FAIR PROCESSING NOTICE

  1. INTRODUCTION

The purpose of this Fair Processing Notice ("Notice") is to inform you of how SKYNIGHT ("we", "us", "our") will process your personal data as data controller and the measures and processes we have in place to ensure adequate protection. The provision of this information is one of the requirements of the General Data Protection Regulation 2016/679 ("GDPR").

This notice does not constitute a contractual relationship between you and us, and we may change it from time to time.

  1. LAWFUL TREATMENT

We will only process your personal data:

(a) if you have given your consent;

(b) if the processing is necessary to provide our products or services to you or your employer;

(c) if the processing is necessary to respond to a request from you or your employer;

(d) if the processing is necessary to maintain our relationship with you or your employer;

(e) if the processing is necessary to comply with our legal and regulatory obligations.

With regard to statement (a) above, you may withdraw your consent at any time by making a request as indicated in section 12 below.

3. PERSONAL DATA WE COLLECT ABOUT YOU

3.1 We process the following types of personal data about you:

(a) Your name, e-mail address and other contact information;

(b) Your function, position and/or job title;

(c) Your preferences for types of events or marketing materials;

(d) Your access information to our premises, systems and websites;

(e) Your messages, feedback or participation in our surveys and questionnaires.

3.2 You may be required to provide us with your personal data so that we can manage our business and operations, maintain our relationship with you or your employer provide our products or services to you or your employer or comply with our legal and regulatory obligations. If you do not provide us with your personal data, we may not be able to maintain our relationship with you or your employer or provide our products or services to you or your employer.

3.3 We strive to ensure the accuracy and completeness of the personal data we hold about you and to keep all your information up to date. However, you can help us considerably by contacting us promptly if your personal data changes, or if you become aware that any information we hold about you is inaccurate (see section 9 below). We accept no liability for any loss arising from personal data supplied by you being inaccurate, inauthentic, insufficient or incomplete.

  1. HOW WE COLLECT YOUR PERSONAL DATA

We generally collect your personal data from information you or your employer provide in the course of your or your employer's relationship with us. This collection will generally take place through the sending by you or your employer of e-mails and other correspondence, business cards, forms and documents used when you or your employer subscribe to our marketing or market information mailing lists, when you are designated as a person authorized to trade on behalf of your employer, or through the use of registration information that you or your employer use to access our products or services on your or your employer's behalf.

We may also collect your personal data from other sources such as our group companies, fraud prevention agencies, market intelligence companies and public service registries.

5.HOW WE USE YOUR PERSONAL DATA

We will process your personal data in the course of managing our relationship with you or your employer and providing our products and services to you or your employer for the following purposes:

(a) provide you or your employer with the products or services requested;

(b) respond to messages or publications sent to us by you or your employer;

(c) provide you or your employer with promotional and marketing materials about our products and services that may be of interest to you or your employer;

(d) to manage, develop and improve our range of products and services, our stores, our technological information systems and our websites;

(e) monitor and assess compliance with applicable legislation and with our standards and policies;

(f) comply with our legal and regulatory obligations/requirements worldwide, including reporting to and/or auditing by national and international regulatory bodies;

(g) carry out checks to combat money laundering, to verify financial situation and solvency, and to prevent and detect fraud and crime;

(h)for administrative reasons relating to security and access to our systems, premises, platforms, websites and applications;

(i) to comply with court orders and to exercise and/or defend our legal rights;(j) for any other legitimate business purpose;

(k) or any other circumstance provided for or required by applicable law or regulation.

  1. TRANSFER OF PERSONAL DATA ABROAD

Your personal data may be transferred (including accessed and stored) to a country or territory outside the European Economic Area ("EEA"), including countries whose legislation does not provide the same level of protection for personal data as that in force within the EEA. In particular, we may transfer your personal data to our group companies outside the EEA, including Japan. We will ensure that such international transfers are subject to all reasonable and appropriate safeguards in accordance with the requirements of the GDPR. You can obtain a copy of the international data protection reference documents by making a request as set out in section 12 below.

  1. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA

We do not sell, rent or trade your personal data. We will only disclose your personal data to the following recipients:

(a) our group companies

(b) companies approved or designated by you;

(c) to third parties who process your personal data on our behalf (such as our system providers, including cloud service providers);

(d) to third parties who process your personal data on their own behalf but as part of a service provided to you or your employer on our behalf (such as our suppliers);

(e) companies providing services for money laundering verification, credit risk reduction and other fraud and crime prevention measures, as well as companies providing similar services, including financial institutions, market intelligence agencies and regulatory bodies to whom such information is distributed;

(f) to any third party to whom we assign or novate any of our rights or obligations;

(g) to any potential purchaser in the event that we sell any part of our business or assets;

(h) to any government, regulatory body, enforcement or financial transaction authority or court where we are required to do so by applicable law or regulation or at their request.

  1. HOW WE PROTECT YOUR PERSONAL DATAWe are committed to safeguarding and protecting your personal data by implementing and maintaining appropriate technical and organizational measures designed to guarantee an adequate level of security against accidental or unauthorized destruction, loss, modification, disclosure or unauthorized access.
  2. YOUR RIGHTS REGARDING THE PERSONAL DATA WE COLLECT

9.1 If you wish:

(a) update, amend or delete your personal data, obtain a copy of the information we hold about you, or

(b) limit or terminate our use of the personal data we hold,
you can request this by contacting us as set out in section 12 below.

9.2 In any of the circumstances described above, we may ask you to prove your identity by sending us a copy of a valid form of identification in order to comply with our security obligations and prevent any unauthorized disclosure of your information.

10. RETENTION PERIOD OF YOUR PERSONAL DATA

We will only retain your personal data for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

  1. UPDATE OR MODIFICATION OF THIS FAIR PROCESSING NOTICE

We may need to modify or update certain elements of this notice in order to ensure our compliance with applicable laws and regulations or following an update of our internal procedures. We will do so by updating this notice. You may not be directly informed of such changes. Therefore, please check this notice from time to time for any changes or updates.

  1. TO CONTACT US

If you have any questions about the content of this notice or your personal data, or if you would like to make a request in this regard, please contact us using the details below:

Email: rgdp@skynight.com[/av_textblock]