PRIVACY
The Company endeavors to fully comply with all applicable international, federal and state laws, rules, and regulations, as well as similar local / regional laws, rules, and
regulations. The Company is not a bank, a bank holding company, or a subsidiary of a bank or a bank holding company. However, the Company partners with banks (each, a
“Bank Partner”) to provide services to its customers / consumers / entities that are within the scope of Bank Partners ’obligations. Accordingly, the Company takes its role in
ensuring its best business practices comply with all laws, rules, and regulations very seriously and to give the best reasonable assurance of safety & soundness of the company
and the relationships that it holds.
This privacy policy (“Privacy Policy”) describes how SKYWAY PAYMENTS, and each of its affiliates, subsidiaries, and
divisions (collectively “we” or “us”), collect, use, and disclose user (“you” or “your”) information.
This Policy applies to our websites and other online services that post or include a link to this Privacy Policy (collectively, the
“SKYWAY PAYMENTS Platforms”). The SKYWAY PAYMENTS Platforms are owned or controlled by us.
What Information Do We Collect?
We may collect the following information about individuals or businesses (“Information”):
“Personal Information” that may directly identify you, such as your name, address, telephone number, email address, and
bank account or other financial information that you submit directly to us.
“Business Information” such as a business’s name, physical address, phone number, legal SKYWAY PAYMENTS type,
industry, employer identification number or any other additional information that we may request.
“Usage and Device Information” such as the hardware model, browser, and operating system that you are using, the URL
or advertisement that referred you to the SKYWAY PAYMENTS Platforms, all of the areas within the SKYWAY PAYMENTS
Platforms that you visit, location information, and mobile network (if applicable), your IP address or other unique device
identifier for any computer, mobile phone, or other device that is used to access the SKYWAY PAYMENTS Platforms. In some
cases, we may directly collect location information through your device. You may be able to turn off the collection of location
information through the settings on your device. Business Information and Usage and Device Information are generally non-
identifying, but if we associate it with a specific and identifiable user, we treat it as Personal Information.
How Do We Collect Your Information?
From You. We collect Information that you provide directly to us, both online and offline, in connection with an inquiry about
our services, an application to obtain our services, or payments for our services made to us or our agents. The Information
collected from you will vary depending on the product or service requested.
Other Sources. We may obtain Information about you from our affiliates and other third-parties such as merchants, recipients
and senders of funds, data providers, identity verification providers, and credit bureaus, where permitted by law. that collect
your information in order to submit your application to us. We may also use certain third parties to complete, validate, or verify
Information that you have provided to us in order to assist you in your use of the SKYWAY PAYMENTS Platforms, in order to
supplement information already provided by you, or in the prevention or identification of identity theft and fraud.
Automatic Collection, Cookies, and other Internet Technologies. We also use cookies, web beacons, other standard
internet technologies, and certain third parties to collect Information from you, from your device, and about your activities on
the SKYWAY PAYMENTS Platforms. We may automatically collect Information from your browser when you use the SKYWAY
PAYMENTS Platforms.
Cookies. A cookie is a small text file that is stored on your computer for record keeping purposes. When you visit the SKYWAY
PAYMENTS Platforms, we may assign your computer one or more cookies to facilitate your access, personalize your online
experience, maintain continuity during your online sessions, and record information about your visit. Cookies may also be used
for anti-fraud and information security purposes, Through the use of a cookie, we also may automatically collect information
about your online activity, such as the web pages visited, the links or advertisements clicked on, and other actions taken while
using the SKYWAY PAYMENTS Platforms. We may use different kinds of cookies, including HTTP cookies (also known as
browser cookies), Local Shared Objects such as Flash cookies, and other similar technologies, such as HTML5 local storage.
Most browsers automatically accept cookies, but you can usually modify the browser setting to decline cookies. Flash Cookies,
which by their nature are associated with Flash Player, may be removed by managing the settings with Adobe by visiting
www.adobe.com. If you choose to decline cookies, please note that some of the features and services of the SKYWAY
PAYMENTS Platforms may not function properly.
Web Beacons. Web beacons (also known as clear gifs, pixel tags, targeting and re-targeting pixels, third party pixels or web
bugs) are small graphic images or other web programming code that may be included in our web pages and e-mail messages.
Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to
the SKYWAY PAYMENTS Platforms, to monitor how you navigate the SKYWAY PAYMENTS Platforms, or to count how
many e-mails that were sent were actually opened.
How Do We Use Your Information?
Our Usage. We may use your Information, to: i) process, review, determine eligibility, and approve or deny your application
for Products & Services you request; ii) manage your customer relationship, respond to questions, and provide customer
service; iii) develop and display content and services tailored to your interests; iv) communicate with you via email, telephone,
postal mail, and/or your mobile device about our Products & Services; v) operate, evaluate, and improve our business and
the SKYWAY PAYMENTS Platforms, including to develop new Products & Services, to perform research, and for audit
purposes; vi) analyze usage and performance of the SKYWAY PAYMENTS Platforms and improve your experience and the
experience of other users; vii) to comply with legal obligations and regulations, enforce contractual obligations, verify your
identity, and to help prevent or identify fraud, unauthorized or criminal activity, claims, and other liabilities; viii) market our
Products & Services and the Products & Services of our affiliates and other third parties; and ix) perform functions as
described to you at the time of collection. We will not sell your Personal Information, except in the event that all or a part of our
business is merged, sold, or reorganized.
Job Applicants. If your Information is submitted when applying for a position with us, the Information will be used solely in
connection with considering and acting upon your application. We may retain your Information for a period of time, but only for
the purpose of considering your application for current or future available positions or as required by law.
With Whom Do We Share Your Information?
Our Businesses. We may share your Information with our affiliates and subsidiaries.
Service Providers. We may share your Information with third party service providers who provide services to us or on our
behalf to assist in providing our services and to help us understand our users’ use of our products. Service providers include
the categories listed in this section 4, along with shipping vendors, billing and refund vendors, payment card processors,
merchants, and other companies that help us operate and improve our Products & Services. Your Information may be stored
and processed by our service providers in the United States or other locations where the service providers or we maintain
facilities. Disclosure of your Personal Information to service providers is not a sale, and we do not allow our behalf
Consumer and Credit Reporting Agencies. We may provide your Information to consumer and/or credit reporting agencies
and to third parties that provide identity verification and fraud detection.
Marketing. We may share your Information with select third parties so that they can send you promotional materials about
goods and services (including special offers and promotions) on our behalf.
Third-Party Advertising and Analytics Companies. We may share your Information with network advertisers, ad agencies,
and other advertising partners to serve our ads online. We may also use analytics providers to provide us with information
regarding the use of the SKYWAY PAYMENTS Platforms and the effectiveness of our advertisements. You may see ads on
the SKYWAY PAYMENTS Platforms and those ads may be served by a third party. These third parties may set and access
their own tracking technologies on your device (including cookies and web beacons), and they may otherwise collect or have
access to Information about you. Some of these parties may collect Information (including Personal Information) over time
when you visit the SKYWAY PAYMENTS Platforms or other online websites and services. We may share Information,
including Information that has been de-identified, with third party advertising companies, analytics providers and other third
parties, including for the purpose of serving you more relevant ads.
We may use a variety of companies to serve our advertisements. Some of these companies are Customers / Consumers of
the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online
Behavioral Advertising and you may want to visit the following webpages, which provide “opt-out” mechanisms for participating
companies: http://networkadvertising.org/managing/opt_out.asp; http://www.aboutads.info/choices/. You may also be able to
opt-out from certain interest-based advertising through your mobile device settings or as described below in the Section titled
“What Are Your Options Regarding Your Information.” Please note opting out through these mechanisms does not opt you out
of being served advertising. You will continue to receive generic ads while online.
Other Situations. In addition to other sharing described in this section, we may also disclose your Information at our sole
discretion: (i) in order to comply with laws or legal processes, including subpoenas or agency orders and investigations under
appropriate circumstances; (ii) as we reasonably determine necessary or appropriate to protect property, our rights, or the
rights of others; and (iii) to enforce our contracts, policies, and customer agreements. We may also transfer Information covered
by this Privacy Policy, including Personal Information, in connection with a merger, sale, or acquisition (including transfers
made as part of insolvency or bankruptcy proceedings) of all or part of our business or as part of a corporate reorganization,
stock sale, or other change in control.
How Do We Protect Your Information?
We maintain administrative, technical, and physical safeguards intended to protect against the loss, misuse, unauthorized
access, and disclosure of Information, including your social security number. Although we take such precautions seriously, it
is impossible for us to guarantee the safety and security of your Information. Our policies prohibit the unlawful disclosure of
Personal Information. We share Personal Information externally only where federal and state law allows or requires it.
Internally, it is our policy to limit the access, use, and disclosure of Personal Information to be in line with the job duties of our
employees, as well as applicable law. Please note that we do not ensure or warrant the security of any Information that we
collect, and you use the SKYWAY PAYMENTS Platforms and our services and provide us with your Information at your own
risk.
What Are Your Options Regarding Your Information?
Accessing and Correcting Personal Information. You may request to access or update the Personal Information that we
hold about you. You can access or update your Personal Information in the following ways:
If you have created an account on the SKYWAY PAYMENTS Platforms, you will be able to update your
own contact and payment information, subject to certain limitations.
Contact us through one of the methods listed in the “How Can You Contact Us?” section within this Privacy
Policy. Please include your current contact information, the information that you are interested in
accessing, and your requested changes. After authenticating your request, we will provide you with the
Personal Information that you requested or make your requested changes if i) the information is
reasonably available; ii) the information does not infringe on the privacy of other individuals, and iii) the
disclosure or changing of the information is not otherwise prohibited by law or our internal policies or
procedures. For all requests, we will reasonably describe the types of Personal Information that we
generally collect, how it is used, and with whom it is shared.
Communications. You may elect to opt-out of email and text communications from us by following the instructions provided
in such communications or by contacting us as described in this Privacy Policy. Even after opting out, you may still receive
service oriented, non-promotional communications from us and promotional communications from other third parties as a result
of their own interactions or transactions with you. Please allow time for us to process requests. You should contact us should
there be any concerns about your opt-out request.
Targeted Advertising. You may opt-out from many third parties who serve online advertising, including some who serve ads
on the SKYWAY PAYMENTS Platforms and elsewhere online, by visiting http://www.networkadvertising.org/managing/opt_out.asp;
or http://www.aboutads.info/choices/. Opting out does not mean you will not see any ads when using the SKYWAY PAYMENTS
Platforms, but the ads that you see will no longer be customized to you based on your profile or interactions with us.
“Do-Not-Track.” Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online
services that you visit. Like many websites and online services, the SKYWAY PAYMENTS Platforms do not alter their practices
when they receive a “Do Not Track” signal from your browser. To find out more about “Do Not Track,” please visit
How Can Your Contact Us?
If you wish to contact us regarding your Information, this Privacy Policy, to designate a third party who may communicate with
us on your behalf, or to request to access, change, or delete your Personal Information, you may contact us as described
below. If you choose to contact us, please provide sufficient contact information to allow us to contact you. If you choose to
contact us, we will verify your identity using an appropriate method of verification based on the type of request. These methods
may include one or more of the following: email address verification, proof of residency displaying your name and principal
residence address, or proof of identity using government issued identification.
For Information Security & Information Technology issues:
For Compliance, Fraud & Physical Security Issues:
Will This Privacy Policy Change?
This Privacy Policy may be updated periodically to reflect relevant changes in our information practices. We will notify you of
material changes by posting the changed or modified Privacy Policy on the SKYWAY PAYMENTS Platforms. We may also
provide notice to you in other ways in our discretion, such as through contact information that you have provided. Any changes
to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified,
and your continued use of the any of the SKYWAY PAYMENTS Platforms after the effective date of the revised Privacy Policy
will constitute your consent to those changes. You may be required to consent to our new policies in order to continue to use
the SKYWAY PAYMENTS Platforms and our services.
Third Party Content and Sites
The SKYWAY PAYMENTS Platforms may contain content, services, advertising and other materials that link to websites
operated by third parties. We have no control over those other websites, and this Privacy Policy does not apply to them. You
should refer to the privacy policies of those websites.
California Privacy Rights
The California Consumer Privacy Act (CCPA) provides consumers residing in California with several rights concerning their
personal information, including but not limited to the ability to request the personal information being collected and the option
of deleting certain collected personal information.
Requests for access, deletion, and to know what we share with others should be submitted as described in the “What Are Your
Options Regarding Your Information?” and “How Can You Contact Us” sections. SKYWAY PAYMENTS will attempt to respond
to a verifiable consumer request within 45 days of its receipt.
We will not discriminate against California residents who exercise their rights under this section. Any such request will not
result in the denial of any goods or services offered by SKYWAY PAYMENTS. It will not result in different prices, rates or
quality of goods or services.
Compliance is a living Program, a living document
Great and Strong Compliance is Great for Business