Aviation Software Data Privacy

Skylegs Privacy Policy 02 June 2022

We understand that your trust in us is Skylegs BV’s and Skylegs, Inc. most important asset (hereinafter referred to as “Skylegs”, “we” or “us”). As such, your privacy is essential for us. This privacy declaration (hereinafter referred to as “Privacy Declaration”) is applicable, inter alia, to (i) our website https://www.skylegs.com/ (hereinafter referred to as the “Website”), (ii) our Platform (hereinafter referred to as the “Platform”), (iii) all (commercial) relations between Skylegs and its customers, prospects, pilots and business partners.

Skylegs wishes to emphasize that it always attempts to act in accordance with (i) the Belgian Privacy Law of 8 December 1992 on privacy protection in relation to the processing of personal data, (ii) the EU General Data Protection Regulation (GDPR) 2016, (iii) The UK Data Protection Act 2016 and/or (iv) the Swiss Federal Act on Data Protection (FADP) 2023, concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC and all (future) Belgian laws regarding the implementation of this Regulation. This Privacy Declaration includes information about the personal data collected by Skylegs, as well as the manner in which Skylegs uses and processes this personal data.

Visiting the Website, creating a paying resp. free account for the purpose of using Skylegs’ services and/or platform (i.e. all online applications of Skylegs, hereinafter referred to as the “Platform”) implies your approval (through disclosure of your personal information or opt-in when acting as a pilot) of the Privacy Declaration and consequently how we collect, use and process your personal data.

Please read this Privacy Declaration in conjunction with Skylegs’ Terms of Use.

1 Types of personal data

Skylegs can collect and process the following personal data:

E-mail address
Name
Surname
Address
Telephone number (landline/mobile phone)
Billing information
All other Personal Data voluntarily provided by you (e.g. Personal Data in incoming and outgoing correspondence)

Skylegs also automatically collects anonymous information regarding your use of the Website and Skylegs’ services via the Platform. As such, Skylegs shall, for example, automatically log which sections of the Website and Platform you visit, which web browser you use, which website you visited when you obtained access to the Website. We cannot identify you through these data, but it allows Skylegs to draw up statistics regarding the use of the Website and the Platform.

2 Methods of personal data collection:

These personal data are collected in the context of:

Requesting a quote
Collaboration with Skylegs
Signing up for the account (free or paying)
Using the services via the Platform
Entering personal data into the Platform
Visiting the Website
Filling out the contact form on the Website
Signing up for the newsletter
Incoming and outgoing correspondence with Skylegs

3 Use of personal data

Skylegs can use your personal data to:

Perform the services under the agreement (incl. the follow-up thereof)
Create an account (free or paying) and the confirmation thereof
Draw up a quote
Follow-up after a meeting
Provide the services via the Platform
Provide support
Send targeted marketing and advertising, updates and promotional offers based on your communication preferences and – where applicable – upon explicit consent
Respond to a question received through the contact form
Issue invoices and collecting payment
Optimise the quality, management and content of the Website and the Platform
Create statistics
Conduct customer satisfaction studies, surveys and other market research

4 Disclosure of personal data to third parties

Skylegs shall not disclose your personal data to third parties, unless it is necessary in the context of providing Skylegs’ services and optimising them (including but not limited to maintenance works, payment processing and database management). If it is necessary that Skylegs discloses your personal data to third parties in this context, the third party is required to use your personal data in accordance with the provisions of this Privacy Declaration.

Notwithstanding the foregoing, it is however possible that Skylegs discloses your personal data:

To the competent authorities (i) if Skylegs is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend our rights;
If Skylegs, or the majority of its assets, are taken over by a third party, in which case your personal data – which Skylegs has collected – shall be one of the transferred assets;

In all other cases, Skylegs will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.

5 Storage of personal data

Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, Skylegs shall only store your personal data for the period necessary to achieve and fulfil the purpose in question, as specified in the Privacy Declaration under ‘Use of personal data’.

6 Your privacy rights

If you wish to invoke your privacy rights, as defined below, please contact dpo@skylegs.com or complete the form for exercising your privacy rights and deliver it to Skylegs by email or post:

Right of access to personal data which Skylegs possibly has concerning you;
Right to rectification, completion or update of your personal data;
Right to delete your personal data (‘right to be forgotten’);
Right to limit the processing of your personal data;
Right to transferability of your personal data;
Right to object to/oppose the processing of your personal data;

In principle, you can exercise these rights free of charge via the above-mentioned form. In addition, you can always, via your personal account, update, modify and/or verify your personal data which you were required to submit when creating your account.

If you no longer wish to receive newsletters or information about our services, you can unsubscribe at any time by clicking the “unsubscribe” button underneath each of Skylegs’ emails.

7 Security of personal data

Skylegs undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.

Skylegs shall store all personal data which it has collected in the cloud (with data centre(s) within the EU).

Notwithstanding Skylegs’ security policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, Skylegs is, in this context, not in a position to guarantee absolute security.

Finally, the security of your account will also partly depend on the confidentiality and complexity of your password. Skylegs will never ask for your password, meaning that you will never be required to communicate it personally. If you have nonetheless communicated your password to a third party – for example because this third party has indicated that it wishes to offer additional services – this third party shall have access to your account and your personal data via your password. In such cases, you are liable for the transactions which occur as a result of the use made of your account. Skylegs therefore strongly advises you, if you observe that someone has accessed your account, to immediately change your password and contact us.

8 Cross-border processing of personal data

Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer agreement, which shall contain (i) the standard contractual clauses, as referred to in the ‘European Commission decision of 5 February 2010 (Decision 2010/87/EC)’, or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.

9 Update Privacy Declaration

Skylegs is entitled to update this Privacy Declaration by posting a new version on the Website. As such, it is strongly recommended to regularly consult the Website and the page explaining the Privacy Declaration, to make sure that you are aware of any changes. The Website will always show the date of the latest changes.

10 Other websites

The Website and Platform may potentially contain hyperlinks to other websites. In no event, Skylegs is responsible for the privacy policy or the privacy practices of any third party.

11 Contact Skylegs

If you have questions and/or remarks about this Privacy Declaration or the manner in which Skylegs collects, uses and/or processes your personal data, please contact us:

Via e-mail: dpo@skylegs.com

Via post: Skylegs BV, Luchthavenlei 7A, 2100 Antwerpen, Belgium or Skylegs, Inc. 6 Liberty Square #2246, Boston, MA 02109, United States

In case you are not satisfied with the way Skylegs handled your questions and/or remarks or have any complaints about the way Skylegs collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Privacy Commission.