1. INTRODUCTION

    This Privacy Policy provides information on the collection, use, and sharing (collectively referred to ‘processing’ or ‘process’) as of personal information by Blue Sky Corporation and its affiliates (“Blue Sky”, “we” or “us”) in connection with your use of Blue Sky websites, mobile applications, and social media pages that link to this Privacy Policy, your interactions with Blue Sky during in-person meetings or at Blue Sky events, and in the context of other offline sales and marketing activities. This Privacy Policy also explains the privacy rights you have in relation to these processing activities.

    This Privacy Policy was last updated on May 12, 2020. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example via a pop-up notice or statement of changes on our website).

    As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, business contact details, or information gathered through your interactions with us via our websites or at events. Personal information is also referred to as ‘information about you.’ For more detail about the types of information about you that we may process, please refer to Section 4 below.

    2. SCOPE

    This Privacy Policy applies to the processing of personal information by Blue Sky of:

    • visitors and users of the various Blue Sky sites, including our websites on blueskygrs.com, computer or mobile software applications and our social media pages that link to this Privacy Policy (collectively referred to as the sites);
    • attendees of Blue Sky events, or Blue Sky-sponsored events;
    • customers and prospective customers and their representatives;
    • subscribers to Blue Sky newsletters, publications, services and solutions; and
    • suppliers and business partners and their representatives.

    When interacting with our websites, you also have the ability to link or connect with non-Blue Sky websites, services, social networks, applications or other features. Enabling these features will lead to other parties than Blue Sky processing information about you. Blue Sky does not have any control over these features of other parties. We encourage you to review the privacy policies of these parties before using these features.

    3. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

    Blue Sky and its affiliated entities are responsible for processing your personal information described in this Privacy Policy.

    4. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?

    Blue Sky can process information about you collected both offline and online.

    • Offline information about you originates from our interactions with you during in-person meetings or at Blue Sky events, conferences, workshops or gatherings;
    • Online information about you originates from your activities on our sites, for example, in relation to your Blue Sky accounts, (pre-)sales inquiries or subscription to our magazines, or from your interactions with Blue Sky via electronic communication tools such as email or telephone. Information about you may also be provided by third-party sources, such as data aggregators who may not have a relationship with you. Online information about you may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties. For more information on cookies and similar technologies, please see Section 11 below.

    Specific pieces of information about you that Blue Sky may be collect and process includes:

    • name and physical address, email addresses, and telephone numbers;
    • demographic attributes, when tied to personal information that identifies you;
    • photographs and testimonials;
    • transactional data, including products and services, ordered, financial details and payment methods;
    • company data such as the name, size, and location of the company you work for and your role within the company;
    • data from surveys and publicly available information, such as social media posts;
    • call recording and chat transcript data from Sales and customer support calls and live chat sessions;
    • unique IDs such as your mobile device identifier or cookie ID on your browser;
    • IP address and information that may be derived from IP address, such as geographic location;
    • information about a device you use, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, and the preferred language;
    • behavioral data of the internet-connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site; and
    • CEO name linked to the CEO’s company information and activities (for certain Blue Sky services relating to public company information and activity).

    Please note that Blue Sky does not control the content that you may post to Blue Sky Communities forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.

    5. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

    We may use personal information for the following business purposes:

    • to communicate and respond to your requests and inquiries to Blue Sky;
    • to deliver functionality on our sites and for their technical and functional management;
    • to engage in transactions with customers, suppliers and business partners and to process orders for Blue Sky products and services;
    • to analyze, develop, improve and optimize the use, function and performance of our sites and products and services;
    • to manage the security of our sites, networks and systems; and
    • to comply with applicable laws and regulations and to operate our business.

    We may use personal information for the following commercial purposes:

    • to administer magazine subscriptions; and
    • to market our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests.

    We may also use the names of company CEOs to provide select services to Blue Sky customers which may include publicly-available information regarding names of company CEOs.

    These purposes are described below in further detail.

    To communicate and respond to your requests and inquiries to Blue Sky

    If you get in touch with us (such as by submitting contact forms on our sites, attending Blue Sky events or other occasions, sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries. We can also process personal information to interact with you on third party social networks.

    To deliver functionality on our sites and for their technical and functional management

    When you choose to register with us (such as to make use of our communities), we need to process the personal information provided by you so that we can create and manage a personal account for you. Upon creating your account, we will send you your personal login information. This personal information enables us to administer your account, for example by changing your password for you.

    To engage in transactions with customers, suppliers and business partners and to process purchases of our products and services

    If you place an order for our products and services, or if you provide services to Blue Sky, our employees, customers or partners as a supplier or business partner, Blue Sky processes information about you to engage in and administer the relevant transactions (such as by sending invoices and making payments), administer your order, and help you get started and adopt our products and services (e.g., by contacting you to activate your Cloud services credits). If you download products or services from our sites, Blue Sky uses information about you to confirm certain information about your order (for example, that you did not experience problems in the download process).

    To analyze, develop, improve and optimize the use, function and performance of our sites and products and services

    We may process personal information in order to analyze, develop, improve and optimize the use, function and performance of our sites and products and services, including for quality assurance and training purposes, as well as for marketing and sales campaigns. In case the sites permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities, Blue Sky may process personal information when moderating these activities.

    To manage the security of our sites, networks and systems

    We may collect site use data for security and operations management to help keep our sites, networks and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots.

    To comply with applicable laws and regulations and to operate our business

    In some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.

    To administer subscriptions of magazines

    If you subscribe to our magazines, we process information about you to administer your subscription to our magazines (including the renewal process).

    To market our products and services or related products and services and to tailor marketing and sales activities

    Blue Sky may use information about you to notify you about new product releases and service developments, events, alerts, updates, prices, terms, special offers and associated campaigns and promotions (including via newsletters). Blue Sky may also use personal information to advertise Blue Sky’s products and services or related products and services, and also to have our distributors, resellers or partners notify you about our products or services or their related products or services (such as via joint sales or product promotions). We do our best to tailor your website visit, marketing experience and our communications to your expressed interests. This happens, for example, if you sign up for a Blue Sky community or program.

    If you attend an event, Blue Sky may process information about you gathered in relation to the event and can share information about your attendance with your company. Blue Sky may also permit designated event partners or conference sponsors to send you up to two communications related to your event attendance. Please note that our partners or conference sponsors may directly request information about you at their conference booths or presentations, and their use of your information that you provide to them will be subject to their privacy policies.

    We may also process your personal information to post testimonials on our sites, but will first obtain your consent to use your name and testimonial.

    To provide select services to Blue Sky customers which may include publicly-available information regarding names of company CEOs

    For some services, we may collect the publicly-available names of CEOs of companies to better understand the status of these companies and help inform our services which relate to providing customers information about other companies.

    6. WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU?

    For personal information collected about you in the EU, our basis for processing is the following:

    • In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information.
    • In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
    • We process personal information for marketing and sales activities based on your consent where so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services.
    • We rely on our legitimate interest to analyze, develop, improve and optimize our sites, products and services, and to maintain the security of our sites, networks and systems.
    • In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

    7. FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATION

    Blue Sky maintains personal information for the following retention periods:

    • Information about you we collect to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
    • If you have registered for a Blue Sky account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for 18 consecutive months. Blue Sky retains records of that deletion for 90 days.
    • If you have registered for our newsletters and blogs, including magazine, your subscription data will be retained for as long as you are subscribed to our distribution lists. Blue Sky retains records of that deletion for 30 days.
    • Contact information such as your email address or phone number collected online on our sites or offline from our interactions with you at Blue Sky events and conferences, and used for direct marketing and sales activities will be retained for as long as we have an active (customer) relationship with you. We treat you as an active contact if (i) you have interacted with Blue Sky or updated your contact details and preferences in the past 18 months; and (ii) you have not made a deletion request.
    • If you have reached out to us via Blue Sky Sales chat, we will delete all chat transcripts 90 days after the chat has concluded.
    • If you have reached out to us via our support line and you have not opted out of call recording, we will delete call recordings 60 days after the call has concluded unless otherwise specified during the call.
    • Personal information needed to retain your opt-out preferences is retained for 20 years (or longer as necessary to comply with applicable law).

    8. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?

    Sharing within Blue Sky

    As a global organization, information about you may be shared globally throughout Blue Sky’s worldwide organization. Blue Sky employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

    Sharing with third parties

    We may share personal information with the following third parties for a business purpose:

    • Third-party service providers (for example, credit card processing services, order fulfillment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of Blue Sky;
    • Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
    • As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

    We may share personal information with the following third parties for a commercial purpose:

    • Blue Sky distributors or resellers for further follow-up related to your interests, specific partners that offer complementary products and services or with third parties to facilitate interest-based advertising.

    When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

    9. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

    Blue Sky is a global corporation and personal information is processed globally. If personal information is transferred to a Blue Sky recipient in a country that does not provide an adequate level of protection for personal information, Blue Sky will take measures designed to adequately protect information about you, such as ensuring that such transfers are subject to the terms of the EU Model Clauses.

    10. HOW IS YOUR PERSONAL INFORMATION SECURED?

    Blue Sky has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

    11. WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE ON OUR SITES?

    Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Blue Sky and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.

    • When do we use cookies and similar technologies?

    Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. Any browser visiting our sites will receive cookies from us. We also place cookies in your browser when you visit non-Blue Sky sites that host our plugins or tags.

    We use cookies and other technologies on all our sites to ensure the best possible and secure experience on our sites and to provide you with tailored information on products and services.

    Blue Sky also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device, as well as behavioral data of your device usage on our sites (e.g. pages viewed, links clicked, documents downloaded). This information contributes to Blue Sky’s services designed to provide targeted digital advertising and personalization services to Blue Sky customers.

    Blue Sky uses Google Analytics on its websites. Please refer to Google’s privacy policy for more information on how Google uses information collected via its Google Analytics services

    • How can I manage my cookie preferences?

    If you are a visitor of our sites, you have a choice to accept or reject our cookies policy upon your first visit to our sites.

    If you do not want to receive cookies, or wish to change a prior choice you have made on our sites for accepting or rejecting the use of cookies, you can also change your browser settings on your computer or another device you are using to access our services. Most browsers also provide functionality that lets you review and erase cookies, including Blue Sky cookies.

    12. WHAT ARE YOUR PRIVACY RIGHTS?

    We provide multiple choices in respect of the information we process about you:

    • Opt-out of our use or sharing of your personal information
      You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Blue Sky.
    • Delete personal information
      You can ask us to erase or delete all or some of the information about you.
    • Change or correct personal information
      You can edit some of the information about you by. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.
    • Object to, or limit or restrict use of personal information
      You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).
    • Right to access and/or have your information provided to you
      You can also ask us for a copy of information about you and can ask for a copy of information about you provided in machine readable form if you reside in the EU, California or other jurisdiction that provides you this right as a matter of law.

    You can exercise these choices in accordance with applicable laws by filling out our contact form.

    13. DO YOU COLLECT SENSITIVE INFORMATION AND INFORMATION FROM CHILDREN?

    Sensitive personal information

    We ask that you do not send us, and do not share any sensitive personal information (for example, government-issued IDs, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

    Children’s privacy

    As a company focused on serving the needs of businesses, Blue Sky’s sites are not directed to minors and Blue Sky does not promote or market its services to minors, except in very limited circumstances as part of specific educational outreach programs with parental permission. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our sites without appropriate consent, please notify us through our inquiry form so that we may immediately delete the information from our servers and make any other necessary corrections. Additionally, please use this same form to request removal of content or information that was posted to our sites when the registered user was under the age of 16. Please note that such requests may not ensure complete or comprehensive removal of the content or information, as, for example, some of the content may have been reposted by another user.

    14. WHAT ARE YOUR RIGHTS UNDER THE California Consumer Privacy Act (CCPA)?

    If you are a California resident, you may request that we:

    • disclose to you the following information covering the 12 months preceding your request:
      • the categories and specific pieces of personal information we collected about you and the categories of personal information we sold (see Section 4);
      • the categories of sources from which we collected such personal information (see Section 4);
      • the business or commercial purpose for collecting or selling personal information about you (see Section 5); and
      • the categories of third parties to whom we sold or otherwise disclosed personal information (see Section 8).
    • delete personal information we collected from you (see Section 12); or
    • opt-out of any future sale of personal information about you (see Section 12).

    We will respond to your request consistent with applicable law.

    If you are a California resident, you may obtain information about exercising your rights, as described above, by contacting us at 1-800-633-0748.

    15. DATA PROTECTION OFFICER

    Blue Sky does not have an appointed Global Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, please contact us by filling out our contact form.

    16. DISPUTE RESOLUTION OR FILING A COMPLAINT

    If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.

    17. Blue Sky corporate address

    Blue Sky’s corporate address is:

    Blue Sky Retail Solutions LLC
    16192 COASTAL HIGHWAY
    LEWES, DELAWARE 19958-9776
    Phone: (302) 645-7400 (800)-345-2677
    Fax: (302) 645-1280

    Updated: December 24, 2019