Privacy Policy

Midway Sky Privacy Policy

Effective date: January 1, 2015

• Introduction
• About this Privacy Policy
• Personal Information we may collect and use
• When we may share personal information
• Children
• Security
• Email preferences
• Your rights
• Contacting us

Introduction

Midway Sky Ltd and its affiliates (“DigiDesk”) and (“CSAT”) are committed to protecting the privacy of all individuals who:

visit the DigiDesk website located at mws-digidesk.com and CSAT website located as mws-csat.com, which includes all subdomains, present and future (the “Website”);

use the applications that DigiDesk and CSAT make available from time to time (the “Applications”); and

use the services including DigiDesk and CSAT platforms, wall boards and other products and services (the “Platforms”).

To make this policy easier to read, we call the Website, the Applications and the Platforms together the “Services”.

It is Midwak Sky’s policy to respect your privacy and the privacy of all users of the Services. This Privacy Policy has been established to help you understand our commitment to protecting your privacy and personal data, and the steps we take to ensure it. By visiting and/or using any of the Services, you agree to be bound by the terms of the present Privacy Policy (the “Privacy Policy”). Where the present Privacy Policy refers to “DigiDesk” or “CSAT”, it may refer to the Services or to Midway Sky Ltd, depending on the context.

Midway Sky reserves the right, at any time, to modify or replace the Privacy Policy. The most recent version of the Privacy Policy is available at midwaysky.com/privacy-policy. Please check the Privacy Policy periodically for changes, though we will also notify you via email or other direct electronic communication method of any changes that, in our sole discretion, materially impact your use of the Services or the treatment of your Personal Information. Your use of the Services following the posting of any changes to the Privacy Policy constitutes acceptance of those changes.

About this Privacy Policy

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) and other non-identifiable information gathered by DigiDesk and CSAT when you are using or accessing the Services.

This Privacy Policy does not apply to the practices of any third-party services such as Facebook or Twitter that you elect to access through the Platforms (the “Supported Platforms”) or to any applications developed by third parties that DigiDesk or CSAT does not own or control (“Third-Party Apps”) or to any third parties who use the DigiDesk or CSAT Application Programming Interface (API) to perform any function related to the Platforms. As an example, the Privacy Policy does not cover any information or other content you can view via the Services on Supported Platforms (but which was not posted there using the Services) or information you provide to Third-Party Apps accessed via the Services. While we attempt to facilitate access only to those Supported Platforms and Third-Party Apps that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of any Supported Platforms or Third-Party Apps. We encourage you to carefully review the privacy policies of any Supported Platforms or Third-Party Apps you access via the Services.

Personal information we may collect and use

i) Registration and Logged-in Users

When you first register for a DigiDesk or CSAT account we collect some personal information about you such as:

• your full name, username, and email address
• your password, in connection with your account and your log-in facility
• the geographic area where you use your computer and mobile devices
• a unique DigiDesk or CSAT user ID (an alphanumeric string) which is assigned to you upon registration
• other optional information as part of your account profile

When creating a DigiDesk or CSAT account, we may also collect your credit card or PayPal information, billing address, and such other information as is required to complete a commercial transaction on our site.

As a registered user of DigiDesk or CSAT, we may also collect the following:

• information you post in the form of messages, conversations, or contributions to discussions exchanged over the Supported Platforms
• images or other files that you may publish via our publishing services
• information we may receive relating to communications you send us, such as queries or comments concerning our services
• information relating to your real time location, but only where you enable your computer or mobile device to send us location information or when posting through the Supported Platforms

DigiDesk and CSAT use the collected information for the following general purposes:

• to identify you when you log in to your account
• to enable us to provide the Services to you
• to verify transactions you make and for billing, security, and authentication (including security tokens for communication with installed Third-Party Apps)
• to analyze the Website , Services and our visitors, including research into our user demographics and user behaviour in order to improve our content and Services
• to contact you about your account and provide support
• to share aggregate (non-identifiable) statistics about users of our Services to prospective advertisers and partners
• to keep you informed of information about our Services we think you may find useful or which you have requested from us, provided you have indicated you would like to be contacted for these purposes

By submitting information to DigiDesk and CSAT when registering, you consent to the use of your information for these purposes.

When we may share Personal Information:

Except as provided in the next paragraphs and elsewhere in this Privacy Policy, Midway Sky does not divulge any Personal Information gathered via the Services to third parties.

Notwithstanding anything in the Privacy Policy to the contrary, we may share any information we have collected about you or that you have submitted:

(1) when you explicitly consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing;

(2) where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands;

(3) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;

(4) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Services generally);

(5) to a parent company, subsidiaries, joint ventures, or other companies under common control with Midway Sky;

(6) if we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this Privacy Policy or inform you that you are covered by a new privacy policy); and

(7) if this information is not private, is aggregated or is otherwise non-personal information, such as your public user profile information and related public data (such as Tweets, likes, etc.) or the number of users who clicked on a particular link (even if only one did so).

Subject to confidentiality obligations consistent with this Privacy Policy, we may also disclose information to our affiliates, agents, contractors, and service providers in order to facilitate the functioning of the Services or to perform tasks that are integral to the Services, such as processing transactions, fulfilling requests for information, or providing support services or other tasks, from time to time. Information may also be transferred from DigiDesk or CSAT to the third parties in control of the Supported Platforms, but only to the extent required in order for the Services to function properly.

Children

Protecting the safety of children when they use the Internet is very important to us. Our Services should only be accessed by individuals of Minimum Age. “Minimum Age” may mean different ages in different countries, depending on where the individual accesses the services. For reference, “Minimum Age” shall mean (a) 14 years old for the United States, Canada, Germany, Spain, Australia, and South Korea; and (b) 13 years old for all other countries. However, if applicable law requires that you must be older than such ages in order for DigiDesk or CSAT to lawfully provide the Services to you (including the collection, storage, and use of your information in accordance with this Privacy Policy), then the Minimum Age would be such older age. The Services are not designed nor intended for use by children or anyone else under the age of 13.

Security

We use industry best practices to keep any information collected and/or transmitted to the Supported Platforms or Third-Party Apps secure. This includes the use of HTTPS with TLS (Transport Layer Security), which encrypts all transmitted data, and OAuth 2.0 protocols for authentication and data transfer to Supported Platforms and Third-Party Apps.

Certain Personal Information, most notably DigiDesk and CSAT log-in details, is encrypted during transmission using TLS. Once validated within our system, passwords are deleted from our system. In addition, DigiDesk and CSAT use third-party vendors and hosting partners such as Amazon to provide the necessary hardware, software, networking, storage, and related technology required to run the Services. These vendors have been selected for their high standards of both physical and technological security, including ISO and SSAE16 certifications.

When payments are processed via credit card, MidwaySky uses third-party vendors that are PCI-DSS Compliant. At no point does Midway Sky have access to your credit card information.

You should bear in mind that submission of information over the Internet is never entirely secure. We cannot guarantee the security of information you submit via the Services whilst it is in transit over the Internet and any such submission is at your own risk, and this risk is specifically disclaimed in our Terms.

If you are a Logged-in User, it is advisable that you log out of your account at the end of every session and not leave a logged-in account unattended for any period of time, particularly if you use a shared computer or device.

Email preferences

Midway Sky uses email as the primary mode of communications with our users. We want to respect your privacy by only sending emails of interest to you. You can manage your email preferences, such as opting-out or unsubscribing from emails sent by Midway Sky, by clicking on the unsubscribe link provided in each email correspondence that we send you.

Your rights

You can contact us to obtain a copy of the Personal Information held about you by us. This may be subject to a fee not exceeding any prescribed fee permitted by applicable law. You can also ask us to correct and, where relevant, erase that information. Please note that certain Personal Information may need to be retained by Midway Sky for a period of time following cancellation of your account where this is necessary for our legitimate business purposes or required by applicable law. As mentioned above you have a right to change your email preferences at any time.

You should be aware that DigiDesk and CSAT act as a conduit between our users and the various Supported Platforms and Third-Party Apps. In several instances, the content published via DigiDesk will not be in DigiDesk’s custody or control, and any content that has been shared by you through any Supported Platform or Third-Party Apps via the Services may continue to be available to third parties and the public at large, as this content is now under the control of the operators of the Supported Platforms and/or the Third-Party Apps.

Contacting us

If you have any questions about this Privacy Policy, please contact:

Midway Sky Ltd
145-157 St. Johns Street
London
EC1V 4PW
United Kingdom

© 2015 Midway Sky LTD. All rights reserved