SKYWIND HOLDINGS LIMITED

PRIVACY POLICY

Skywind Holdings Limited (“Skywind”, “us”, “we” or “our”) respects the privacy of every individual whose personal information it handles. This Privacy Policy explains how Skywind collects, stores and uses personal information.

For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended or supplemented, Skywind is the “controller” of personal information collected through www.skywindgroup.com (the “Site”).

If you have any questions about the use of your personal information please contact us via our “Contact Us” page or email privacy@www.skywindgroup.com.

1. How we collect and process your personal information

When you contact us

If you contact us using the “Contact Us” page on our Site we will collect your name, email address and any information about you that you choose to give us.

We will use this information to review, investigate and respond to any comment or question that you may raise.

When you purchase a Skywind product or service

If you purchase a Skywind product or engage our services, we will collect your name, email address, telephone number, mailing address and payment information.

We will use this information to:

  • communicate with you about the product or service you have purchased;
  • carry out our obligations arising from any agreements entered into between you and us;
  • respond to your customer service requests and support your needs efficiently;
  • notify you about changes to our products or services;
  • process payments;
  • detect and prevent fraud;
  • update our records and details of our account with you; and
  • comply with any legal obligations to which we are subject, and to protect and defend our rights and interests.

If we need to verify your identity

In some circumstances we may be required by law or by our internal compliance procedures to take steps to verify the identity of the owners or companies officers of companies that we do business with. These checks are sometimes called “know your client” or “KYC” checks. As part of this process we will ask relevant individuals to provide certain information such as name, address and nationality. We will also ask for documentary evidence verifying these details, such as a copy of the individual’s passport and/or utility bill.

We will use the information that provided us for the purpose of complying with our legal or internal compliance obligations. Our legal basis for processing this personal information is that it is necessary for compliance with a legal obligation to which we are subject, alternatively that it is necessary for our legitimate interests in ensuring that we are conducting our business in a responsible way which complies with our internal standards.

2. Our legal basis for using your personal information

If you contact us, our legal basis for processing personal information is that it is necessary for our legitimate interests in conducting our business and meeting the requirements of our current and prospective customers.

3. Why we use your personal information

We will use your personal information in order to contact you regarding any queries or comments we receive from you via the “Contact Us” page of our Site.

4. How we may share your personal information

We may share your personal information with any member of our group, which includes our subsidiaries and its subsidiaries, from time to time.We may share your personal information with selected third parties including:

  1. our group companies and affiliates;
  2. our service providers, including IT and data hosting companies;
  3. third party companies in the event that we are involved in a corporate transaction such as an actual or potential merger, joint venture, consolidation or asset sale;
  4. professional advisors such as attorneys, accountants, auditors, financial and other professionals;
  5. regulatory authorities, including tax authorities;
  6. law enforcement agencies, courts and other relevant tribunals.

We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
  • if we transfer ownership or management of the Site, services, business and/or assets (in whole or in part) to a third party, in which case we may also transfer your personal information to such third party, provided such third party agrees to observe and adhere to the terms set out in this Privacy Policy (as amended from time to time); and
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or to protect our rights, property, or safety, or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

5. International transfers of personal information

The personal information we collect from you may be transmitted to third parties located in countries outside of your country of residence, including the United States and Belarus.If you would like more information about the safeguards under data protection law we apply to personal information transferred, please contact us at privacy@www.skywindgroup.com.

6. Retention of personal information

The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation.For example, if you submit a query through our Site, we will store your personal information and details about your query for as long as is necessary to respond to you, and in accordance with our general policy on the retention of business records.

7. Your rights

You may have certain rights in relation to the personal information we collect about you. These may include the right to request access to your personal information, to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing to privacy@www.skywindgroup.com.You may also have the right to complain to your local data protection authority about the use your personal information.

8. Changes to this Privacy Policy

This Policy will be reviewed from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. Any personal information held will be governed by our most current Policy.
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