SkyLaunch Privacy Policy

Last Updated: January 23, 2025

General

SkyInCorp Inc. (d/b/a SkyLaunch) appreciates the sensitivity of Personal Information (as defined below) received in the course of providing our service. We are responsible for the Personal Information that we collect and store. The confidentiality of your Personal Information and protection of your privacy are important to us.

To ensure accountability, we have developed this Privacy Policy and have trained our staff about our policies and practices.

This Privacy Policy outlines how we manage your Personal Information. It forms part of SkyLaunch’s Terms of Service{link} (the “Terms of Service”), which governs your access to and use of our Website and Services (each as defined in the Terms of Service), whether as a guest or as a registered user. This Privacy Policy applies to Personal Information we collect, use, or disclose about you on the Website and in email, text, forms or other electronic messages between you and the Website.

Please read the Privacy Policy carefully before you start to use the Website and our Services. By using the Website and Services, you accept and agree to be bound and abide by the Privacy Policy. If you do not agree to the Privacy Policy, you must not access or use the Website or our Services.

Application of Privacy Laws and the Definition of Personal Information

Organizations engaged in commercial activities in Canada, including SkyLaunch, must comply with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and “substantially similar” provincial legislation.

Personal information is broadly defined in PIPEDA as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person (“Personal Information”). Such Personal Information may include an individual’s name, birth date, mailing and residential addresses, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, and any other identifier that may be used to contact the individual. However, Personal Information does not include business contact information including your name, position name or title, business address, business email address, and business telephone or fax numbers.

Collection and Use of Personal Information

We only collect Personal Information that is reasonably necessary for the legitimate purposes identified and for which consent has been obtained.

Information you Provide to Us

The Website provides various places for users to submit information. The information we collect directly from you on or through our Website may include:

• information that you submit by filling out forms on the Website, communicating with us via contact forms, engaging with interactive features and functionalities on the Website, providing comments or other feedback, and submitting information when ordering a product or service via the Website;
• information that you submit to us (including upon our request) when you report a problem with our Website;
• records and copies of your correspondence (including email addresses), if you contact us;
• your responses to surveys that we might ask you to complete for research purposes;
• details of transactions you carry out through our Website and through the use of our Services; and
• your search queries on the Website.

We use information you provide to us to deliver the requested product and/or service (including the Services) and to improve our overall performance. We may also use the information you provide to us to provide you with offers, promotions, and other information related to the Services.

Information Collected via Automated Tracking Technology

When you browse our Website or use our Services, we may utilize automatic data collection technologies such as Google Analytics to collect information that helps us learn about your browser and operating system, Website usage patterns, and related-site information on our Website, as well as responses and click-through activity on our publications, allowing us to optimize our web service and communications. We may also collect information about any communications and interactions between your computer and our Website, as well as your location, the type of computer you are using, your computer’s operating system, browser type and internet connection.

In addition, the Website utilizes server logs to collect information about how SkyLaunch is used. Information gathered through server logs may include the date and time of visits, the pages viewed, time spent at our site, as well as your computer’s internet protocol (IP) address.

The information collected automatically may be considered Personal Information and may be used for statistical purposes and for improving our Website and service offering.

Information Collected from Other Sources

Sometimes, we may obtain information about you from other sources including, but not limited to:

• a government agency or registry;
• your accountant, upon your authorization; or
• your other advisers, upon your authorization.

The kind of Personal Information we may collect includes, but is not limited to:

• contact information, identity verification information, and biographical information (such as job title); and
• Personal Information provided to us or generated by us in the course of providing our Services.

Consent

You consent to the collection, use and disclosure of your Personal Information in accordance with this policy whenever you:

• register an account with us;
• provide us with Personal Information to complete a transaction (such as an incorporation), including Personal Information for purposes of verifying the payment method (e.g., credit card) for the transaction;
• interact with our Website; or
• contact us or subscribe to our mailing list.

Where information is already available in the public domain, your consent may be implied for any collection, use or disclosure thereof.

If you provide us with the Personal Information of another individual, you represent that you have the appropriate authority to permit us to collect, use and disclose such Personal Information for the purposes set out in, and in accordance with, this policy.

Withdrawal of Consent

You may withdraw your consent to the collection, use and disclosure of your Personal Information at any time on reasonable notice by contacting us at the contact details below. However, your withdrawal of consent to our collection, use and disclosure of your Personal Information may affect our ability to provide services to you.

In some cases, we may be authorized or required by law to collect, use or disclose Personal Information without your consent.

Use of your Personal Information

We collect, use and disclose Personal Information for the primary purpose of providing our Services to you, including for the following purposes:

• presenting our Website and its contents to you;
• providing you with information;
• providing you with offers for products and services;
• providing you with information about your subscriptions and products;
• communicating with you;
• administering our business activities and operations;
• developing and improving the Website and the products and services we offer;
• to provide you with notices about your subscription, including expiration and renewal notices;
• to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent or as permitted or required by law.

Disclosure of your Personal Information

We may disclose your Personal Information in the following circumstances:

• to our subsidiaries and affiliates;
• when we are required or authorized by law to do so;
• when the Services we are providing to you require us to give your information to third parties, including when making government filings or where it is necessary to establish or collect payment (see “Disclosure of your Personal Information to Third-Party Service Providers” below for more information);
• to the Law Society of Ontario (the “LSO”) to ensure SkyLaunch’s compliance with the terms of the LSO’s Access to Innovation (“A2I”) program{link} (in which SkyLaunch is a participant), and the evaluation of A2I by the LSO;
• to contractors, service providers, and other third parties we use to support our business;
• to our insurers and to regulatory agencies in connection with regulatory or other activities in relation to the provision of our services to customers;
• to any successor or assign in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SkyLaunch’s assets and/or business, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding ;
• if requested by a person whom you have expressly authorized us to disclose to, such as your lawyer, accountant or other adviser or agent; or
• if the information is publicly available information, as specified under PIPEDA.

Disclosure of your Personal Information to SkyLaw

If you request to be connected to SkyLaw to assist with your legal needs, you will be asked to consent to us disclosing or transferring Personal Information we have collected from you to SkyLaw for the purposes of enabling a member of SkyLaw’s staff to contact you and conduct any required conflict checks. Following such connection, SkyLaw’s privacy policy will apply, as well as any applicable rules and regulations of the Law Society of Ontario to which SkyLaw is subject.

Disclosure of your Personal Information to Third-Party Service Providers

General

SkyLaunch relies on a number of service providers to assist in the performance of the Services. These include:

• government platforms (such as the Ontario Business Registry);
• cloud-based computing, access control (authentication) and data storage services;
• payment processors (see below for more information);
• customer messaging platforms; and
• website hosting service providers.

The third-party service providers that we utilize have their own privacy policies with respect to the information they collect from you for transactions conducted with SkyLaunch. These service providers are given the information they need only in order to perform their designated functions as part of SkyLaunch’s service offering. Our Privacy Policy does not apply to these third-party service providers but we do not disclose nor do we authorize them to disclose your Personal Information to any third party to enable them to market their products or services to you.

Payment Processing Services

We utilize a third-party payment processor, Stripe, Inc., to assist us with processing payments for our Services. In the course of providing payment processing services, Stripe may collect some Personal Information from you to allow them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. Where necessary for processing future or recurring payments and subject to your prior consent, your financial information will be stored in encrypted form on Stripe’s secure servers.

Stripe is a Level 1 PCI DSS service provider, which is required to adhere to the latest data security standards as managed by the PCI DSS Security Standards Council. We will share payment data with Stripe only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.

Information regarding Stripe can be found here: https://stripe.com/en-ca.

Retention of your Personal Information

We will retain Personal Information for as long as it is necessary for the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting requirements. We may be required by law to retain certain types of information for certain periods of time.

Security of your Personal Information

We take reasonable precautions including physical, organizational and technological measures to ensure that your Personal Information is kept safe from loss, theft, unauthorized access, disclosure, copying, use or modification. However, there is an inherent risk involved in the exchange of information over the internet or through the use of any form of communication, such as email, telephone, fax transmission and courier service. You should take proper precautions when sending us Personal Information, especially by email. We cannot guarantee that all electronic communications will always be received, or that such communications will always be virus-free.

The security of your Personal Information depends in part on the security of the computer or device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

Data Breach

In the event we become aware that the security of the Website has been compromised or any of our users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals in accordance with applicable law.

Accessing and Correcting your Personal Information

You may request access to any of your Personal Information in our possession. We will respond to any such request as quickly as possible. We may require you to supply enough information to verify your identity and enable us to account for the existence, use, and disclosure of Personal Information, and your right of access to such information.

Your rights to access your Personal Information are not absolute. We may deny you access to your Personal Information when:

• to do so is required or authorized by law;
• to do so would reveal confidential commercial information and the Personal Information cannot be severed from the record;
• to do so could reasonably be expected to harm the life or security of another individual and the Personal Information cannot be severed from the record;
• to do so would reveal information that is protected by solicitor-client privilege and such information cannot be severed from the record;
• the information was generated in the course of a formal dispute resolution process; or
• the information is prohibitively expensive to provide.

If we deny your request for access to your Personal Information, we will provide the reason for such denial.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.

You can review and change your Personal Information by logging into the Website and visiting your account profile page.

Links to External Sites

Our Website may contain links to other websites, which are not governed by this policy. We do not take any responsibility for the privacy practices of the third parties operating such websites. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every resource that may collect personal information from you.

GDPR

If you are visiting this Website from within the European Union (“EU”), you are entitled to certain information and have certain rights under the General Data Protection Regulation of the EU (“GDPR”) which include the following:

• We will retain any personal data (as defined by the GDPR) you choose to provide to us until the earlier of: (a) you asking us to delete such data, (b) our decision to cease using our existing data providers, or (c) we decide that the value in retaining the data is outweighed by the costs of retaining it.
• You have the right to request access to your personal data that we store and the rights to either rectify or erase your personal data.
• You have the right to seek restrictions on the processing of your personal data.
• You have the right to object to the processing of your personal data and the right to the portability of such data.
• To the extent that you provided consent to our processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.

You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the GDPR.

For more information about your rights as a website visitor from the EU and the GDPR, please see the European Commission website here: https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en.

Contact Information

If you have any questions, wish to request access, or make changes to your Personal Information, or if you would like to provide feedback or withdraw your consent from our use and disclosure of your Personal Information, please write to us at the following address:

SkyInCorp Inc. (d/b/a SkyLaunch)

3 Bridgman Avenue

Suite 204

Toronto, ON M5R 3V4

Attention: Privacy Officer

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Privacy Policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

Changes to this Policy

We may make changes to or update our Privacy Policy on our website any time. Any changes will be accessible on our website at www.skylaunch.ca. Changes to our Privacy Policy will be effective upon posting of the revised version on our Website. It is your responsibility to periodically review our Privacy Policy and we will treat your continued use of the Website and SkyLaunch’s Services following such change, modification, addition or removal as your acceptance of such changes. However, we will not, without your consent, use your Personal Information in a manner that is materially different than what was stated at the time your personal information was collected.