Privacy Policy

We process your Personal Information based on:

• Your provision of consent (where applicable),
• Your contract with us,
• exceptions to the consent requirement as outlined in the law; or
• in line with legal or regulatory requirements or guidance.

We collect Personal Information necessary to provide information, products, or services of your choice. With limited exceptions, we collect your Personal Information directly from you through our website, emails, phone, fax, physical forms, internal systems, marketing campaigns or lists, etcetera. From time to time, we utilize publicly accessible information where necessary to verify information provided by you.

When you disclose to us the Personal Information of another person for use in connection with our products or services, for example, a beneficiary or a family contact, you must be authorized to entrust that Personal Information to us.

We process your Personal Information for the following purposes and, where applicable, for secondary purposes that are compatible (meaning reasonable, necessary, and proportionate) with the ones listed below:

• Assessing and closing commercial transactions, such as the acquisition and disposition of assets.
• Initiating, establishing, and managing a business relationship and the termination of the relationship.
• Managing our portfolio, which includes solar assets, leases, and biogas facilities.
• Managing service providers, partners, and relevant agreements.
• Managing payments.
• Overseeing our debt collection processes.
• Conducting marketing activities.
• Overseeing compliance with legal and regulatory obligations on an ongoing basis.
• Assisting Skyline entities with their sustainability initiatives, for example, by installing and monitoring solar panels and EV chargers.
• Additionally, we process your Personal Information for business purposes like record-keeping, crisis management, data governance, analyses of our products and services, risk analysis, and for conducting data analytics in general, as well as in connection to the oversight and management of the security and resilience of our networks, systems, and physical premises.

In line with the Processing of your Personal Information for the purposes listed above, we conduct different sets of tasks (“Processing Activities”) that are required to provide you information, products, and services. Those Processing Activities dictate the Personal Information we collect, use, and disclose.

The following table highlights some of our Processing Activities and the categories of Personal Information we process or may process (depending on the context) pursuant to each Activity.

Note that Processing Activities and Personal Information collected, used, and disclosed may change occasionally.

TRANSACTION MANAGEMENT

Personal Information is disclosed for the assessment of the relevant asset, facility or entity. This may include Personal Information of employees, such as their employment agreements, employee history and payment records, government-issued IDs of company executives, and Personal Information contained in rent rolls, if any. Furthermore, we process Personal Information required to conduct additional due diligence processes such as credit checks or reviews of insurance, credit information and/or credit information of guarantors.

ASSET & FACILITY MANAGEMENT

• Personal Information provided by vendors acting as sole proprietors.
• Personal Information of landlords, partners, shareholders, and related parties, in connection with the administration of the relevant contract and any service requests including, for example, tax filing information and ethnicity information.

Other Information of Relevance

• The Processing Activities identified above require communication and sharing of Personal Information within the Skyline Group of Companies. For example, the financial component of your business relationship with us requires sharing Personal Information with Skyline Group of Companies’ finance department.

• PROFILING: Profiling means the collection and use of Personal Information to assess specific characteristics of an individual, in particular to analyze that person’s work performance, economic situation, health, personal preferences, interests, or behavior.

  If you are an investor or potential investor, we use your Personal Information through Skyline Wealth to understand your marketing preferences and document your investor profile. Compliance with some legal or regulatory requirements may result in you being profiled; that is the case when complying with Anti-Money Laundering and Know Your Client requirements, where we build your profile with information obtained from trusted sources to establish whether a business relationship or specific transaction should proceed. Note that we do not automate the profiling of individuals; there is significant human oversight of this process.

  For clarity, your profile is created with information you share regarding your risk appetite and additional investment details. This is required for us to understand your needs and ensure that the product or service we offer aligns with your risk preferences.

• TRACKING:
  We track the lifecycle of our relationship with you in our database. We also track your user activity to enable our systems to recognize your browser or device and to provide, market, and improve our offerings. To this end, we and our service providers use cookies and similar technologies (pixels and beacons). To learn about cookies, visit https://allaboutcookies.org/.

• Service Providers: We use service providers for different purposes. We require them to abide by applicable legislation and implement security controls to safeguard your Personal Information. Some of the categories of service providers and partners with whom we may share your Personal Information include the IESO, government institutions, financial institutions, debt collection agencies, marketing management, advertising partners, as well as technology vendors, analytics providers, credit bureaus, consultants, auditors, and record-keeping providers.

  In addition to service providers, you have relationships with third parties with whom we need to exchange your Personal Information for processing transactions. Moreover, where you express interest, we will connect you to our partners for the provision of additional products or services, in which case disclosure of Personal Information will be required.

• Other Companies within the Group: If we determine that Processing of Personal Information by another entity within the Skyline Group of Companies would allow us to provide the service or product in a way that guarantees a better user experience for you, or where the expertise required to deliver you products or services lies with another entity within Skyline Group of Companies, we will grant them limited access, on a need-to-know basis, to the Personal Information they require to do so.
• Government Bodies or Authorities, Courts, Police, and Compliance with Legal or Regulatory Obligations: Where required to disclose information per legal or regulatory requirements; asked to comply with an order or similar request, or to collaborate on matters subject to investigation, we will disclose your Personal Information to the extent permitted by law or, where available, in line with applicable case law (like court, tribunal, board, or commission decisions) when no law regulates the order or request. In addition, we will disclose your Personal Information when necessary to comply with legal or regulatory obligations.
• Access Requests by Third Parties: In some cases, third parties submit requests for access to Personal Information which are processed in accordance with parameters provided by the law.