Privacy policy

This Privacy Policy applies to personal information collected, processed, or stored by Skycoach website (hereinafter – "Platform", "we" or "us") and describes the extent of collection and use of personal information by Deval Limited. Deval Limited, a company registered in the Republic of Cyprus under registration number HE 432317, having its registered office at 25 Martiou, 27 D. Michael Tower, flat/office 105A, Egkomi, 2408, Nicosia, Cyprus is a Data controller of personal information processed in accordance with this Privacy Policy. We give special attention to the confidentiality of information provided to us when you visit our website or otherwise communicate with us.

Definitions

"Personal information" means any information relating to an identified or identifiable natural person where an identifiable natural person is one 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 (hereinafter – "Personal Information" or "Personal Data"). For the purposes of this Privacy Policy, information shall constitute Personal Information only to the extent it is processed by Skycoach and enables, either on its own or in combination with other information reasonably available to Skycoach, the identification of a natural person in accordance with applicable Data Protection Laws;

"Data Protection Laws" means all applicable laws and regulations relating to privacy, data protection, and the processing of personal data;

"Data controller" (hereinafter – "Controller") is a party that sets out the purposes and means of processing of Personal Information. 

"GDPR" is Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC.

1. GENERAL PROVISIONS

1.1. This document, the Skycoach Privacy Policy (hereinafter – the Policy), contains our policies and provisions concerning the information collected about you by Skycoach.

1.2. By visiting or registering on the Platform, making or accepting Offers, obtaining any Services or digital content on the Platform you accept all terms and conditions of this Policy.

1.3. This Policy is a part of a body of documents that sets terms and conditions of use of the platform Skycoach – General Terms and Conditions, Terms of Services for Coaches, Terms of Services for Customers. Unless defined otherwise by this Policy, all terms and definitions used herein shall have the meaning defined in the above mentioned documents.

1.4. This Policy, including its construction, method of adoption, performance, amendments, and termination, is subject to the legislation of the Republic of Cyprus.

2. INFORMATION WE COLLECT

2.1. We may collect information, including personal information, about you when you provide it to us, when you use our Platform, and when other sources provide it to us, as further described below.

2.2. We process the following categories of personal information:

• Information provided directly by you
• Information collected automatically

2.2.1. Information provided directly by you

• Account and user information. We collect information about you such as email address, password, username (only for coaches), name and surname (only for coaches) when you register an account, create or modify user information, and/or provide (optionally: userpic (only for coaches) any other related information to access or use our Platform. We collect above mentioned data for the following purposes: 1) verifying your identity; 2) processing your registration as a user, and maintaining and managing your registration; 3) providing you with the opportunity to use the Platform’s functionality, responding to your inquiries, resolving the disputes; 4) notifying you about important functionality changes and alterations to the Platform (including changes to this Privacy Policy, Cookie Policy and/or the User Agreement); 5) internal record keeping.
• Data necessary for accessing respective account (optionally). We collect above mentioned data for the following purposes: 1) verifying your identity; 2) processing your registration as a user, and maintaining and managing your registration; 3) internal record keeping.
• Payment information* you provide during an Order, or other transaction and order-based content that you generate or that is connected to your account as a result of a transaction and the appropriate Order you are involved in (credit and debit card partial number, cardholder, the number of e-Wallet (if applicable) and related e-mail number for e-Wallet (if applicable). *Please pay your attention to the following: we DO NOT STORE AND DO NOT HAVE AN ACCESS to your card expiry date, billing address and CV code. For Visa cards we DO NOT HAVE A FULL ACCESS to the card number (e.g. 1234 5678 **** **00).

• Data necessary for participation in the Skycoach Affiliate Program (optionally). When you submit an application to participate in the program, we collect information about you such as name and surname, country, mobile phone number, email, Discord account, and accounts on other social media platforms. We process this data for the following purposes: 1) verifying your identity and assessing your eligibility to participate in the program; 2) processing your registration as a program participant and maintaining and managing your participation; 3) providing support services, including responding to your inquiries, claims, or disputes; 4) processing your payout requests and administering payments under the program; 5) internal record keeping and performing administrative functions necessary for the operation of the program.

• Payment information under the Skycoach Affiliate Program (optionally). When you submit an invoice after receiving a payout under the program, or when you provide any other payout-related or transaction-based data linked to your participation in the program, we process this information you provide. We use this data for the following purposes: 1) complying with legal obligations applicable to us, including accounting, reporting, taxation, and anti-fraud requirements; 2) internal record keeping and administering our financial operations. 

2.2.2. Information collected automatically

• Date and time of registration on the Platform. We collect this information from you for the following purposes: 1) internal record keeping; 2) processing your registration as a user; 3) maintaining and managing your registration.
• Details of visits to our site, including access time. We collect this information from you for the following purposes: 1) personalizing our communication with users based on the Order history and browser records, and performing research or statistical analysis in order to customize and improve the content and layout of the Platform; 2) market research purposes.
• Source of arrival on the Platform. We collect this information from you for the following purposes: 1) internal record keeping; 2) market research purposes.
• Country. We collect this information from you for the following purposes: 1) internal record keeping; 2) developing our Platform in accordance with applicable laws.
• IP address. We collect this information from you for the following purposes: 1) assessing account security and transaction risks of users; 2) detecting and preventing fraud and other security incidents. This information may be collected and/or processed by the third parties' analytics services, cookies, web beacons and another similar technology to gather information about the webpages you view, the links you click and other actions you may take when using our Platform. "Cookies" are small text files stored by your web browser when you use websites. For more information about using Cookies and how you can control Cookies please review our Cookie Policy Subject to user's prior consent cookies or other similar technologies may be used to provide you by electronic means with advertising and promotion materials based upon your browsing activities and interests (for more information see Cookie Policy ). You may at any time request that we discontinue sending you advertising and promotion materials, emails or other correspondence.

Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. Google Analytics uses cookies to help analyze how visitors use the website. The information generated by the cookies is transmitted to and stored by Google. Google Analytics helps us understand the use of our website by visitors. Because Google Analytics requires cookies to function, users who wish to avoid tracking by Google Analytics while on our website can disable cookies in their browser. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information about how Google uses data, please visit https://www.google.com/policies/privacy/partners/ .

Criteo. Criteo is an advertising platform that helps merchants to effectively target and retarget potential customers through personalised advertisements. It uses data-driven advertising technology to deliver targeted, relevant ads to consumers. Criteo tracks the browsing history and choices of users through the use of cookies, allowing it to serve personalised ads to them. For more information about how Criteo uses data, please visit https://www.criteo.com/privacy/.

Meta Pixel. The Meta Pixel is a snippet of JavaScript code that loads a small library of functions we can use to track Facebook ad-driven visitor activity on our website. It relies on Facebook cookies, which enable us to match our website visitors to their respective Facebook User accounts. Once matched, it tallies their actions in the Facebook Ads Manager so we can use the data to analyze our website's conversion flows and optimize our ad campaigns. For more information about how Meta uses data, please visit https://www.facebook.com/privacy/policy/.

Hybrid. Hybrid is a programmatic advertising ecosystem which provides access to all the advertising technologies through one interface in real time. For more information about how Hybrid uses data, please visit https://hybrid.ai/privacy_policy/ .

Intercom. We use third-party analytics services to help understand your usage of our Platform. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. ("Intercom") and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve the Platform. For more information on Intercom's use of cookies and collection of personal data, please visit Intercom's cookie policy and Privacy Policy | Intercom.

3. YOUR RIGHTS

Under data protection law as the data subject, you have rights we need to make you aware of. The rights available to you depend on our reason for collecting and processing your information.

• Right of access. You have the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the Personal Data and the following information:

  • the purposes of the processing;

  • the categories of Personal Data concerned;     

  • the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;   

  • where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;    

  • the existence of the right to request from the Controller rectification or erasure of Personal Data or restriction of processing of Personal Data concerning you or to object to such processing;

  • the right to lodge a complaint with a supervisory authority;     

  • where the Personal Data are not collected from you, any available information as to their source;     

  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.    

You also have the right to obtain a copy of your Personal Data undergoing processing, subject to any applicable legal limitations.

• Right to rectification. You have a right to obtain from the Controller the rectification of inaccurate Personal Data concerning the User or to have the incomplete Personal Data completed by providing a request.
• Right to erasure. You may ask us to delete your personal information in certain circumstances, for example, if your personal information is no longer needed for its processing or if you want to withdraw your consent. If we share your personal information with others, we will notify them that they need to erase your information where it is possible. However, we may retain part of your Personal Data, if necessary, to comply with our legal or professional obligations, enforce our agreements, or resolve disputes. For this purpose, we retain your part of your Personal Data for 6 years after the date it is no longer needed by us for any transactions, fulfilling contract purposes or marketing communications.
• Right to restriction of processing. You have the right to ask us to restrict the processing of your data in cases determined by law.
• Right to object to processing. You have the right to obtain from the Controller restriction of processing where one of the following applies:
  • the accuracy of the Personal Data is contested by the User;
  • the processing is unlawful and the User opposes the erasure of the Personal Data and requests the restriction of their use instead;
  • the Controller no longer needs the Personal Data for the purposes of the processing, but they are required by the User for the establishment, exercise or defense of legal claims;
  • the User has objected to processing pending the verification whether the legitimate grounds of the Controller override those of the data subject.
• Right to data portability. You have the right to receive the Personal Data concerning the User, which was provided by the User for the Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Controller to which the Personal Data have been provided.
• Right to withdraw a consent. If we rely on your consent to process your personal information, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
• Right to make a complaint with a supervisory authority. We work to high standards when it comes to processing your personal information. If you have queries or concerns, please contact us at [email protected] and we'll respond. If you have a concern about our privacy practices, including the way we handle your personal information, you can report it to the data protection authority that is authorized to hear those concerns – for example, the Commissioner for personal data protection as our business activity is located on Cyprus. You can contact the Commissioner for personal data protection at [email protected].
• Right to non-discrimination. We will not discriminate against you (e.g., through refusing to provide the opportunity to use the Platform or limiting your access to the Platform) for exercising any of the rights available to you.

4. LEGAL BASIS

Skycoach processes your Personal Data strictly in accordance with applicable data protection laws, including the GDPR. Our processing activities rely on three principal legal bases: contractual obligations, User consent, and legitimate interests. Under the GDPR, we shall always have a lawful basis for processing your Personal Data.

Our legitimate interest and legal and professional obligations which includes the following cases:

• to detect, prevent and investigate fraud or other potentially prohibited or unlawful activities;
• to ensure access to the Platform;
• to improve the quality and maintain functionality of the Platform and to adapt it to what users like based on users' actions on the website;
• to contact you regarding your account actions, potential troubleshoot issues, resolving disputes or provide other necessary assistance.

To make sure that the Personal Data we process is necessary for the interests mentioned above, we perform a Legitimate Interests Assessment which consists of the following test:

1. The assessment of whether a legitimate interest exists;
2. The establishment of the necessity of processing;
3. The performance of the aforementioned balancing test.

Through this test we analyze the impact of processing, the nature of the interests and whether they can apply and the safeguards measures which we shall put in place.

Skycoach sends technical and service communications (such as order confirmations, password resets, policy updates) (hereinafter – “Technical communications”) necessary for providing you with Platform’s functionality and fulfilling our contractual obligations. Such communications do not require separate consent. Marketing and advertising communications will only be sent with your prior explicit consent, which you can withdraw at any time. Skycoach ensures these communications fully comply with GDPR and clearly distinguishes between Technical and marketing communications.

Skycoach regularly conducts compliance reviews to ensure that our Technical communications adhere to applicable data protection laws, including GDPR.

5. DATA RETENTION PERIOD

We retain Personal Data for as long as your account is active or as necessary for the duration of the purposes outlined in this Privacy Policy. Notwithstanding the duration of the purposes or the status of your account, we may retain part of your Personal Data, if necessary, to comply with our legal or professional obligations, enforce our agreements, or resolve disputes. For this purpose, we retain your part of your Personal Data for 6 years after the date it is no longer needed by us for any transactions, fulfilling contract purposes or marketing communications.

6. CHILDREN'S PRIVACY PROTECTION

We understand the importance of protecting children's online privacy. The functionality of our Platform is intended for individuals who are 18 (eighteen) years of age or older. If you are under 18 (eighteen) ("Minor"), you shall obtain and provide documented parental or legal guardian consent, along with any additional required verification, before accessing the Platform. Should we become aware that Personal Data from a Minor has been collected without proper authorization, we shall promptly delete that data.

7. MEASURES WE APPLY FOR THE INFORMATION SECURITY

We have in place reasonable commercial standards of technology and operational security and appropriate legal measures to protect all personal information provided by Users from unauthorized access, disclosure, alteration, risks of loss, misuse or unlawful erasure, as well as from any other unauthorized form of processing.

For registered Users of the Platform the Personal Data provided is protected by a password. We recommend that you do not disclose your password to anyone. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.

We kindly ask you to note that we cannot guarantee the privacy or security of your Personal Data once you provide it for any third party and we encourage you to evaluate the privacy policy before deciding to share your Personal Data.

In case a User loses access to the account or in case of detection of fraudulent or deceptive activity, we are entitled to request a photocopy/scan/photo of an ID (citizen passport, driver's license, ID card etc.) to validate registration data or the User's rightful possession of the specific account.

8. DISCLOSURE OF INFORMATION TO THIRD PARTIES

We may disclose and transmit (whether within or outside the jurisdiction of Deval Limited that is the Controller) your Personal Data to our business partners and to hosting providers engaged by us to provide you with the Platform’s functionality or who otherwise process Personal Data for the purposes described in this Privacy Policy or notified to you when we collect your Personal Data. Your personal information may also be disclosed to employers of Deval Limited and legal consultants in order to respond to your requests or inquiries.

Personal information may also be disclosed to law enforcement, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.

All of these disclosures may involve the transfer of personal information to countries or regions without data protection rules similar to those in effect in your area of residence. Where we transfer your personal data as described above, we will take steps to ensure that your personal data receives adequate security protection where it is processed and your rights continue to be protected pursuant to the applicable data protection law, including through the use of Standard Contractual Clauses approved by the European Commission. If you would like to receive more information on the safeguards that we implement as described above, please contact us as indicated below.

We use Discord as a communication channel for interactions under the Skycoach Affiliate Program between us and the participants of the program. Such processing is carried out on the basis of our legitimate interest in (i) ensuring effective, fast, and streamlined communication with participants of the program, (ii) maintaining the operational efficiency of the program, and (iii) providing timely support and any other information about the program to participants through a unified communication channel.

In connection with this, the personal data you provide to us may be transferred to and processed by the relevant legal entities operating the Discord, to the extent necessary for enabling such communication. Discord’s legal entities act as independent data controllers for such processing. Discord processes personal data in accordance with its own Privacy Policy. 

9. CHANGES TO THIS PRIVACY POLICY AND FUTURE DEVELOPMENTS

We continually improve and update our Platform to enhance your experience. As a result, our Privacy Policy continues to evolve. As soon as we implement new technology or otherwise change the Platform’s functionality, we will update our Privacy Policy accordingly. We encourage you to refer to this page on an ongoing basis for our most current Privacy Policy and practices.

If our information practices change at any time in the future, we will post the policy changes on this page including the effective date of the amended version of the Privacy Policy and such modified or amended Privacy Policy shall be effective as to you and your information as of that effective date. If we make any material changes, we will announce it and notify you by means of a notice on this website.

10. FINAL PROVISIONS

10.1. We may scan messages automatically and check for spam, viruses, phishing and other malicious activity, illegal or prohibited content or violations of our usage policies, this Privacy Policy and the Cookie Policy.

10.2. We may process and retain your Personal Data on our servers.

10.3. These Privacy Policy provisions are subject to the law of Cyprus. All the disputes regarding the provisions of this Privacy Policy shall be settled by negotiation and, in case of failure to resolve an issue by negotiation, the dispute shall be taken to courts of Cyprus. Nothing in this Privacy Policy shall limit, waive or otherwise restrict any rights or remedies available to data subjects under the GDPR, including the right to lodge a complaint with a competent supervisory authority or to seek an effective judicial remedy in accordance with the GDPR.

10.4. You can visit this website not providing any information about yourself, however, if you want to use the Platform's functionality, we will ask you to provide your Personal Data and to carry out established identification procedures. If you not register on the Platform, we do not collect your Personal Data, however, your Personal Data may be gathered by Google Analytics.

10.5. By visiting or registering on the Platform, making or accepting Offers, obtaining any Services or digital content on the Platform, you acknowledge and confirm that you have read the Privacy Policy, understand it and agree with it. We kindly ask you to note that when visiting this website, you have a responsibility to make sure that you are familiar with the latest version of the Privacy Policy that applies to you at the time you are visiting the website.