VERSION v1 DRAFT — requires Sky Vista counsel review before public publication.
SKV 360 Partners — Privacy Policy
Effective Date: {{effective_date}}
1. Who we are
SKV 360 Partners is a referral partner management platform operated by Sky Vista Consulting, LLC, a Nevada limited liability company ("Sky Vista", "we", "us"). You can reach us at privacy@skyvistaconsulting.com.
2. Information we collect
- Account information: name, email, phone, company, country, title, address.
- Tax information: W-9 / W-8BEN / W-8BEN-E forms including TIN/SSN/EIN (stored encrypted).
- Payout information: account details for ACH, Zelle, Wise, wire, or PayPal (stored encrypted).
- Lead information: data you submit about prospective clients, business card images, voice memo recordings and their transcriptions.
- Agreements: signed copies of the NDA, Referral Agreement, or Expansion Agreement, with signature image, IP address, user-agent, browser fingerprint, and timestamp.
- Usage: pages visited, referral link clicks, QR scan events (IP hashed), device type, mobile app telemetry.
- Cookies: authentication session cookies, CSRF protection, and minimal analytics.
3. How we use it
To run the referral-partner program: onboard and vet partners, track leads you refer, calculate and pay commissions, issue year-end tax forms (1099-NEC / 1042-S), prevent fraud, and maintain a legally-required audit trail of signed agreements.
4. How we protect it
We encrypt TINs, payout details, and signed-agreement artifacts at rest. Access is role-gated. We maintain an audit log of every administrative action. Files uploaded by partners are stored outside the webroot and scanned for malware before persistence.
5. Sharing
We share information only with: (a) our subprocessors — Twilio (SMS), Postmark or Mailgun (email), AWS (storage), Google Calendar (scheduling), Claude/Anthropic and OpenAI (business card OCR and voice memo transcription), Stripe (future billing); (b) our accountants, tax authorities, and legal counsel as required; (c) a successor in a merger or sale; (d) when compelled by law.
6. Your rights
Depending on your jurisdiction you may have the right to access, correct, delete, or export your personal data, and to object to processing or withdraw consent. Contact privacy@skyvistaconsulting.com to exercise any of these rights. EU/UK data subjects may lodge a complaint with their supervisory authority. California residents: see §8.
7. International transfers
Sky Vista operates in the United States. If you are outside the US, your information will be transferred to and processed in the United States. Where required, we use Standard Contractual Clauses or comparable safeguards.
8. California residents (CCPA/CPRA)
We do not "sell" personal information. We disclose the categories above for business purposes (service delivery, fraud prevention, legal compliance). You have the right to know, delete, correct, limit use of sensitive personal information, and non-discrimination.
9. Children
SKV 360 Partners is not directed to anyone under 18 and we do not knowingly collect data from minors.
10. Retention
Account and lead data: retained while your partner relationship with Sky Vista is active and for seven (7) years afterward for tax and audit purposes. Signed agreements: retained indefinitely for legal enforceability. You may request earlier deletion where no legal obligation prevents it.
11. Changes to this policy
We will post updates with a new Effective Date and notify active partners by email for material changes.
12. Contact
Sky Vista Consulting, LLC · Nevada, USA · privacy@skyvistaconsulting.com