Last updated: 22 april 2024
1.1This Privacy Policy and its accompanying documents (the “Policy”) explain how we
(“AzureSky Ventures Corp.,” “AzureSky”) manage your personal information, how we use
cookies on the Website, and what options you have for limiting those uses. For
purposes of this Privacy Policy, “you” and “your” refer to you as a user of the
Service (“User”). Unless otherwise defined in this Policy, capitalized terms used in
this Policy have the same meanings as in our Terms of Service. This Policy governs
your use of the Website, however accessed, including through an internet browser,
smartphone, tablet or other internet-connected device, and is incorporated into and
forms a part of our Terms of Service. This Policy will also provide you with
information so that you can, where appropriate, give your explicit and informed
consent to the processing of your personal data. We ask that you read our Privacy
Policy carefully before using the Website. By accessing, browsing or otherwise using
the Website, you acknowledge that you have read, understood and agree to be bound by
this Policy. If you do not accept this Policy, you must not access, browse or use
the Website.
1.2 Revisions. We may change this Privacy Policy from time to time as laws
change, technology changes, our products evolve, and your feedback makes us better.
The effective date of the changes will always be at the top of the Policy. If you
continue to use our services or provide us with personal data after we post an
updated Privacy Policy or notify you by other means (if applicable), you agree to
the revised Privacy Policy and the practices described therein. Each time you wish
to use this website, please check this Privacy Policy to ensure you understand the
policy that applies at that time. We encourage you to periodically review this page
for the latest information on our privacy practices.
2.1Personal data.
We may collect, use, store, and transfer certain personally identifiable
information that alone or in combination with other information in our possession
could be used to contact or identify you (“personal data” “personal information”).
“personal data” Means any information relating to an identified or identifiable
natural person (a “data subject”). Identifiable means someone who can be identified
directly or indirectly in particular by reference to an identifier such as a name,
an identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic, cultural
or social identity of that natural person. Personal data includes special category
data (defined below) but excludes: Publicly available information from government
records; data where the identity has been removed (anonymous, de-identified, or
aggregated consumer information); information specifically excluded from the scope
of relevant privacy and security laws and regulations. Personal data we collect may
include:
a.Identity data. First name, surname, middle name (optional), username or
similar identifier, date of birth, information of id card/passport/driver’s license
or other identification documentation for the use of kyc verification process
complied with applicable laws and our aml policies.
b.Contact data. Billing address, delivery address, email address and
telephone numbers.
c.Financial data. Bank account and payment card details.
d.Special category data. A sub-category of personal data and means
information revealing biometric recognition, religious belief, specific identity,
medical and health, financial account, personal location tracking and other
information of a natural person, as well as any personal information of a minor
under the age of fourteen (or other ages defining “children” In applicable laws). We
only collect this type of personal data where required by law to enter into an
employment relationship.
e.Transaction data. Details about payments to and from you and other details
of products and services you have purchased from us.
f.Technical data. Internet protocol (ip) address, your login data, browser
type and version, time zone setting and location, browser plug-in types and
versions, operating system and platform, and other technology on the devices you use
to access this website.
g.Profile data. Your username and password, purchases or orders made by you,
your interests, preferences, feedback and survey responses.
h.Usage data. Information about how you use our website, products and
services.
i.Marketing and communication data. Your preferences in receiving marketing
from us and our third parties and your communication preferences.
j.Public and third-party records. Details about you that are in public
records and information about you that is publicly available on the internet. We
also collect information about you which we receive from other companies, such as
credit reference or fraud protection agencies.
k.Documentary data. Details about you that are stored in documents in
different formats, or copies of them.
l.Consents. Any permissions, consents or preferences that you give us.
2.2 Aggregated data.
“aggregate data” Means de-identified aggregated data or information
regarding information or data submitted to, collected by, or generated by azuresky
through the site or in connection with azureskyservices.
2.3.Client data.
“client data” Means any documents, files, information or data stored or
processed through use of the services that concerns the client’s business, human
resource demands, job openings or recruiting practices, or any of the client’s
employees, clients or data concerning the client that has been uploaded by the
client to the site operated by azuresky solely on behalf of the client. Client data
includes, without limitation, the names, addresses, telephone numbers, e-mail
addresses and any other personally identifiable information of the client’s
employees or clients. The client data does not include (a) aggregate data; (b)
information or data collected directly by third party providers from the client or
any; or (c) any azuresky materials.
2.4Cookies.
“cookies” Are small text files that are placed on your computer by the
websites you visit. They are widely used in order to allow websites to work
properly, remember your preferences, improve user-experience and provide information
to the owners of the site. We mainly use cookies that are necessary for the proper
functioning of the website, as well as for providing you with an enhanced user-
experience. More details about cookies can be found in below in this policy.
3.1Provide our services for you. We only use or process your personal data as
allowed by the law and do not sell it. Depending on whether you are a site visitor,
client, employee, contractor, vendor or supplier, we use information we collect to:
Manage our relationship with you or your business;
a.Carry out our obligations arising from and exercising our rights set out
in our contracts;
b.Respond to your requests; protect the security or integrity of our site;
c.Improve our marketing and promotional efforts;
d.Statistically analyze site usage;
e.Improve our content product offerings;
f.Customize our site's content, layout, and services;
g.Administer workforce solutions;
h.Authenticate eligibility for potential employees, contractors, vendors, or
suppliers;
j.Maintaining business records, logs, and other reporting tools; and (k)
other general administrative and operational tasks.
3.2Secure access to our services, operate and improve our platform, and
analyze and develop our products and services. AzureSky has the right to aggregate
data submitted to, collected by, or generated by azuresky through the site or in
connection with our services in a non- identifiable format, and to freely use the
aggregated data for our own business purposes, including to improve, support, or
expand the site or our services. All aggregated data that we disclose to third
parties will be in anonymous, de-identified form only and will not be specifically
linked to you or to any individual. AzureSky retains all intellectual property
rights in the aggregated data.
3.3.Marketing and communication. We may use your data to contact you to
communicate with you about products or services we believe may be of interest to
you. We may use that information to send special offers to your email or telephone
number with your consent. You may also opt out of receiving emails by following the
instructions contained in each promotional email we send you. If at any time you do
not wish to receive future marketing communications, you may contact us. If you
unsubscribe from our marketing lists, you will no longer receive marketing
communications but we will continue to contact you regarding management of your
account, other administrative matters, and to respond to your requests.
3.4.Crime prevention and managing risks. Our services comply with laws and
regulations, so we need to manage risk for us and our users. We will identify,
investigate, report and prevent fraud, money laundering and other crime. We may
validate your identity (including via sms or voice call, as applicable). To register
you and provide our services to you, we may communicate with you about your use of
our services and kyc verification process or any changes in our terms of service or
this policy that apply to you.
3.5.Sharing with third-parties. In certain circumstances we may share your
data with third parties for being efficient about how we fulfil our legal and
contractual duties:
Vendors, suppliers and service providers. To assist us in meeting business
operations needs and to perform certain services and functions, we may share data
with vendors and service providers. When we provide your information to these third
parties, we enter a contract that requires the recipient to keep that information
confidential. We do not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions, and the law. Other third
parties as required to provide our services. They may include: (a) government
agencies and taxing authorities; (b) banking and financial institutions; insurance
carriers; (c) legal and financial advisors and auditors.
Legal requirements. We may share your data, if required to do so by law or
our good faith belief that such action is necessary to: (a) comply with a legal
obligation; (b) protect and defend our rights or property; (c) act in urgent
circumstances to protect the personal safety of users of the services, or the
public; (d) detect, prevent, or respond to fraud, intellectual property
infringement, violations of this policy, our terms of service, violations of law, or
other misuse of our site or otherwise; (e) protect against legal liability.
Affiliates and business transfer. We may share data with our current and future
affiliates, meaning an entity that controls, is controlled by, or is under common
control with our company. Our affiliates may use the data we share in a manner
consistent with this policy. If we are involved in a merger, acquisition, financing
due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of
our assets, or transition of service to another provider (collectively a
“transaction”), your data and information may be shared in the diligence process
with counterparties and others assisting with the transaction and transferred to a
successor or affiliate as part of that transaction along with other assets. In such
event, we will use commercially reasonable efforts to help ensure that your data and
information will be subject to appropriate privacy protections, in accordance with
applicable privacy law.
3.6.Cookies. We use cookies and similar tracking technologies to track the
activity on our service and we hold certain information. Types of cookies we use may
include, but are not limited to:
a.Necessary cookies. These cookies are strictly essential in order to enable
you to navigate around the webpages and the various features. Our website requires
the use of these cookies to properly operate or provide necessary functions relating
to the services you request.
b.Analytical cookies. These cookies collect information about how you use
the website, for example, which pages are visited the most often as well as if any
error messages may have occurred. The information collected remains anonymous and
does not include any identifiable information about the website visitor.
c.Preferences cookies. These cookies allow our website to remember
information that changes how the website behaves or looks, like your preferred
language or the region you are in.
d.Marketing cookies. These cookies enable different advertising related
functions. They may allow us to record information about your visit to our website,
such as pages visited, links followed and videos viewed. We do not sell your data to
any third parties. We may use them, however, for gathering analytics and
intelligence about the site. These cookies only use anonymous identifiers and have
no way of associating identifiable users.
e.Third-party cookies. Some cookies we use are from third party companies,
which provide us with web analytics and intelligence about our websites. We do not
control the third party’s use of those cookies, their duration, or their ability to
share information with other third parties. Please review each party’s cookie
disclosure before consenting to this use category.
You can manage your cookies settings to clear or block specific cookies,
such as third-party cookies, or all cookies. You may consent to the use of all,
some, or none of our non-essential cookies. While continued use of the website will
imply your consent. You may withdraw your consent or otherwise limit your consent at
any time on our cookie choice page. Should you opt to accept all cookies, they won’t
be with you forever. With the exception of essential cookies, all cookies will
expire after two weeks.
You can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may not be able to
use some portions of our service. You can access these settings via our cookie
banner, or in your browser by going to the browser settings; this option should be
available for most browsers. Please keep in mind that by clearing all cookies, your
website preferences may be lost, including your ability to opt-out enabling cookies
as this function itself requires the placement of a cookie on your device.
4.1Self provided. We collect data when you create an account on our site, complete a
contact form on our site or request access to the service, subscribe to our service
or publications, request marketing to be sent to you, enter a competition, promotion
or survey, or give us feedback or contact us. In addition, we receive data provided
by you when filling in forms (e.g., applications or questionnaires) on our site or
other third-party sites, sign up to receive notifications, newsletters or other
communications from us, interact with our social media accounts or correspond or
otherwise communicate with us. You should check the privacy settings of third-party
services to understand what data may be disclosed to us.
4.2Third-parties provided. They may include:
a.Companies and business partners that introduce you to us;
b.Our service partners, third-party vendors and suppliers, including without
limitation those that help us authenticate your identity;
c.Social networks and other technology providers, for instance, when you
click on one of our google adverts;
d.Fraud prevention agencies;
e.Financial services companies to fulfil a payment or other service as part
of a contract which they have with you, or to help prevent, detect and prosecute
unlawful acts, money laundering, and fraudulent behavior;
f.Public information sources;
g.Third-party agents, suppliers, sub-contractors and advisers;
h.Market researchers;
i.Firms providing data services;
j.Government, law enforcement agencies, authorities and regulatory bodies to
help us comply with legal obligations.
4.3 Automatically collected and cookies. AzureSky may automatically collect
certain technical data when you access and interact with the site, including your ip
address, browser type, operating system, the type of device you are using, and the
device identifier. We also use technologies such as cookies, beacons, tags, server
logs, and scripts in order to gather information regarding your use of the site.
This allows us to analyze trends, administer the site, and gather demographic
information about our user base as a whole. We also use cookies and other internet
tracking software to collect data while you are using our website or mobile apps
with your consent. Some features of the site may only be available through the use
of a cookie. You are always free to decline cookies if your browser permits,
although in that case you may not be able to use certain features of the site and
you may be required to reenter your password more frequently during a session.
5.1 We will only retain your personal data only for as long as necessary to fulfill
the purposes for which it was collected, and consistent with applicable law, to
comply with our legal obligations, to resolve disputes, and to enforce our
agreements. We may keep your data and personal information for up to 5 years after
you stop being a client or user, in order to comply with legal rules that apply to
us about keeping records. For example, the money laundering terrorist financing and
transfer of funds (information on the payer) regulations 2017 require us to retain
certain data for a minimum of 5 and a maximum of 10 years.
5,2 We may also retain usage data for internal analysis purposes. Usage data
is generally retained for a shorter period of time, except when this data is used to
strengthen the security or to improve the functionality of our service, or we are
legally obligated to retain this data for longer periods. In that case, we will
aggregate or anonymize your personal data so that it can no longer be associated
with you.
5.3 In some circumstances you can ask us to delete your data, via email to
[email protected]. Please be aware that it is not always possible to completely
remove or delete all of your personal information from our systems due to backups or
technical constraints.
6.1 The security of your data and personal information is important to us. We
implement commercially reasonable technical, physical, administrative, and
organizational measures to protect personal data both online and offline from loss,
misuse, and unauthorized access, disclosure, alteration, or destruction. In
addition, we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to know. They will only
process your personal data on our instructions and they are subject to a duty of
confidentiality. Finally, we have put in place procedures to deal with any suspected
personal data breach and will notify you and any applicable regulator of a breach
where we are legally required to do so.
6.2 However, please be aware that no method of transmission over the
internet, email or method of electronic storage is ever fully secure or error free,
and we are unable to guarantee the absolute security of the personal information we
have collected from you. In addition, we are not responsible for circumvention of
any privacy settings or security measures contained on the site, or third-party
websites. You are also a key stakeholder in making sure that your personal
information is protected. If you become aware of any breach of security or privacy,
please contact us immediately.
6.3 Links to other sites. The site and service may contain links to other
websites including social media services not operated or controlled by us
(“third-party sites”). If you click on a third-party link, you will be directed to
that third party's site. By providing these links we do not imply that we endorse or
have reviewed these sites. We strongly advise you to review the privacy policy of
every site you visit. The information that you share with third-party sites will be
governed by the specific privacy policies and terms of service of the third-party
sites and not by this privacy policy. We have no control over, and assume no
responsibility for the content, privacy policies or practices of any third-party
sites or services. Please contact the third-party sites directly for information on
their privacy practices and policies.
7.1Information collected while you use the site and/or service, including your
personal information, may be transferred to and maintained on computers located
outside of your country or other governmental jurisdiction where the data protection
laws may differ than those from your jurisdiction. Your consent to this privacy
policy followed by your submission of such personal information represents your
agreement to that transfer. Accordingly, by using our services, you authorize the
transfer of your information to where we are based and to other locations where we
and/or our service providers operate, and to their storage and use as specified in
this privacy policy.
7.2 Specifically, whenever we transfer your personal data out of the eea, we
ensure a similar degree of protection is afforded to it by ensuring at least one of
the following safeguards is implemented: (a) (b) w
b.Where we use certain service providers, we may use specific contracts
approved by the european commission which give personal data the same protection it
has in europe.
b.Here we use providers based in the us or elsewhere, we may transfer data
to them if they provide evidence of similar protections to those afforded to
personal data in europe.
More details can be found in section 9 of this policy.
7.3 Cookies. The cookies we use may process, store, or transfer personal
data in and to a country outside your own, with privacy laws that provide different,
possibly lower, protections. You consent to this transfer, storing, or processing
when you consent to our cookie use.
8.1 We do not knowingly collect personal information from children under 14. If you
are a parent or guardian and you learn that your children have provided us with
personal information, please contact us. If we become aware that we have collected
personal information from a child under age 14 without verifiable parental consent,
we will take steps to remove that information from our servers.
8.2The age described in clause 8.1 may differ in different jurisdiction to
define a “child” In accordance with applicable laws (e.g. Age under 12, 13, 14, 15,
16 or 18). AzureSky will strictly comply with data protection laws where applicable.
9.1 The information below is required pursuant to eea law regarding privacy and data
protection. The terms below apply to our eea and uk customers and website visitors,
in addition to the terms in the rest of the policy. We collect, process, use and are
responsible for certain personal information about you, regulated under the general
data protection regulation (eu) 2016/679 (gdpr) which applies across the european
union and eea (including in the uk), and the data protection act 2018 (together with
the dpa).
9.2 Data transfer. You should be aware that when sharing your information,
it may be transferred to, and stored at, a destination outside the eea or the uk, as
applicable. Please note that where data is transferred outside of the eea, non-eea
countries may not offer the same level of protection for personal data as is
available in the eea. AzureSky will take various measures to ensure that your data
is treated securely, which may include, but not be limited to: (a) assessing the
security measures taken at any place your personal data is transferred to; (b)
having suitable contract terms in place that oblige a data processor to only process
in accordance with our instructions; (c) having monitoring, reporting and resolution
procedures in place with regard to ongoing security; and (d) only transferring your
data via an appropriate safeguard as described in article 46 of gdpr, including:
Standard contractual clauses adopted by the european commission (article 46.2).
9.3 Data subject rights. You have rights regarding how your personal data is
handled, especially some or all of the following:
a.To request access to your personal data;
b.To rectify inaccurate personal information;
c.To erase your personal information in limited circumstances where it is no
longer necessary in relation to the purposes for which it was collected or
processed; however, we may not always be able to comply with your request of erasure
for specific legal reasons which will be notified to you, if applicable, at the time
of your request;
d.To request the transfer of your personal data to you or to a third party;
e.To obtain a copy of your personal information together with information
about how and on what basis that personal information is processed; to obtain a
portable copy of your personal information, or to have a copy transferred to a
third-party controller; to obtain a copy of or access to safeguards under which your
personal information is transferred outside of the eea;
f.To challenge processing which we have justified on the basis of our
legitimate interest; to object to decisions which are based solely on automated
processing or profiling; to restrict processing of your personal information where:
The accuracy of the personal information is contested; the processing is unlawful
but you object to the erasure of the personal information; we no longer require the
personal information for the purposes for which it was collected, but it is required
for the establishment, exercise or defense of a legal claim; and/or
g.To withdraw consent at any time where we are relying on consent to process
your personal data; however, this will not affect the lawfulness of any processing
carried out before you withdraw your consent; and if you withdraw your consent, we
may not be able to provide certain products or services to you; we will advise you
if this is the case at the time you withdraw your consent.
We will not discriminate against you for exercising any of your rights
related to accessing, restricting, transferring, or deleting your personal
information. If you wish to exercise any of the rights set out above, please contact
us at [email protected]. We may ask you for additional data to confirm your
identity and for security purposes, before disclosing data requested to you. We
reserve the right to charge a fee where permitted by law. We may also decline to
process requests that jeopardize the privacy of others, are extremely impractical,
or would cause us to take any action that is not permissible under applicable laws.
Additionally, as permitted by applicable laws, we may need to retain certain
personal information for a limited period of time for record-keeping, accounting and
fraud prevention purposes.
If you have any questions about our privacy policy or information governance practices, please feel free to contact us ([email protected]). If you disagree with our approach or have a particular concern with how we handle your personal data, you may lodge a complaint with your country’s proper oversight agency. We would, however, appreciate the chance to deal with your concerns directly before you make a complaint so please contact us first.
For cross-border payroll solutions, you can trust AzureSky with confidence.