Policy Statement

This document sets forth the policy of Skyxfalcons and is designed to provide reasonable assurance that (i) a consistent process is followed with respect to the dissemination of commercial electronic messages to Skyxfalcons clients and prospective clients in Canada, and (ii) Skyxfalcons employees sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.

The Skyxfalcons Anti-Spam Policy (“ Anti-Spam Policy ”) and related procedures (the “CASL Procedures”) require that all Skyxfalcons employees sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada comply with CASL, and seeks to ensure that all CEMs sent by or on behalf of Skyxfalcons, or using a Skyxfalcons email address or using a device owned or provided by Skyxfalcons, comply with CASL.

Policy Details

The Anti-Spam Policy describes Skyxfalcons's commitments relating to the provisions of CASL and electronic messages of a commercial nature sent to Skyxfalcons clients, prospective clients, and others, as applicable. From time to time, Skyxfalcons may implement additional policies, procedures and/or practices as it relates to anti-spam measures.

ApplicationThis Policy applies to Skyxfalcons employees who may be sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada. With respect to Skyxfalcons's operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and Skyxfalcons is committed to complying with CASL. All other Skyxfalcons policies and procedures will be interpreted in a manner that is consistent with the Anti-Spam Policy and that promotes compliance with CASL to seek to deter damaging and deceptive forms of spam from occurring in Canada.

Consent Skyxfalcons obtains express, opt-in consent, unless a verifiable basis for implied consent or an exception to consent exists, before sending a CEM to anyone who has not had an existing business relationship with Skyxfalcons within two years before the date on which the CEM is sent. Unless a valid documented basis for implied consent or an exception to consent exists, Skyxfalcons also obtains express, opt-in consent for the sending of CEMs to Skyxfalcons prospects.

The request for consent cannot be in an electronic message unless there exists a basis for implied consent to send the message. The request for consent must be sought separately within a communication (e.g. through a separate action such as affirmatively checking a checkbox) and cannot be bundled as a term of acceptance of an agreement. A verbal consent is acceptable where a record of the details of the consent is maintained in a database.

Form and Content of CEMsAll CEMs are required to comply with the form and content requirements of CASL, generally described as follows:

Skyxfalcons takes steps to require that any third-party service provider who sends CEMs on behalf of Skyxfalcons complies with CASL.

Storage of Relationship DetailsA key component of complying with CASL involves maintaining records of Skyxfalcons’ relationships with clients and prospective clients.

Each business unit of Skyxfalcons is required to create and maintain in the business unit’s Client Relationship Management (CRM) system (including, but not limited to, Benchmark, and Salesforce), verifiable records documenting the relationships giving rise to implied consent, and verifiable records of express, opt-in consents obtained from Skyxfalcons clients and prospective clients. “Clients ” are defined as those organizations or individuals who have at least one open account or a contractual relationship with Skyxfalcons at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with Skyxfalcons are not considered Skyxfalcons clients for purposes of this Policy.

Implied consent or express, opt-in consent is obtained in accordance with the CASL Procedures and recorded in the applicable CRM system in order to track the client and prospect relationships.

Records of express, opt-in consent and records documenting the relationships giving rise to implied consent are retained for a minimum of three years after Skyxfalcons ceases sending CEMs to the Skyxfalcons client or prospect.

Commercial Electronic MessagesAll Skyxfalcons employees sending CEMs from and/or to a computer system(s) in Canada are required to comply with this Policy and related CASL procedures and processes.

A “CEM” is defined as an electronic message that includes content (for instance, text, hyperlinks, images or attachments) that:

a. promotes, offers, or advertises Skyxfalcons or Skyxfalcons’ products or services, or employees, or contacts;

b. solicits business for Skyxfalcons or Skyxfalcons’ employees or contacts; and

c. any other similar message that encourages participation in commercial activity.

Examples include promotional event invitations (e.g., webcasts or Skyxfalcons events), marketing newsletters, etc.

The following messages do not have to comply with the requirements applicable to CEMs:

Messages that Skyxfalcons employees email each other internally using a device that Skyxfalcons owns or provides, or using a Skyxfalcons email address, should be related to Skyxfalcons. Skyxfalcons employees may not internally email each other offers, promotions, advertisements, or referrals unrelated to Skyxfalcons business without the internal recipient’s verbal consent.

Compliance by Third PartiesAll third-party contracts with service providers who may send CEMs on behalf of Skyxfalcons must contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.

Unsubscribe MechanismCEMs that are not exempt from requirements applicable to CEMs noted above are required to include a form of unsubscribe mechanism to facilitate the withdrawal of consent or do-not-contact requests within a period of time and in a manner that would allow Skyxfalcons to process that request within 10 days of the date on which the unsubscribe, withdrawal of consent or do-not-contact request was made. This information should be maintained in the applicable database that tracks the client and prospect relationships.

All emails sent by employees will be compliant with CASL and will include the option to ‘unsubscribe.’ You can ‘unsubscribe’ from our Commercial Electronic Messages at any time by visiting

This Link

or by emailing dpo@skyxfalcons.com with ‘Unsubscribe’ in the subject line.