Privacy Policy

(Effective Date: 11 March 2025)

If you access the Skyark Universe Limited (SAU) Services in any way, or have registered a SAU Account, you will be deemed to use and be a user of the SAU Services. SAU will collect the Personal Data of all users of the SAU Services, but will do so in compliance with the BDPA. This policy highlights the key information pertaining to what we collect when you use SAU Services. It also highlights the key information about how we store, use, share, transfer, and delete that information. It further includes information about how you may manage that information. For full details of how your Personal Data will be collected and processed by SAU from the SAU Services, please refer to the BDPA definition.
In general, the Personal Data which is collected from you shall be processed in compliance with the BDPA. We share your data with our Data Intermediaries or other third-party service providers used by us to the extent necessary for them to provide their services.

Unless the context otherwise requires, the definitions and interpretative provisions in Schedule1 apply throughout this Privacy Policy.

INFORMATION WE COLLECT
1. When you use the SAU Services, and as you continue to use the SAU Services, we may collect certain types of information from you, including but not limited to the following:
  1. full name;
  2. Service address;
  3. email;
  4. telephone number;
  5. geographical location;
  6. device identifiers;
  7. profile picture;
  8. your network usage data or other information gathered automatically by our systems, including computer IP address, links visited, and other activities conducted online;
  9. information about how you use the SAU Services; and
  10. other information which you may provide to SAU from time to time.
2. If you provide us with any Personal Data relating to a third party, by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes set out in this Privacy Policy.
3. You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our ability to provide you with the SAU Services you have requested.
COOKIES AND WEB BROWSER INFORMATION
1. When you visit the SAU Services, we send one or more cookies to your computer and other devices. The information obtained from such cookies may be used by us for storing user preferences and to enable SAU or third-party advertising partners (including Google and Facebook) to display targeted advertisements which may be of interest to you.
2. We also collect information which is sent to us by your web browser. When you browse the SAU Services, we automatically receive your computer’s IP address which provides us with information that helps us learn about your browser and operating system, such as the name of your operating system and the name and version of your browser.
3. Other information we may collect include the address of the web page you were visiting when you accessed the SAU Services and the date and time of your visit. The type of information we collect depends on the settings on your web browser.
PURPOSE OF PROCESSING
1. We use this information to:
  1. provide the SAU Services and its features to you, including:
    1. ensuring the contents of the SAU Services are presented in the best way for you and your computer (or mobile device);
    2. providing you with information about products or services that you request for or which we consider may be of interest to you;
    3. allowing you to use various features of the SAU Services;
    4. measuring and improving the SAU Services and its features;
  2. provide you with customer support;
  3. provide you with service-related announcements;
  4. prevent potentially illegal activities;
  5. enforce our T&Cs;
  6. generate aggregate, non-identifying information about how people use the SAU Services;
  7. for any other purpose for which SAU has specifically obtained your consent;
  8. provide, test, improve, promote and personalize the SAU Services;
  9. fight spam and other forms of abuse;
  10. comply with any applicable rules, laws, regulations, code of practice guidelines, issued by any legal or regulatory bodies which are binding on SAU (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, and conducting audit checks, due diligence, and investigations); and
  11. for any other purposes which are reasonably related to any of the above purposes, or for any other purpose which we may notify you at the time of obtaining your consent.
2. If you have registered a SAU Account, we collect, use, and disclose your Personal Data for the following purposes:
  1. establishing or providing you with the SAU Services you subscribe to (including but not limited to booking processing, rescheduling, and cancelation, assignment of housekeeper, and service delivery);
  2. facilitating the continuation or termination of your subscription to the SAU Services;
  3. facilitation the daily operation of the SAU Services (including but not limited to billing, customer service, customer verification, technical support, SAU Platform maintenance and troubleshooting);
  4. facilitating third party services if obtained, administered, or processed through us;
  5. processing of payment instructions, GIRO, direct debit facilities and/or credit facilities requested by you;
  6. enforcement of repayment obligations (including but not limited to debt collection, filing of claims, retrieval of payments from losses made by our service partners);
  7. credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
  8. generating internal reports (including but not limited to annual, operational and management reports);
  9. administering fee adjustments, refunds and waivers;
  10. notifying you of your entitlements under any subscription programmes with us;
  11. analysing your use of the SAU Services so as to help us improve, review, develop and efficiently manage the SAU Services offered to you; and
  12. purposes which are reasonably related to any of the above purposes, or for any other purpose which we may notify you at the time of obtaining your consent.
USE OF INFORMATION FOR MARKETING PURPOSES
1. SAU will send you marketing communications by email if they relate to goods and services similar to those you have expressed an interest in and if you have consented to us contacting you in this manner.
2. You have the right to unsubscribe to the marketing communications by clicking the corresponding link featured in each marketing communication email sent to you.
3. You have the right to request that SAU does not use the Personal Data collected for marketing purposes or refrain from transferring the data to third parties for marketing purposes, by notifying SAU of the same via contact@skyarkuniverse.com
POTENTIAL CONSEQUENCES OF PROCESSING
1. By subscribing to SAU Services, you may make available to the public certain Personal Data through interactions on the SAU Platforms.
2. Where such Personal Data may reveal special category protected data, it is processed on the basis that you have manifestly made it public.
3. If you do not agree with and accept the risk of such use of your Personal Data, you will not be permitted to register for a SAU Account and to use the SAU Services.
OBJECTIONS TO USE OF PERSONAL DATA
1. You may at any time object to the use of your Personal Data by notifying SAU of the same via contact@skyarkuniverse.com Your subscription will be suspended in the meantime whilst investigations are underway for any alleged misuse of your Personal Data.
TRANSFER OF PERSONAL DATA ACROSS BORDERS
1. The SAU Services are hosted in Singapore, through Amazon Web Services’ Cloud servers which are virtual and can be accessed globally across Amazon Web Services’ global cloud availability zones. You hereby authorise the transfer, storage, and use of your Personal Data in the Amazon Web Services Cloud servers and across the respective Amazon Web Services’ global cloud availability zones to the extent that is allowed by the BDPA.
MODIFICATION OF PERSONAL DATA
1. You may at any time access and modify your Personal Data through the SAU Platforms or by contacting us at contact@skyarkuniverse.com. It is your responsibility to ensure that the information therein is accurate and kept up-to-date at all times.
EXPORTING OF PERSONAL DATA
1. You may at any time request to export your Personal Data by requesting the same through contact@skyarkuniverse.com.
DELETION OF PERSONAL DATA
1. You may at any time delete your Personal Data by requesting the same through contact@skyarkuniverse.com. SAU will notify you of the acceptance/confirmation of such deletion. Your subscription will be considered terminated once your Personal Data is deleted. All your Personal Data will be deleted from our systems as soon as reasonably practicable after the date of notice of confirmation of deletion, save as to aggregated data and to the extent required to facilitate compliance with global industry standards of data retention.
RETENTION AND CROSS-BORDER TRANSFER OF PERSONAL DATA
1. SAU retains Personal Data associated with you for the entire duration which you remain a SAU User, and your consent is not withdrawn. In the event that your Personal Data is deleted, or consent is withdrawn, SAU will only retain your Personal Data to the extent required by law and to the extent permitted by the BDPA (save as to aggregated data).
2. We may need to transfer personal information to other countries with different data protection laws, in order to provide you with our products or services, unless it’s restricted by applicable law. Keep in mind, no matter where we process personal information about you, we’ll always protect it in the manner described in the Data Protection and Privacy Principles, this Statement, and in accordance with applicable laws.
DISCLOSURE
1. We may disclose your Personal Data if we are required by law to do so or if it is necessary to facilitate any investigation for breach of our T&Cs or to enforce our rights under the T&Cs.
2. By using the SAU Services, subject to the provisions of the BDPA, SAU may share your Personal Data:
  1. with parties whom you have consented for SAU to share such information;
  2. with SAU ’s partners, affiliates or subsidiaries;
  3. in the event of a sale, transfer of ownership of the shares or assets of SAU, merger or other similar transaction;
  4. where we provide services jointly with other companies or Data Intermediaries;
  5. to give search engines access to publicly available information; and
  6. as otherwise set forth in this Privacy Policy.
3. Information about you may also be shared where you have made that information public by uploading it on or to the public areas of SAU Platforms.
DATA INTERMEDIARIES AND THIRD PARTY SERVICE PROVIDERS
1. In general, the Data Intermediaries or other third-party service providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
2. This Includes the following categories of recipients:
  1. hosting, storage, and other infrastructure;
  2. security;
  3. analytics;
  4. network providers and partners; and
  5. communication and support.
3. However, when you click on links available on the SAU Services, they may redirect you away from the SAU Services. Once you exit the SAU Services or are redirected to a third-party website or application, you may be subject to their equivalent of a privacy policy and terms of use.
4. Further, the SAU Platforms may integrate with third-party systems including but not limited to payment gateways and digital token wallets. These third-party systems are embedded into SAU Platforms and send data to the host site as if you were visiting the host side directly (i.e. you will be subject to their respective privacy policy and terms of use). SAU does not control the data collected by these third-party systems. Any queries you may have regarding their privacy policies and terms of use may be addressed to them directly.
5. We are not responsible for the privacy practices of these Data Intermediaries/service providers and encourage you to read their privacy policies in order to understand the manner in which your personal information will be handled by these providers.
6. In particular, please note that certain providers may be located in or have facilities that are located in a different jurisdiction. Thus, if you elect to proceed with a transaction that involves the services of a third-party service provider, your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
CONSENT
1. SAU collects and stores your Personal Data only on the legal basis set out in the BDPA. Consent is obtained when you provide us with Personal Data to register your subscription and consciously tick the box to agree to this Privacy Policy.
2. If we wish to use your Personal Data for a purpose other than as set out in this Privacy Policy, we will ask you for your express consent.
AGE OF CONSENT
1. SAU does not knowingly provide access to the SAU Services to anyone under the Age of Majority or collect any Personal Data in relation to any such person.
2. By using the SAU Services, you represent that you are at least the Age of Majority in your country/state/province of residence, where applicable.
WITHDRAWAL OF CONSENT
1. You may withdraw consent by requesting the same through email. SAU will notify you of the acceptance/confirmation of withdrawal of your consent. Your Personal Data will be erased within 10 Business Days from the date of notice of confirmation of withdrawal of consent, save as to where it is aggregated and anonymised, and except to the extent that SAU is prevented from doing so by law.
SECURITY
1. To protect your Personal Data, we take reasonable precautions and follow industry practices to ensure that such information is not lost, misused, accessed by unauthorised persons, disclosed, altered or destroyed.
2. Nonetheless, you should be aware that transmission of information via the internet is not entirely secure and SAU cannot guarantee the security of any data transmitted to our SAU Services via the internet.
3. You should take steps to keep your data secure by protecting your credentials for your subscription and any other account which is accessed through the SAU Services.
4. In the event that there is a data breach, SAU shall notify you within 72 hours with a relevant breach notification.
CHANGES TO POLICY
1. AU reserves the right to modify this Policy at any time to ensure that it is consistent with its business development or changes in applicable legal or regulatory requirements. Changes and clarifications will take effect immediately upon their publication on the SAU Services. We will notify you about significant changes to our Privacy Policy. Should you no longer agree to this Privacy Policy, you can opt out of any such changes to our Privacy Policy by unsubscribing to SAU Services and withdrawing your consent as set out above in Clause 16.
GOVERNING LAW
1. This privacy policy forms part of the T&Cs of the SAU Services and shall be governed and construed in accordance with laws of the British Virgin Islands. Any dispute arising out of or in connection with this privacy policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved exclusively by the courts of the British Virgin Islands.
CONTACT INFORMATION
1. If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, please contact our Data Protection Officer at contact@skyarkuniverse.com.

DEFINITIONS AND INTERPRETATION

1. Definitions
In this Privacy Policy, unless the context otherwise requires, the following words and expressions shall have the following meanings:

“Age of Majority” means 21 years old, as stipulated in the BDPA, or such age as stipulated by the requisite law in order for SAU to lawfully collect Personal Data from the individual without parental consent.

“Data Intermediaries” means third party service providers engaged by SAU to manage or process its data, including Personal Data.

“IP address” means internet protocol address.

“BDPA” means the the British Virgin Islands Data Protection Act, 2021, as may be amended from time to time.

“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;”

“SAU Services” means the SAU website (www.skyarkuniverse.com) including any content, functionality, services, and products, offered on and through the SAU Platforms.

“SAU User” means an individual who uses the SAU Services, including but not limited to, accessing the SAU Platforms, or creating a SAU Account.

Unless otherwise defined in this Privacy Policy, all capitalized terms shall have the meanings ascribed to them in the T&Cs at https://www.skyarkuniverse.com/terms-conditions/.

INFORMATION WE COLLECT

COOKIES AND WEB BROWSER INFORMATION

PURPOSE OF PROCESSING

USE OF INFORMATION FOR MARKETING PURPOSES

POTENTIAL CONSEQUENCES OF PROCESSING

OBJECTIONS TO USE OF PERSONAL DATA

TRANSFER OF PERSONAL DATA ACROSS BORDERS

MODIFICATION OF PERSONAL DATA

EXPORTING OF PERSONAL DATA

DELETION OF PERSONAL DATA

RETENTION AND CROSS-BORDER TRANSFER OF PERSONAL DATA

DISCLOSURE

DATA INTERMEDIARIES AND THIRD PARTY SERVICE PROVIDERS

CONSENT

AGE OF CONSENT

WITHDRAWAL OF CONSENT

SECURITY

CHANGES TO POLICY

GOVERNING LAW

CONTACT INFORMATION

DEFINITIONS AND INTERPRETATION