “persistent” which means that they remain stored on your computer after you leave the Sites and after you close your browser window. Our Sites use both session and persistent cookies. You have the ability to delete cookies from your hard drive at any time, or to avoid cookies by setting your Internet browser to reject them or to notify you when a cookie is being placed on your hard drive. However, if you block cookies, you may not be able to use certain features on our Sites and/or may be required to re-enter information more frequently to use certain services on the Sites. For more information about cookies generally, for example, how to control and delete cookies, please visit www.allaboutcookies.org.
Below is a summary of the types of cookies we use and why we use them. We have a legitimate business interest in placing the following cookies on your device:
Strictly Necessary: These cookies are essential in enabling you to browse our Sites and use its features. Without them, basic Site services cannot be provided or the functionality will be significantly impaired.
Performance Cookies: These cookies collect anonymous information on how visitors use our Sites and whether they encounter error messages from the Sites. All information gathered is aggregated and therefore anonymized. They are used to improve how the Sites work and to analyze trends (on an anonymized basis).
Functionality Cookies: These cookies allow our Sites to remember choices you make while browsing, like language, font size, and other customizable site elements. The information associated with these cookies will not, by themselves, personally identify you. When you choose these preferences, you agree that we can place these functional cookies on your device.
Your Personal Information
Skysail’s services are utilized by various organizations and for a variety of purposes.
Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing by emailing firstname.lastname@example.org. Doing so may prevent your ability to access our Sites.
Access To Your Personal Data, Limitations Of Use And Disclosure
Skysail performs services on behalf of its clients. All users have the right to opt-out or discontinue using the Skysail services and discontinue receiving email communications from Skysail at any time. Due to the predominant use case of our services as a secure medium to transfer information and documents to identifiable, qualified and / or authorized recipients, Skysail cannot offer its full services to users who do not wish to disclose their Personal Data. Users wishing to limit their disclosure of Personal Data may reach out to Skysail via email or telephone to request direct access to the client engaging Skysail’s services.
Skysail has strict policies in place to protect the security and confidentiality of all user Personal Data we receive. Skysail limits disclosure of Personal Data to employees, its clients, its Sites users, and other EU-US Privacy Shield and Swiss-US Privacy Shield participants that have a specific business purpose for collecting, maintaining and processing such Personal Data.
Skysail retains personal data for a minimum of 6-years to satisfy regulatory compliance, including, but not limited to, the Financial Industry Regulatory Authority (FINRA). For more information on FINRA, please visit http://www.finra.org/.
Skysail may disclose Personal Data as required by law, regulation or the rules of practice of a governmental or quasi-governmental body. Skysail may also disclose Personal Data to law enforcement officials in response to a lawful request made pursuant to national security interests or law enforcement requirements. Though we do not currently anticipate a change in our ownership, in the event of a sale of the company or a significant portion of its assets, Skysail may disclose or transfer Personal Data to a purchasing party that is EU-US Privacy Shield-compliant and/or Swiss-US Privacy Shield-compliant, or has implemented another valid data transfer mechanism, such as EU Standard Contractual Clauses, as applicable.
How We Protect Your Information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Sites.
Sensitive and private data exchange between our Sites and its users happens over an SSL secured communication channel and is end-to-end encrypted and protected with digital signatures.
Third Party Websites
Users may find content on our Sites that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Sites. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to, or from, our Sites, is subject to that website's own terms and policies.
Your Acceptance Of These Terms
By using our Sites, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Sites. Your continued use of our Sites following the posting of changes to this policy will be deemed your acceptance of those changes.
Commitment To Comply With The EU-US Privacy Shield Framework And The Swiss-US Privacy Shield Framework
This section covers Skysail’s collection, use and retention of Personal Data provided by those who access and use (individually, a “user” and collectively, “users”) our Sites, and those whose Personal Data Skysail transfers from European Union member countries and Switzerland to the United States. The Federal Trade Commission has jurisdiction over Skysail’s compliance with this Policy, the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework.
Privacy Practices (EU-US Privacy Shield)
Skysail has further committed to refer unresolved Privacy Shield complaints to EU Data Protection Authorities (“DPAs”), an alternative dispute resolution provider located in the European Union. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm for more information or to file a complaint. The services of the EU DPA are provided at no cost to you.
As a last resort, privacy complaints that remain unresolved after pursuing these and other channels may be subject to binding arbitration before the Privacy Shield Panel to be created jointly by the US Department of Commerce and the European Commission.
Limitations On Use And Disclosure Of Personal Data (EU-US Privacy Shield And Swiss-US Privacy Shield)
Skysail limits access to Personal Data to those persons in Skysail’s organization, or agents of Skysail, that have a specific business purpose for maintaining and processing such Personal Data. Individuals who have been granted access to Personal Data are aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so. Skysail takes appropriate measures to protect the security of Personal Data in order to ensure it is only accessed for its intended use. Personal data is protected from loss, misuse, unauthorized access, disclosure, alteration and destructions, taking into account the risks involved in the processing and the nature of the Personal Data.
As a user of the Sites, you agree to only process the Personal Data as necessary to review and evaluate the information included on the Sites and to protect the Personal Data with at least the same level of protection as provided in the Privacy Shield. You will notify Skysail if you make a determination that you cannot meet this obligation, and to cease processing or take other reasonable and appropriate steps to remediate when such determination is made.
Inquiries And Complaints (Swiss-US Privacy Shield)
In compliance with the Swiss – U.S. Privacy Shield Framework, Skysail commits to respond to inquiries and resolve complaints about your privacy and our collection or use of your Personal Data. Any Swiss citizen with inquiries or complaints regarding this Policy and/or his or her Personal Data should contact the following organization:
Australian Privacy and Credit Reporting
Where Supplier Personal Data: (i) is Processed in Australia by a Credit Suisse Affiliate; or (ii) relates to an individual Data Subject domiciled in Australia, the Supplier represents and warrants that it has notified all individuals who are subjects of the Supplier Personal Data of the Australian Privacy and Credit Reporting Policy available at www.credit-suisse.com/au.
Skysail Advisors Ltd
50 Milk Street, Floor 16
Boston, MA 02109 USA