Privacy Policy
(Last updated: 5/12/09)
Skydebtgroup.co.uk is serious about protecting your online privacy. This Privacy Policy explains our views and practices concerning privacy, and how they may pertain to you as a user of our system.

Recitals
"You" or "Your" means you as a participant in or as a user of the Skydebtgroup.co.uk program. "We" or "Our" or "Us" means Skydebtgroup.co.uk. "Our site" means Skydebtgroup.co.uk. All information transmitted, printed or otherwise submitted to Skydebtgroup.co.uk via this website shall be deemed to be the property of Skydebtgroup.co.uk and Skydebtgroup.co.uk shall be free to use such information for any lawful purpose as detailed herein.

This site may contain links to other sites. We are not responsible for the privacy practices or the content of such sites. We reserve the right to release such information to law enforcement or other governmental officials as we, in our sole and absolute discretion, deem necessary to comply with the law.

EU Safe Harbor
The website servers that support the Website, as well as many of our operations, are located in the United States. In order to properly protect Personal Data that we receive in the United States about EU residents, we adhere to the US-EU Safe Harbor Privacy Principles with respect to the use and processing of such data in the United States (“EU Safe Harbor”). For further background about the EU Safe Harbor, please refer to the U.S. Department of Commerce’s website at http://www.export.gov/safeharbor, or contact us as described at the end of this Privacy Policy.
By providing us with your personal information on our Website or in the course of using our services, you consent to the transfer of your personal data, and any other data we acquire about you from third-party service providers in the process of evaluating you for a loan, to companies outside the EU, including Skydebtgroup.co.uk its affiliates, and authorized third parties, in accordance with this Privacy Policy.

Information / Data Collection
We automatically collect and/or track the following:
1. Web page http headers (home server domain names, IP address, type of client computer, and type of Web browser)
2. Information knowingly provided by you through on-line forms, registration forms, surveys, and/or other entries, such as email addresses, personal, financial or demographic information
3. Information, user specific or aggregate, on what pages our visitors access
4. E-mail addresses of visitors that communicate with Skydebtgroup.co.uk via e-mail.

Use of Information / Data Collected
We use your personal, demographic and profile data to enhance your experience at our site and to enable us to present content we think you might be interested in. We use your contact information to send you information about our company and promotional material from our partners. We may also use your personal, demographic and profile data to improve our site, for statistical analysis, for marketing and promotional purposes, and for editorial or feedback purposes for our advertisers. Information collected by us may be added to our databases and used for future telemarketing, SMS text-messaging, e-mails or postal mailings regarding site updates, new products and services, upco.uking events, and/or status of orders placed online. By using this site, you agree that you may be contacted in any manner contemplated in this section even if your number is found on a do not call registry, in-house list or similar registry Information collected by us may be added to our databases and used for future e-mails or postal mailings regarding site updates, new products and services, upcoming events, and/or status of orders placed online.

Data obtained from you in connection with this SMS service may include your name, address, cell phone number, your provider's name, and the date, time, and content of your messages.  In addition to any fee of which you are notified, your provider's standard messaging rates apply to our confirmation and all subsequent SMS correspondence.  All charges are billed by and payable to your mobile service provider.  We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator.  SMS message services are provided on an AS IS basis.

We may use personal information to provide the services you've requested, including services that display customized content and advertising.  We may also use personal information for auditing, research and analysis to operate and improve our technologies and services.  We may share aggregated and non personal information with third parties. When we use third parties to assist us in processing your personal information, we require that they comply with our Privacy Policy and any other appropriate confidentiality and security measures.  We may also share information with third parties in limited circumstances, including when complying with legal process, preventing fraud or imminent harm, and ensuring the security of our network and services.

Third-party Data / Information Disclosure
If you choose to provide personal information, it will be used for the following purposes:
1. Consideration of your application for a Skydebtgroup.co.uk account as required by law; and
2. For marketing products and services which we determine, in our sole judgment, that you might find of interest. We reserve the right to share, rent, sell, or otherwise disclose data we collect to third parties. Any third party we share, rent, sell, or otherwise disclose data to will be carefully prescreened by us, determined by us to be reputable, and will use the personal data for marketing products and services which we determine, in our sole judgment, that you might find of interest.

Your Opt-Out Rights
You may opt-out of receiving communications from us and or our partners by not submitting your information. We also allow you to remove your information from our marketing lists. If you remove your information from our marketing lists it will no longer be used by us to send promotional correspondence to you. You can remove your information by sending your request in writing via email to privacy@ciwol.co.uk or by sending  "STOP", "END", "QUIT" to the SMS text message you have received.

We Do Not Intend to Collect Data from Children
The information and services provided to us or our affiliates, sponsors, and advertisers are not intended to be viewed by children (under 18 years old). No information collected from children is knowingly used for any marketing or promotional purposes whatsoever, either inside or outside Skydebtgroup.co.uk, nor is any part of Skydebtgroup.co.uk web site is designed to attract anyone under the age of 18. Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.

Our Right to Contact You
We reserve the right to contact you regarding your account status and changes to subscriber agreements, privacy policy, or any other policies or agreements relevant to you.

Our Right to Change our Privacy Policy
We reserve the right to change this policy at any time by notifying you of the existence and location of the new or revised privacy policy or by posting the changes online at our site.

Anti Spam Policy / Compliance with Can-Spam Act
Skydebtgroup.co.uk is dedicated to ensuring compliance with the 'Can-Spam Act', which took effect January 1, 2004. You may receive email from Skydebtgroup.co.uk in the following circumstances:
1. Acknowledging your application has been received and requesting additional action
2. Requests for additional information to support your current application
3. Response to your inquiries regarding transactional requests
4. Thanking you for your valued business
5. Advertisements for our products, services, changes in services, new product availability
6. Advertisements for third party products and services where we have determined that such product or service may be of interest to our customers
To ensure compliance with the Can-Spam Act, Skydebtgroup.co.uk has implemented the following guidelines for email delivery:
1. The Subject Line of any email you receive will always accurately describe the subject matter of the email.
2. Any email from Skydebtgroup.co.uk will include the ability to unsubscribe from future email messages.
3. Unsubscribing will ensure the customer is removed from ALL lists at Skydebtgroup.co.uk; this excludes customer service emails regarding the processing and status of a current loan application.
4. Advertising emails from Skydebtgroup.co.uk will include information that the email is an advertisement, either in the body or footer of the email.
5. All emails sent to you directly by Skydebtgroup.co.uk include valid postal address information in the footer.
6. All third party marketing partners are required to comply with the Can-Spam Act.
7. Emails sent to you directly by Skydebtgroup.co.uk will include an email address and physical address where you can send suggestions, complaints or other correspondence.

The Use of Cookies
Cookies are pieces of information that are stored on a user’s computer when the user accesses a Web site. Cookies do not collect personal identifying information about the user. There are two types of cookies that may be used at the Skydebtgroup.co.uk website: a persistent cookie and a session cookie. A persistent cookie gets entered by your Web browser into the “Cookie” folder on your computer and remains in this “Cookie” folder after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site.

A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut off your computer. The Skydebtgroup.co.uk website may also use Web beacons (also called “clear GIFs” or “pixel tags”) in conjunction with cookies. Web beacons are small strings of code that are placed in a Web page. Because a Web beacon is only 1 pixel high by 1 pixel wide, it appears invisible on your computer screen.

If all or part of the company is sold, merged or otherwise transferred to another entity, the information that you have provided at this site may be transferred as part of that transaction. However, Skydebtgroup.co.uk will take reasonable steps to assure that such information is used in a manner consistent with the Skydebtgroup.co.uk privacy policy under which it was collected.

Additional Information
Website: Skydebtgroup.co.uk
Email Address: privacy@ciwol.co.uk
Skydebtgroup.co.uk understands consumers' concerns over the use of their personal information. We hope this information will relieve any concerns your company may have regarding our email policies.
Skydebtgroup.co.uk and its affiliated sites use only an "opt-in or opt out" method of obtaining customer information, and it is not our policy to send unsolicited email. We obtain email addresses and personal information from third parties that follow the same set of policies.
From time to time, Skydebtgroup.co.uk will enter into an arrangement with a third party website to allow individuals to opt into our marketing program on those third party websites. In each case the third party websites have represented and warranted to us, among other things,
1. that the data was collected voluntarily from individuals on website registrations and co-registrations
2. that the sellers have a right, under any applicable privacy statements, to transfer the data to us
3. that Skydebtgroup.co.uk has the right to send marketing offers to the individuals.

We hope this information satisfies any questions or concerns you may have regarding the email practices of Skydebtgroup.co.uk. If you have additional questions or wish to discuss this matter further, please contact us at privacy@ciwol.co.uk

Conditions of Use and Revisions
If you choose to visit the Skydebtgroup.co.uk your visit and any dispute over privacy is subject to this Privacy Policy. We reserve the right to change this Privacy Policy at any time by notifying you of the existence and location of the new or revised privacy policy or by posting the changes online at our Website.

If you have any concern about privacy or have any questions or comments, please send them to:

DirectROI LTD
Gainsborough House
81 Oxford Street
London, W1D 2EU
Fax: +44 (0) 207 9035333