SkyLow Ltd. (“ SkyLow", "Company" “we or "us") respects the privacy of the Users (as such terms in defined in the TOU) of its Site and Platform and is committed to protect the personal information that its Users share with it. We believe that Users have a right to know our practices regarding the information we may collect and use when Users visit and/or use our Site and/or Platform. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at ("TOU") , into which this Privacy Policy is incorporated thereto by reference.

1. Users’ Consent (PLEASE READ CAREFULLY!)

BY ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE SITE AND/OR PLATFORM, USERS AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE "PRIVACY POLICY"), INCLUDING TO THE COLLECTION AND PROCESSING OF USERS’ PERSONAL INFORMATION (AS DEFINED BELOW). IF A USER DISAGREES TO ANY TERM PROVIDED HEREIN, THE USER MAY NOT ACCESS AND/OR USE THE SITE AND/OR PLATFORM.

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.

2. Which information we may collect on our Users?

We may collect two types of data and information from our Users:

a. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering and/or using the Site and/or Platform. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Site and/or Platform, type of operating system, type of the User's device and its operating system and version, User's 'click-stream' on the Site and/or Platform, type of browser and keyboard language, the hardware specifications of such device (including screen resolution), time spent on various screens of the Site and/or Platform, User demographics, traffic patterns, etc. We may also use third-party service providers such as Google Analytics to obtain detailed analytics on the User's device and the User's behavior on the Site and/or Platform. Please note that we or our third-party service providers will collect such information by using certain technologies such as Cookies (as further detailed below).

b. The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
• Identifiers: Users of the Site and/or Platform may automatically provide their IP address (or MAC Address, as applicable) and/or advertiser identifiers (when available on a device) mainly for enhancing the User’s experience on the Site and/or Platform and for geo-location, advertising and security purposes, as further detailed below. We note that SkyLow may collect, use and provide third party advertising publishers with access to the User's advertising identifiers that may collected through the use of the Site or Platform, for the purpose of proving Users with SkyLow's and third-party vendors' targeted and behavioral advertising, all in accordance with the applicable advertising platform provider's policies.

• In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User via the Site and/or Platform:
- Personal Information is collected from the details the User provides when opening an Account and signs up to the Service, including first and last name, email address, phone number, date of birth and passport details. We may require additional information in order to complete the registration process and you may also (but are not required to) provide us with additional details.

- Personal Information is also being collected from details that Users voluntarily provide us through different activities on the Site and/or Platform, such as filling out forms on the Platform, including requests for receiving Quotes for desired destinations, requested trip dates etc.

- Any Personal Information that may be included in the Travel Agent Content and Customer's Data (as such terms are defined in the TOU), including travel dates and destinations, purchased products and services, traveling accommodations, and needs and other requests. The User represents and warrants that if the Customers' Data or Travel Agent Content uploaded to, or generated through, the Platform include Personal Information, the User has obtained the effected individuals' consent and has provided them with all information notices (as may be required under any applicable laws) in order to upload their Personal Information to the Platform.

- We will collect information relating to all searches Users perform via the Platform and any products, services, Travel Agent Content or advertisements which Users may show interest in, and we may also derive from such information additional Personal Information about the User, all in order to create a profile which includes the User's personal preferences and which shall be used in order to provide Users with targeted advertising and in order to offer Users with personalized deals, products and services which are likely to be of interest to the User.

- Personal Information may be collected as part of any communications with SkyLow, by any means, including through our social network pages, by approaching our customer services, attending SkyLow events or during sales calls (such information may include marketing and communication data that includes Users preferences in receiving marketing from us and communication preferences).

- When a User enquires about SkyLow's services via the Site and/or Platform, we will ask to provide us some or all of the following details: name, e-mail address, phone number and a free text message.

- Our Fees are charged by use certain Online Payment Processors which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information). We will not store such information on our servers. We only keep token information such Online Payment Processors provide us with, and such information is strictly secured.
c. Please note:
• We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists. For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

• We use third-party tracking services and usage logs, to track and analyze data from Users of the Site and/or Platform for purposes of security and fraud prevention. We may also use cookies to gather information regarding your use of the Site and/or Platform and the information for which you searched and accessed.

• WE WILL NOT collect any Personal Information from your engagements and interactions with Travel Agents (other than information which has been uploaded by Users or Travel Agents to the Platform).

• We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms of Use and the Privacy Policy.

3. How Do We Collect Information on Our Users?

There are two main methods we use:

a. We collect information through your entry, connection, access and/or use of the Site and/or Platform. In other words, when you are using the Service, we are aware of it and may gather, collect and store the information relating to such usage.

b. We collect information which you provide us voluntarily. For example, we collect Personal Information when a User registers and opens an Account. We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

4. What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:

• Use it for statistical and research purposes and for customization and improvement of our Site and Platform.

• Provide our third party partners and/or service providers the ability to receive aggregative and/or anonymous information, such as click stream data regarding our Users, preferences of Users, general trends on our Site and Platform and other anonymous data for analytics, statistics, advertising and/or business purposes.

• Enhance and improve the User's experience while using the Site and Platform.

• Learn about the preferences of Users and general trends on and uses of the Site and Platform. Personal Information is collected in order to:

• Provide, personalize and improve the Service for our Users.

• Improve the quality of the Service by formulating, customizing and enhancing the User's experience.

• If the User's device has an Advertising ID or other persistent identifiers, we may collect and use these for advertising, security and user analytics purposes.

• Add the User's contact details to our mailing list for the purposes of sending information about our products and services by email and through web-browser and/or push notification (for example, we may send email and push notifications regarding products that are of interest to you or general trends in the travel industry). Users have the right to opt-out of marketing messages at any time by following the instructions in such message or by contacting us at:privacy@skylow.com

• Display ads and send you offers. We may also use the User's Personal Information, including interactions with the Services in delivering cross-platform third party advertisements to the User. This may include "targeted ads" based upon the User's interactions with our Services. Please note that where required by law, we will do so only pursuant to the User's consent.

• Verify the User's identity when he/she signs into the Platform, as well as verifying User's identity for the purpose of dealing with inappropriate interactions of User and/or fraudulent use of our Service.

• Respond to the User's inquiry and to contact you for marketing and sales purposes;

• Be able to contact Users for the purpose of providing them with technical assistance and support.

• Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes, including in order to improve our Services. Please note that in general we analyze aggregate data for such purposes, rather than specific user data, however we may need to analyze a specific case to address a specific problem.

• Determine general geo-location information (i.e., country) from which the User's computer is connected to the Internet in order for us to know the general location of our Site and/or Platform's and Service's Users as well as in order to safeguard our Site and/or Platform and/or Service.

• Comply with our legal obligations and in order to be able to protect our rights and legitimate interests.

• Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.

5. Sharing Information with Third Parties

SkyLow will not share any Personal Information it collects with any third party, other than as explicitly detailed herein (e.g. sharing Personal Information between Customers' Users and Travel Agents). Notwithstanding, SkyLow may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User's support requests; (e) to respond to claims that any content available on the Service violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of SkyLow, its Users, or the general public; (h) when SkyLow is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) to collect, hold and/or manage Users’ Personal Information through SkyLow's authorized third parties service providers (including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as the User’s jurisdiction; (j) to store or process Users’ Personal Information through SkyLow's affiliated companies, which may be located in a country that does not have the same data protection laws as the User’s jurisdiction. SkyLow requires its affiliated entities to agree to processing Users’ Personal Information in compliance herewith; (k) cooperate with third parties for legitimate business purposes, including without limitation, enhancing the User's experience; and/or (l) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, SkyLow has the unrestricted right to use Non-personal Information for any purpose and to transfer and disclose Non-personal Information to third parties at its own discretion.

6. Deletion or Modification of Personal Information

If for any reason a User wishes to delete his/her Account and/or rectify his/her Personal Information, the User can send us an e-mail with adequate detail of its request to: privacy@skylow.com, and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless a User instructs us otherwise, we may retain and use the User’s Personal Information after termination of the User’s Account, for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations, to resolve disputes, to enforce our Terms and/or to enable the User to reinstate his/her Account, all as permitted under any applicable privacy laws. Please note that the laws of your local jurisdiction may provide you with certain privacy related rights, such as a right of access, right of rectification, right to erasure, right to restrict processing, right of data portability and right to object to processing of Personal Information. If you wish to exercise such rights and find that you are unable to do so via the Platform, please send us an email with adequate detail of your request to: privacy@skylow.com. Aggregate and/or anonymous information derived from a User’s Account and/or use of the Service may remain on SkyLow servers indefinitely.

7. Minors

The Site and/or Platform is intended for Users over the age of eighteen (18). Therefore, SkyLow does not intend and does not knowingly collect Personal Information from minors under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Service. If we learn that we collected Personal Information from minors under the age of eighteen (18) we will delete that information as quickly as possible. A User can contact SkyLow at privacy@skylow.com if a User has reasons to suspect that SkyLow collected Personal Information from minors under the age of eighteen (18) and we will delete that information as quickly as possible.

8. Security

We take reasonable measures to maintain the security and integrity of our Site and/or Platform and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.

9. Third Party Service Providers

While using the Site and/or Platform we may be using third party service providers, who may collect, store and/or process the information detailed herein. SkyLow uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and Personal Information. Such third-party service providers may include without limitation:

• Google Analytics, for analytics services, which privacy policy can be found at:http://www.google.com/intl/en/policies/privacy/ ; and

• AWS, for cloud hosting services, which privacy policy can be found at https://aws.amazon.com/privacy . Please read such third party service providers' terms of use and privacy policies to understand their privacy practices.

10. International Data Transfer

We may transfer information collected about Users, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from Users’ country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and as a User you consent to such transfer of information.

11. Cookies and Other Tracking Technologies

When you access or use the Site and/or Platform, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies), which store certain local information on Users’ device ("Local Storage") which may enable us, inter alia, to recognize Users’ device from those of other Users of the Site and/or Platform, to improve the Site and/or Platform's performance, to deliver a better and more personalized service according to the User's individual interests and the device or browser used, to track Users' use of the Site and/or Platform, to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Site and/or Platform and to serve targeted advertisements.

Such information is locally stored in the User's device. SkyLow and/or our authorized third-party service providers may access such information. SkyLow and/or our authorized third-party service providers may use both session cookies (which expire once you close the web-browser) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the Site and/or Platform may store non-personal information (such as the different pages viewed by a User within the Site and/or Platform) as well as User persistent identifier, which will be collected in accordance with the terms specified herein.

Most devices and browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your experience of the Site and/or Platform may be limited. Please note that unless you block the acceptance of cookies, the Site and/or Platform will utilize cookies upon your use of the Site and/or Platform. If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Site and/or Platform from placing further cookies on your device unless and until you adjust your settings as described above. For detailed instructions regarding the blocking of cookies, please refer to your browser 'help', 'tool' or 'edit' section or see http://www.allaboutcookies.org/manage-cookies/ . Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers:

Chrome

Internet Explorer and Microsoft Edge

Mozilla Firefox

Safari

It is possible to opt-out of having your browsing activity within the Site and/or Platform recorded by performance cookies. Please note that we use Google Analytics as our service providers in order to track Users' activities on the Site and/or Platform, including by use such services' persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout .

12. Direct Marketing

A User hereby agrees that we may use the User’s contact details for the purpose of informing a User of products, services and other updates and new features which may be of interest to a User, as well as for sending a User other materials to the e-mail address provided by the User in the registration process. A User may withdraw its consent via sending a written notice to SkyLow by e-mail to the following e-mail address: privacy@skylow.com or alternatively following the instructions for removing a User from the mailing list which are available in the e-mail transmitted to the User.

13. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Site and/or Platform and any information collected with respect thereto. SkyLow reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Site and/or Platform and/or we will send Users an e-mail regarding such changes to the e-mail address that the Users may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site and/or Platform or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and the User’s continued use of the Site and/or Platform after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

14. Got any Questions?

If Users have any questions (or comments) concerning this Privacy Policy, Users are most welcome to send us an email to the following address: privacy@skylow.com and we will make an effort to reply within a reasonable timeframe.