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Privacy Policy

 

We Care About Your Privacy

Skyroam attaches great importance to protecting your personal data. We always inform you about personal data that we collect during your visit to our websites and while using our Products and Services, how your data it is used, what choices you have, and how you can influence the process. This Privacy Policy provides answers to the most important questions.  

Updates to this Privacy Policy account for data protection legal changes and a goal in mind to make things more transparent and clear, with regards to what data we collect, how we process your data, and how we obtain your consent.

We also have added some definitions for terms that are not commonly used and a simple of table contents to make your privacy with Skyroam easier to understand.

This Privacy Policy was written in English (US) and may be translated to other languages solely for the convenience of our Site Visitors. In all cases and specifically if a potential conflict between versions arises, the English version of this Privacy Policy controls.

Table of Contents:

(1) Applicability of this Privacy Policy

 “Skyroam,” collectively refers to entities associated with any of our three global offices: Skryoam, GmbH, Skyroam, Inc., and Skyroam Technology Co., Ltd. and its affiliates are the entities that act as the data controller of your information, as explained in more detail in this section and the “Identifying the Data Controller and Processor” section below.

Skyroam is committed to respecting and preserving your privacy. This privacy policy and agreement ("Privacy Policy") covers how Skyroam collects, uses, and treats personal information that you may provide through our website located at Skyroam.com, shop.skyroam.com, a.Skyroam.com and other affiliated Skyroam.com websites, as updated from time to time (the "Site"). If you are an EU customer, you can learn more about information we collect by visiting our data collection and processing information page, which gives you full control over and access to your Skyroam data. By using the Skyroam Products and Services, you’re agreeing to be bound by Skyroam’s Terms of Service (“T&Cs”) and this Privacy Policy. The terms "you" and "your" refer to any visitor at our Site ("Site Visitors"), as well as to any visitors who engage in transactions over the Site (if Skyroam includes such features on the Site) (each a "Site Customer"). Any undefined terms not in this Policy will use the same definitions as defined in the Skyroam, Inc. T&Cs. To the extent the Terms of Service conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.

This Privacy Policy applies (i) to anonymous information you provide to us while using or visiting our Site and Services, and (ii) to Personally Identifiable Information that you choose to provide to us via the Site, or that you provide to us as part of the process of registering online as a Site Customer.

(2) Information we collect and Receive

Skyroam will not share personally identifiable information you provide via the Site with any third party, other than as expressly disclosed in this policy. "Personally Identifiable Information" means information that identifies you, such as your name, mailing address, or email address. Skyroam collects information from you at different points as a Customer on our Site, and uses this information for registration, emergency, processing requests and transactions, informational Notices, anonymous aggregate information, IP addresses, cookies, computer configuration.  

For customers in the EU under GDPR regulations, learn more about what data we collect by visiting the Data Collection & Processing page.

Registration Information:

As a Site Visitor or a Site Customer, you may provide Personally Identifiable Information to us, in connection with requests for information, or for other reasons.

We may collect Personally Identifiable Information voluntarily provided by you when you contact us, sign up for our newsletter, create a user account, download materials, participate in promotional activities, or provide such information through other electronic means. Personally Identifiable Information we collect may include information such as your name, email address, physical address, and telephone number. We are committed to security and implement a variety of security measures to maintain the safety of your Personally Identifiable Information.

We may also collect certain non-Personally Identifiable Information, such as your computer’s IP address, browser information, cookie information, domain name, your geographic location, pages viewed and the number of times viewed. We may also collect information about your use of the website using third party tools such Google Analytics, but only for the purpose of improving our website, user experience, and our services. You may also voluntarily provide us with other non-Personally Identifiable Information, such as your affiliated company. Unless otherwise required by law, all non-Personally Identifiable Information is not used to personally identify you and is only used by us to improve the content and functionality of our Site.

Emergency Information:

 As a Site Customer, you may provide personal information, emergency contact information, and information to us, in connection with requests for information or for other reasons. This information is requested to help you, and designated emergency personnel, in the event of an emergency, and to configure and personalize your Skyroam device and/or experience.

Processing Requests and Transactions:

When you make a request of us via our Site, Skyroam will use any Personally Identifiable Information that you provide in connection with that request for the purposes of processing and responding to that request. In each instance where you make a request under our Site, Skyroam will use the information you provide to us solely for the purpose of fulfilling your request.

Informational Notices, Newsletters and Bulletins:

Periodically, Skyroam may choose to send newsletters, bulletins, marketing materials, or other information to you, and will use Personally Identifiable Information to send such communications. If Skyroam chooses to undertake such communications, you will have the ability to opt-out of receiving these communications as provided in the opt out links and information below, located in in Your Rights, Consent, and Opt out.

Anonymous, Aggregate Information:

"Aggregate Information" is information that does not identify you, and may include statistical information that may range from statistical information and analyses concerning the number of transactions through our Site or services, and the pages on our Site that users visit most frequently. Skyroam uses Aggregate Information to analyze the effectiveness of our Site, to improve our services and our Site, and for other similar purposes. In addition, from time to time, Skyroam may undertake or commission statistical and other summary analyses of (i) the general behavior and characteristics of our Site Visitors, (ii) the effect of our programs on, and the behavior of our Site Visitors, and (iii) the general characteristics of visitors at our Site and participants in our services. Skyroam may share these analyses and Aggregate Information with third parties. Rest assured, though, that Aggregate Information provided to third parties will not allow anyone to identify you, or determine anything personal about you.

IP Addresses:

Skyroam may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer's name, the type and version of your web browser, referrer addresses and other generally accepted log information. Skyroam may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Site is being used and improving the overall Site Customer or Site Visitor experience.

Cookies and our Cookie Policy:

A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. Skyroam may include cookies on our Site and use them to recognize you when you return to our Site. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our Services.

Computer Configuration 

In order to determine whether your computer is supported by our system, Skyroam may collect certain anonymous information. This information includes, but may not be limited to, your operating system and browser, as well as the presence of any software that our Site may require to operate with your computer, or other third party software on your computer. This information is kept strictly confidential and is not shared with third parties, except as provided for in this Privacy Policy.

Extent of Information Collected 

Skyroam does not collect any more Personally Identifiable Information than reasonably necessary to operate the Site, including its Products, and Services, and to respond to your requests. Click here to learn more about the data we collect and how we process your data (Link to Data Collection and Processing Notice).

(3) How we Use your Information

We will not share Personally Identifiable Information you provide via the Website with any third party, other than as expressly disclosed in this policy. We may use your Personally Identifiable Information to:

Personalize your experience (your information helps us to better respond to your individual needs);

Improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you);

Improve customer service (your information helps us to more effectively respond to your customer service requests, inquiries and support needs);

Create and use email lists to send periodic emails to provide you with new product information, technical updates and information about support services;

Perform marketing surveys to better understand the needs of prospective clients and partners.

(4) Data Retention and Deletion

Skyroam will retain content and information submitted by Site Customers in accordance with a Site Customer’s instructions, including any applicable terms in the Site Customer purchase agreement and Site Customer’s use of Services functionality, and as required by applicable law. The deletion of Site Customer data and other use of the Products and Services by Site Customer may result in the deletion and/or de-identification of certain associated Site Visitor information. For more detail, please review the Help Center or contact Customer Service. Skyroam may retain other Site Visitor information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Site Visitor information after you have deactivated your account for the period of time needed for Skyroam to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

(5) How we Share and Disclose Information

Skryoam Does Not Disclose Information to Unaffiliated Third Parties;

Limited Exceptions: Skyroam uses and discloses Personally Identifiable Information as detailed in the Data Retention and Deletion Section, above. Skyroam will not otherwise disclose your Personally Identifiable Information to unaffiliated third parties without your expressed consent, except in the following limited circumstances: Site Vendors, Imminent Harm, Legal, Transfer of Site, and Security.

Site Vendors

Skyroam may employ other companies to perform functions on our behalf, such as (i) maintaining the Site, (ii) maintaining the server farm or farms that allow us to host your data, (iii) collecting information, (iv) responding to and sending electronic mail, or (vi) other functions necessary to our business. Skyroam may need to share your Personally Identifiable Information with these companies (collectively, "Site Vendors"). Skyroam will provide Site Vendors with only that information necessary to perform their functions, and Skyroam will not allow such Site Vendor to use your Personally Identifiable Information for any other purpose.

Imminent Harm

Skyroam may reveal your Personally Identifiable Information to attorneys, private investigator organizations or law enforcement agencies if Skyroam believes (a) that you are in risk of harm from another, or (b) that you are harming or interfering (or will imminently harm or interfere) with others or violating (either intentionally or unintentionally) our Terms of Service or otherwise violating legal rights. Please note, however, that by specifying this exception from our privacy and data protection practices, Skyroam assumes no duty to monitor safety concerns on your behalf.

 

Legal 

 

Skyroam will reveal your Personally Identifiable Information, to the extent we reasonably believe we are required to do so by law, or in the unlikely event we become involved in a dispute with you, and such information is necessary to support or defend our position. In addition, if we receive legal process calling for the disclosure of your Personally Identifiable Information we will attempt to notify you via the email address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted.

Transfer of Site

 

Skyroam shall be entitled to transfer to a third party information it collects, including any Personally Identifiable Information, in connection with a sale or transfer of all or substantially all of the assets of the business entity responsible for the information under this Policy, provided the acquiring third party has agreed to safeguard your Personally Identifiable Information with protections that in all material respects are the same as or more protective than those set out in this Privacy Policy. You will be informed with electronic notice regarding such Transfer of Site and your information in the event such sale or transfer takes giving you an opportunity to review your options and opt out at that time.

 

Security

 

Skyroam has put in place security systems designed to prevent unauthorized access to or disclosure of information you provide to us, and Skyroam takes commercially reasonable steps to secure and safeguard this information, commensurate with the size and the demographics of Skyroam.

In the event of a security breach, Skyroam will promptly notify you of any unauthorized access to your Site Customer information or Personally Identifiable information. Skyroam has incident management policies and procedures in place to handle such an event.

 

(6) Age Limitations

To the extent prohibited by applicable law, Skyroam does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will takes steps to delete such information at DPO@skyroam.com

 

Privacy Protection for Children and Teens

Our Site is not directed at children, and Skyroam will not accept or request Personally Identifiable Information from individuals Skyroam knows to be under 13. In accordance with the Children's Online Privacy Protection Act ("COPPA"), if Skyroam learns that a child under 13 has provided Personally Identifiable Information, Skyroam will either (i) delete this information from our databases, in accordance with our deletion policy, or (ii) obtain verifiable parental consent, in accordance with COPPA.

 

(7) Changes to the Skyroam Privacy Policy

Notification of Changes

From time to time, Skyroam may change this Privacy Policy. If Skyroam makes any changes regarding disclosure of Personally Identifiable Information to third parties, Skyroam will attempt to contact you prior to the date the modified policy is scheduled to take effect. Skyroam will post notice of the new Policy from the privacy link on our Site. With respect to Site Visitors, your use of our Site following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed. With respect to Site Customers, no such material changes will take effect unless and until you have provided us with your explicit consent to such changes, in accordance with The Applicability of this Privacy Policy, as described above.

 

(8) International Data Transfers and Contractual Terms

In order to provide you with Skyroam Products and Services, information that you provide when you register your Skyroam hotspot and use our Service is sent to our Skyroam data centers in Hong Kong and stored securely. For EU Site Customers that use Skyroam Products and Services, you understand that transfer of this basic data is necessary to provide you with service and allow for us to service your Skyroam account.  Information we collect may include your name, email, telephone number, billing and shipping address, and other depersonalized browsing information. We also collect and store data about the amount of data consumed, the date and time Daypasses are used, and the country you are in during the use of a Daypass.  Our systems may record information about the type of virtual SIM card that is running on your Skyroam hotspot as well. 

Skyroam, its authorized partners, or affiliates will not store or transmit any personal data to third parties without your direct consent or agreement.  Skyroam only collects the minimum amount of data necessary to provide you with account servicing and functionality of our Products and Services. 

 (9) Data Protection Officers

Skyroam has three DPOs, one for each business region in USA, EU, and Asia.  If you are a Site Customer or supervisory authority with questions about your data, privacy or our Privacy Policy and Terms of Service, you may email DPO@skyroam.com, and your inquiry will reach our team of Data Protection Officers. 

(10) Identifying the Controller and Processor

Skyroam serves as the joint controller and processor for your customer data.  When you purchase your hotspot from any of our authorized partners, Skyroam may need to process your data if we provide ancillary services such as customer service through a direct business relationship with that partner.  Whenever you purchase or obtain services or products from Skyroam directly, Skyroam will serve as the controller for that data, meaning that Skyroam will serve to store, protect and make decisions surrounding the use of your data.  Whenever you purchase, buy rent or use Skyroam hotspot devices, Skyroam will be the controller of that data.

 (11) Your Rights, Consent, and Opt Out

Consent by Site Visitors

By accessing and using the Skyroam Site as a Site Visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it and any such notifications and opt ins as provided to you throughout the Site. If you do not agree with the terms of this Privacy Policy or such notifications, please refrain from using the Site.

Consent by Site Customers

If Skyroam decides to include features on the Site that allow online transactions, Site Customers submit contact information, and other information, to us via the Site. When you register as a Site Customer via the Site, you will be prompted to click an "I Accept" button linked to this Policy. Clicking "I accept" confirms your agreement to be bound by this Privacy Policy.

To allow appropriate control over Personally Identifiable Information, please fill out our form to get immediate access to the information you have provided to us via the Site, and/or to change or update discretionary information that you have previously submitted. Link to Skyroam’s GDPRCompliance Landing Page.

 

Changing or Removing Information; Opting Out

Discretionary Account Information

If Skyroam chooses to send to you bulletins, updates, or other unsolicited communications that are marketing-related materials, Skyroam will provide you with the ability to decline - or "opt-out of" - receiving such communications. Instructions for opting-out will be provided if and when Skyroam determines to send you such a communication.

 

Opt Out

Finally, in accordance with an Opt-Out, if you also request a deletion with your Opt-Out, Skyroam will remove your name and all other Personally Identifiable Information from our databases compiled from the Site. You may request account deletion or share your privacy preferences with us through your account portal or by filling out this request form. Please understand, however that, if you request deletion of your information, you will be unable to utilize associated features of the Site and any associated services with your previous Site Customer information. You may not remove de-identified or Aggregate Information from our databases. For more information about Deletion, please refer to the Data Retention and Deletion section in this Privacy Policy.

 

 (12) Contacting Skyroam regarding EU GDPR or Data Privacy Questions

For questions about GDPR, please email DPO@skyroam.com or visit our GDPR information page. Please feel free to contact Skyroam if you have any questions about this Privacy Policy or Skyroam’s practices, or if you are seeking to exercise any of your statutory rights.  You may contact us at legal@skyroam.com or at our mailing address below:

For Customers in the US and Canada:

Skyroam, Inc. LEGAL 
180 Sansom Street, 2nd Floor 
San Francisco, CA 94101 USA  

or

For Customers outside the US and Canada:

Skyroam GmBH 
Neue Schönhauser Str. 3-5
10178 Berlin, Germany

 

Last Updated: May 10, 2018

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