Skyhook Website Privacy Policy

Effective Date: 5/11/2020

Thank you for visiting a website created or maintained by Skyhook Holding, Inc. (f/k/a TruePosition, Inc.) and/or its wholly-owned subsidiary, Skyhook Wireless, Inc. (together “Skyhook”). We want you to be familiar with the information we collect about users of our websites, how we use and share any such collected information, and the choices you have regarding the information we collect or you provide. Accordingly, this Website Privacy Policy (“Privacy Policy”) describes our practices with respect to information collected through our websites (including www.skyhook.comwww.skyhookwireless.com and my.skyhookwireless.com) (collectively, the “Websites”).

As part of our commitment to privacy and transparency, Skyhook is an active participant in a number of industry privacy forums.  We are a member of the Network Advertising Initiative (NAI) and complies with the NAI Code of Conduct, including its requirements as to transparency, notice and user control.  In addition, as described in our Privacy Shield Notice, Skyhook complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework 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 Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. 

Please note that this Website Privacy Policy does not address information that may be collected through products or services offered by Skyhook (the “Skyhook Services”), including any aspects of the Skyhook Services that may be accessible via our Websites.  For more information about information collected through the Skyhook Services, please see our Services Privacy Policy.

By using the Websites, you agree to this Website Privacy Policy and to any policies herein. If you do not agree to this Website Privacy Policy, please do not use the Site. If you have any questions about this Website Privacy Policy, or Skyhook’s privacy practices generally, please contact us at privacy@skyhook.com.

1. Information Collection

 As part of operating our Websites, Skyhook collects the following information:

  • Information Provided To Us: In order to access some Skyhook services, such as the My.Skyhook portal, users will be asked to sign up and provide Skyhook with a name, e-mail address and password, all of which we associate with a user’s Skyhook account.
  • IP Address and Other Standard Information: Like most other websites, Skyhook (or its web analytics partners such as Hubspot and Google Analytics) may gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about users. We do this to improve services we offer users and to improve marketing, analytics, or site functionality and to analyzing trends and gather demographic information about our user base as a whole. We may also receive reports based on the use of these technologies by our web analytics partners on an individual as well as aggregated basis.
  • Tracking Technologies (such as cookies and web beacons): Skyhook or its web analytics partners (such as Hubspot and Google Analytics) also use tracking technologies, known as cookies and web beacons, to gather information about visits to our Websites – for example, the number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. Cookies are small text files that are stored on a user’s internet browser, which can be accessed by web servers when the browser returns to this website. Users have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but users can usually modify your browser setting to decline cookies if you prefer. If you choose to accept cookies, users also have the ability to later delete cookies that have been accepted.
  • Social Media Features: Our Websites may link to our external Social Media sites or may include Social Media Features, such as the Facebook Like button. These Features may collect IP address, which page users are visiting on our site, and may set a cookie to enable the Feature to function properly. Where used, Social Media Features are either hosted by a third party or hosted directly on our websites and any interactions with these Features are governed by the privacy policy of the company providing it.

 

2. Use of Information

Skyhook may use the information it collects on its Websites to:

  • Assess the needs of a user’s business to determine suitable products;
  • Send users requested product or service information;
  • Respond to customer service requests;
  • Administer accounts;
  • Send marketing communications;
  • Improve our services, our website and marketing efforts;
  • Display content based upon users’ interests.

 

3. Sharing of Information

To the extent permitted by applicable law, we may share personal information as follows:

  • With any of our current and future corporate subsidiaries and affiliates.
  • With our third-party service providers, agents, vendors and other third parties we use to support the Site and our business. These parties include, but are not limited to, third parties providing us with services such as website hosting, data analysis, infrastructure provision, IT services, customer service, analytics and email delivery services. These third parties are authorized to use your personal information only as necessary to provide these services to us.
  • With third parties for marketing, advertising, promotions, contests or other similar purposes. If required by applicable law, we will share such data for advertising and marketing purposes only in an aggregate, anonymous and de-identified manner.
  • In connection with a corporate transaction, proceeding or reorganization involving the business activities for which the information is maintained. In the event that ownership of Skyhook or its business were to change as a result of a merger, acquisition or transfer to another company, your personal information may be shared. You will be notified via email and/or a prominent notice on our website, of any change in ownership, change in use of your personal information, and choices you may have regarding such change in use of your personal information.
  • As we believe necessary: under applicable law, including laws outside your country of residence; to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, law enforcement or national security investigation or as otherwise required or authorized by law; to respond to requests from public and government authorities, including outside your country of residence; to enforce our policies, terms and conditions; to protect our operations or those of any of our affiliates; to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and to permit us to pursue available remedies or limit the damages that we may sustain.

 

4. User Access and Choice

In the event that you signed up for an account on one of our Websites with an e-mail address, we may send e-mail communications to you via that user e-mail. At any time, you can opt out of marketing email communications we send through a link at the bottom of each email.  If your personal information changes, or if you no longer desire our service, the user may update or delete your account by making the change on your Portal page or by emailing our Customer Support at support@skyhook.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to all requests to access within 30 days.

We will retain user information for as long as an account is active or as needed to provide you services. We will retain and use user information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

5. Links to Third Party Sites

Our Websites may include links to other web properties whose privacy practices may differ from those of Skyhook. If a user submits personal information to any of those sites, a user’s information is governed by their privacy policies. We encourage all users to carefully read the privacy policy of any website that they visit.

 

6. Blog

The Websites may offer publicly accessible blogs. Users should be aware that any information provided in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at support@skyhook.com.

 

7. How We Store and Secure Your Information

We use data hosting service providers in the United States to host the information we collect, and we use technical measures to secure your data.

We will undertake reasonable steps to protect all information, from unauthorized or accidental access, disclosure, misuse or processing, or from alteration, destruction, or loss.  However, because no security measures are perfect or impenetrable, we cannot guarantee the security of information you submit to us.

 

8. How Long We Keep Your Information

We retain your personal information in accordance with our data retention policies and practices.  The length of time we keep your information depends upon a number of factors, including the type of information. In general, we retain personal information for as long as we have an ongoing business need to retain it. Following that period, we will delete it.

 

9. Users from the European Economic Area

Legal Basis for Processing.  If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable European Union laws.  The legal bases depend on how you use the Websites:

  • We need to collect and use the information for you to use the Websites;
  • Our collection satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • You give us informed consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

 If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.  Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Websites. 

 How to Access or Control Your Information– The General Data Protection Directive (GDPR) provides individuals in the EEA certain rights with respect to their information. These include the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format.  You can exercise these rights by contacting us at the address in the Contact Section below.

 The GDPR provides that we may limit or deny your requests in certain cases. For example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we have compelling legitimate interests to keep, including as required by law.  You may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed if you have concerns about your rights.

 

10. Privacy Shield and Data Transfers

As part of our commitment to privacy and transparency, Skyhook is an active participant in a number of industry privacy forums.  We are a member of the Network Advertising Initiative (NAI) and complies with the NAI Code of Conduct, including its requirements as to transparency, notice and user control.  In addition, as described in our Privacy Shield Notice, Skyhook complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework 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 Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

11. Other International Users

The Websites are hosted in the U.S.  If you are a consumer accessing one of our Websites from any other country or region with laws or regulations governing personal data collection, use and disclosure that differ from U.S. laws, your continued use of such Website, which is governed by U.S. law and these terms, indicates your consent to the transfer of any information collected or provided to us in the U.S.

 

12. Contact Information

If you have any questions regarding this Privacy Policy or how we treat information pursuant to this Privacy Policy we encourage you to contact us at privacy@skyhook.com or by writing to us at the following address:

Attn: General Counsel

Skyhook Wireless, Inc.

12 Thomson Place, 4th Floor

Boston, MA 02210

 

12. Children's Privacy

Because protecting the privacy of young children is especially important, we do not knowingly collect or maintain information from or about persons under 13 years of age. No part of our Websites is structured to attract anyone under 13.  If you are under 13, do not use or access the Websites at any time or in any manner.  If we learn that personal information of persons under 13 has been collected on the Websites without verified parental consent, we will take appropriate steps to delete this information.

 

13. Your California Privacy Rights (For California Residents Only)

Our privacy practices are aligned with the requirements of the California Consumer Privacy Act (CCPA). If you reside in California, we are required to provide additional information to you about how we use and disclose your Personal Information, and you may have additional rights with regard to how we use your Personal Information.

Personal Information. Consistent with section 1 above, our website may collect certain categories and specific pieces of information about individuals that are (or may be) considered “personal information” under the CCPA. Specifically, we may collect, receive or process the following types of personal information:

  • Identifiers: Internet Protocol addresses
  • Personal Information Categories Listed in Cal. Civ. Code §1798.80(e): when you sign up for an account, we may collect name, address, contact telephone number, e-mail address and other similar information needed to set-up your account
  • Internet / Network Activity: when you visit or interact with our websites, we may collect information about that usage, including number of visits, average time spent, pages viewed, navigation history through the website, and referring pages.

Sources. The categories of third parties from whom we may collect or receive the Personal Information described above include the following:

  • The Skyhook websites, including skyhook.com, skyhookwireless.com and myskyhookwireless.com.
  • Analytics partners such as Hubspot and Google Analytics.

Purposes. We collect your Personal Information for the business and commercial purposes described in this Privacy Policy.  Please note:  Skyhook does not sell information collected or received via our website.

Your Rights.  Subject to certain exceptions, as a California resident, you have the right to:

  • Request that we disclose access to your Personal Information;
  • Request deletion of your Personal Information;
  • Request information about the Personal Information we have disclosed for a business purposes and/or “sold” (as such term is defined under the CCPA) to third parties within the past 12 months; and
  • Opt-out of the “sale” of your Personal Information, as detailed above and below.
  • “Do Not Sell My Personal Information”. You have the right, as a California resident, to opt-out of the “sale” of your Personal Information.

Please note that Skyhook does not sell or transfer information that is collected in order to operate our websites.  If, instead, you reached this page in order to opt-out your Mobile Ad ID, MAC Address or IP Address, please use the “Do Not Sell My Personal Information” link and/or opt-out page available here.

14. Changes to our Privacy Policy

We may revise this Privacy Policy at any time.  Any Privacy Policy revisions will be effective upon posting to the Websites.  You should review this Privacy Policy, each time you visit the Websites, to inform yourself of any revisions. Your continued use of the Websites will constitute your acceptance of the Privacy Policy as revised.

 

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