Skyhook Data Privacy Framework Notice

Effective Date: 10/05/2023


Skyhook Holding, Inc. (f/k/a TruePosition, Inc.) and its subsidiary Skyhook Wireless, Inc. (collectively, "Skyhook”, “we”, “our" or "us") respect your privacy.  Although its legal status is not clear at this point, Skyhook has certified compliance with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States.  Skyhook has certified to the Department of Commerce that it adheres to the Data Privacy Framework (“DPF”) Principles.  If there is any conflict between the terms in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view our certification, please visit

This DPF Notice ("Notice") describes our standards and procedures for handling Personal Information transferred from the European Economic Area ("EEA") and Switzerland to the U.S. in accordance with Skyhook’s obligations under the EU-U.S. DPF and the Swiss-U.S. DPF.  

For the purpose of this Notice, "Personal Information" means any data relating to an identified or identifiable individual, including, for example, name, address, telephone number and e-mail address, and "processing" means any operation performed on Personal Information, such as, for example, collection, use, management, consultation or disclosure. This Notice supplements the Skyhook Privacy Policy. Unless specifically defined in this Notice, the terms in this Notice have the same meaning as in our Privacy Policy. In case of conflict between this Notice and the DPF Principles, the DPF Principles will govern.

How We May Obtain Personal Information

We may obtain and process Personal Information from the EEA and Switzerland in different capacities:

  • In the case of businesses and individuals opening accounts with Skyhook by signing up at, we may collect and process EEA and Swiss Personal Information as a data controller directly from individuals.
  • In the case of operating our location services, we may obtain and process EEA and Swiss Personal Information such as by receiving location signals or determining location results, as further described, and for the purposes set forth, in Skyhook’s Privacy Policy.

Skyhook commits to comply with the DPF Principles with respect to all Personal Information received from the EEA and Switzerland in reliance on the DPF.

DPF Principles

    1. Skyhook’s Privacy Policyin combination with this Notice describes our privacy practices with respect to Personal Information received from the EEA and Switzerland in reliance on the DPF.


    1. When providing our location services, Skyhook requires clients and third parties to provide notice regarding data collection and use, and to obtain consents or permissions legally required, including without limitation any data such party collects, uses, and/or discloses from its users, the provision of such data to Skyhook, and the other party’s use of such data. Skyhook also provides users the ability to directly opt-out from Skyhook’s services as set forth under the section “Opt-Out Choices” of Skyhook’s Services Privacy Policy.


    1. Data Integrity and Purpose Limitation. Any Personal Information we receive may be used by Skyhook for the purposes indicated in the Skyhook’s Privacy Policy or as otherwise notified to you. We will not process Personal Information in a way that is incompatible with these purposes unless subsequently authorized by you.
      We take reasonable steps to limit the collection and usage of Personal Information to that which is relevant for the purposes for which it was collected, and to ensure that such Personal Information is reliable, accurate, complete and current. Individuals are encouraged to keep their Personal Information with Skyhook up to date and may contact Skyhook as indicated below to request that their Personal Information be updated or corrected. We will retain your Personal Information in an identifiable form only for the period necessary to fulfill the purposes outlined in the Skyhook’s Privacy Policy, unless a longer retention period is required or permitted by law or by the Principles. We will adhere to the DPF Principles for as long as we retain the Personal Information collected under the DPF.


    1. Accountability for Onward Transfer of Personal Information. Skyhook may transfer Personal Information for the purposes described in the Skyhook’s Privacy Policy to a third party acting as a data controller or as an agent. If we intend to disclose Personal Information to a third party acting as a data controller or as an agent we will comply with, and protect, Personal Information as provided in the Accountability for Onward Transfer Principle. When providing our location services we disclose Personal Information as provided in our agreement with customers.  We remain responsible for the processing of Personal Information received under the DPF and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

    1. Skyhook takes reasonable and appropriate precautions, taking into account the risks involved in the processing and the nature of the Personal Information, to help protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

    2. In the case of information submitted to set up an account with Skyhook, individuals have reasonable access to their Personal Information and may request corrections, deletions, or additions where the Personal Information is inaccurate or has been processed in violation of the DPF Principles. In addition, as described above, Skyhook provides end users with the ability to opt out of collection of the users’ MAC address, IP Address and location information.

    3. Recourse, Enforcement and Liability.  In accordance with the DPF Principles, Skyhook has established procedures to periodically verify its implementation and compliance. In addition, in compliance with the DPF Principles, Skyhook commits to resolve complaints about our collection or use of your Personal Information. EU and Swiss individuals with inquiries or complaints regarding our DPF policy should first contact Skyhook according to the contact information provided in the end of this Notice.  

    Skyhook has further committed to refer unresolved DPF complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit here for more information or to file a complaint. The services of JAMS are provided at no cost to you.

    For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration as detailed in the official DPF website.


    Please be aware that the Federal Trade Commission has jurisdiction over Skyhook’s compliance with the DPF. In certain situations, Skyhook may be required to disclose Personal Information received under the DPF in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


This Notice may be amended consistent with the requirements of the EU-U.S. DPF and the Swiss-U.S. DPF. When we update this Notice, we will also revise the "Last Updated" date at the top of this document

Questions and Complaints

If you have any questions, concerns or complaint regarding our privacy practices, or if you’d like to exercise your choices or rights, you can contact us:

  • By email at
  • By mailing to Qualcomm Incorporated, Attn. Privacy Office, 5775 Morehouse Dr., San Diego, CA, 92121, USA

We will make every effort to resolve your concerns.