SKYPATH PRIVACY POLICY

Last Updated: May 31, 2024

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, SkyPath US Inc. and its affiliates (“SkyPath”, “we”, “our” or “us”) use, collect and store personal information that we collect or receive from or about you (“you”) in connection with https://skypath.io (the “Website”), the SkyPath mobile software application (the “App”) and the services provided therein (collectively, the “Services”). We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.

Table of contents:

What information we collect, why we collect it, and how it is used
How we protect and retain your Personal Information
How we share your Personal Information
Your privacy rights
Do not track
Use by children
Interaction with third party products
Analytic tools/ Cookies
Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement material changes in the way we use your information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or App or by other means and take any additional steps as required by applicable law.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

(i) We Process the Following Personal Information:

a. Information You Provide Directly to Us. We collect the following information you provide directly to us, including, without limitation, information when you sign up, browse and make use of our Services, such as your name and email address, records and copies of your correspondence, and additional information you may provide through the use of the Services. b. Automatic Data Collection. We may automatically collect certain information through your use of SkyPath Services, such as your Internet protocol (IP) address, cookie identifiers and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of SkyPath Services.

(ii) We process information for the following purposes:

a. To provide you with the SkyPath Services. SkyPath will use your information to provide SkyPath Services, and to fulfill any other purpose for which you provide it.

**b. For Administrative Purposes. ** SkyPath may use your information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) provide you with notices about your account and any subscription you may hold; (iii) for internal quality control purposes; (iv) to establish a business relationship; and (v) to generally administer SkyPath Services.

c. Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

d. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to analyze and improve SkyPath services (including through the use of artificial intelligence) and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).

e. Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on SkyPath Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through SkyPath Services. We use such Technologies that are small data files placed on your device that help us gather certain pieces of information whenever you visit or interact with SkyPath Services. If you prefer not to use these Technologies, you can opt out of the Technologies we employ on SkyPath Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.

f. For any other purpose with your consent. SkyPath will use your information for purposes disclosed upon obtaining your consent.

2. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION

2.1. Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information. 2.2. Retention of your information. Your information will be stored until we delete our records, and we proactively delete it. Please note that in some circumstances we may store your information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described above, we may share your information as follows: 3.1. We may also share information with our affiliated companies about you. 3.2. We may use third party service providers to process your information for the purposes outlined above, including, without limitation: 3.2.1. With cloud service providers for hosting purposes; 3.2.2. With websites and web content creation platforms in order to help us manage our Website; 3.2.3. With email providers, marketing, CRM, other similar tool providers; and 3.2.4. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy. 3.3. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of SkyPath, our Services, customers, employees, property, and the public. 3.4. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events. 3.5. Where you have otherwise provided your consent to us for sharing or transferring your information.

4. YOUR PRIVACY RIGHTS

4.1. Rights: The following rights (which may be subject to certain exemptions or derogations) apply to certain individuals based on applicable law: a. You have a right to access personal information held about you; and b. To the extent such information is inaccurate or not updated- You have a right to amend or delete personal information. 4.2. You can exercise your rights by contacting us at [[email protected]]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we need further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
4.3. Should you ever decide to delete your account, you may do so by emailing [[email protected]] . If you terminate your account, any association between your account and Personal Data we store will no longer be accessible to you through your account. However, information provided to us through the account may still be retained by SkyPath in accordance with Section 2.2 above. Nevada provides its residents with a limited right to opt out of personal information sales. Please note we do not currently sell data triggering the law’s opt out requirements.

5. DO NOT TRACK.

California law requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected. Because there currently is not an industry or legal standard recognizing or honoring DNT signals, we do not respond to them at this time.

6. USE BY CHILDREN.

We do not offer our products or services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. We do not sell information from any children. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [[email protected]].

7. INTERACTION WITH THIRD PARTY PRODUCTS.

We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. ANALYTIC TOOLS/COOKIES.

We use technologies to automatically collect information through the Website and Services. These technologies are usually small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and Services. In most browsers and devices, you can manage your preferences regarding cookies and similar technologies, including blocking, deleting, or disabling them. For more information on how to manage cookies in specific browsers, you may refer to the following links:

Please note that these links are provided for your convenience, and we do not take responsibility for the accuracy or completeness of the information on these external sites.

We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

9. CONTACT US.

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected]