PRIVACY POLICY

SKILLR, Inc. (“SKILLR”) cares about the security and privacy of the personal data that is entrusted to us. Your access to, and use of the Platform which include this web site (www.skillr.com) and the information, products and services that we provide to you and other users through this web site, as well as any mobile applications (“SKILLR App(s)”) provided by us in connection with our products and services (collectively, the “Platform”) is subject to the Platform Terms of Service and this Privacy Policy.

SKILLR has created this Privacy Policy to explain what information we gather from you when you use the Platform, how we may use this information, the security approaches we use to protect your information, and how you can access and request modification of certain information that we may store about you. This Privacy Policy is incorporated and made part of the Platform Terms of Service.

IF YOU ARE UNDER 18 YEARS OF AGE, PLEASE BE SURE TO READ THIS PRIVACY POLICY WITH YOUR PARENTS OR GUARDIAN AND ASK QUESTIONS ABOUT THINGS YOU DO NOT UNDERSTAND.

Acceptance of This Privacy Policy and Changes to It

By accessing, viewing or otherwise using the Platform, you consent to the collection and use of your information by SKILLR in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you may not use any Platform. SKILLR reserves the right to change, modify, add or remove portions of this Privacy Policy at any time, without prior notice. Changes take effect on the date that change appears on the revised Privacy Policy. If you use any Platform following a change in this Privacy Policy, your use will be understood to signal that you accept and agree to be bound by the changes. Accordingly, we urge you to review this Privacy Policy frequently for changes.

Information We Collect

We collect personally identifiable information (“Personal Information”) and other non-individually identifiable information from you when you register for the Platform, respond to communication such as e-mail, or otherwise use the Platform in any manner. To participate in certain features of the Platform, you will be required to provide certain Personal Information. For example, when registering as a user on any Platform, we may ask you for your name, e-mail address, birth date, mailing address, zip code, phone number, credit card information or other Personal Information. You may, however, visit portions of the Platform without providing any Personal Information. We may collect and use mobile device identifiers, IP addresses and Session identifiers to analyze trends, to administer the Platform, to track user activities, to infer user interests, and to otherwise induce, deduce, and gather information about individual users and market segments.

Like many web sites and certain mobile apps, we use and may allow third party service providers to use “cookies”, flash cookies, local shared objects, web beacons, pixels, single pixel GIFs, clear GIFs, and/or other tracking technologies to enhance your experience and gather information about visitors and visits to the Platform, including how you use the Platform (“Usage Data”). Please refer to the “Use of ‘Cookies’” section below for information about cookies and how we use them.

We may also collect transactional information, customer services information, or any other legally permissible information.

We may also collect and store certain other personally non-identifiable information. This information is collected passively using various technologies and cannot presently be used to specifically identify you.

Your information may be supplemented with additional information from other companies such as publicly available information, information about households and other information that we may append or match to your information.

Our Use of Your Information

We may use the Personal Information and other data we collect from you when you register, purchase services, respond to a survey or marketing communication, access or view the Platform, or use certain other Platform features in the following ways:

To provide any legitimate business service or product.
To personalize your Platform and to allow us to deliver the type of content and product offerings in which you are most interested (including to present offers to you on behalf of business partners and advertisers).
To allow us to better service you in responding to your customer service requests.
To contact you when necessary or requested.
To process your transactions.
To verify and validate your identity, enforce the Terms of Service, and to detect and protect against error, fraud and other unauthorized or illegal activities.
To administer a promotion, survey or other Platform features.
To the extent you have not opted out of receiving marketing communications, to send you information about SKILLR or our products or the Platform, including by letter, email, text, telephone or other forms of communication.
To the extent you have not opted out of receiving marketing communications, to provide you with information about third-party businesses, products and services, including by letter, email, text, telephone or other forms of communication.
To operate and improve the Services available through us.
To fulfill your requests for tools, software, functionality, features and other products, and services.
To communicate with you and respond to your inquiries.
To conduct research about your use of our products.
To help offer you other products, features or services that may be of interest.

We reserve the right to make full use of Usage Data. For example, we may use Usage Data to provide better service to Platform visitors or end users, customize the Services based on your preferences, compile and analyze statistics and trends about the use of our Services and otherwise administer and improve our Services.

You understand and agree that if you are using any Platform from a country outside the United States and provide Personal Information to the Platform, you will be authorizing and consenting to the transfer of Personal Information about yourself to the United States. You understand that the privacy laws of the United States may be different from and not as comprehensive or protective as those in your country, and you agree that the transfer of your Personal Information to the United States occurs with your consent. Personal Information collected on the Platform may be stored and processed in the United States or abroad.

Disclosure of the Information We Collect to Third Parties

You understand and agree that we can disclose your Personal Information and other data to third parties, as follows:

To our subsidiaries or affiliates, strategic partners and to third parties we engage to provide services, such as medical services, website hosting, credit card payment processing, order processing, analytics services etc.
In the event of the sale or transfer of SKILLR, of one or more of our business units or of some or all of our assets, or in the context of some other business acquisition transaction.
In response to lawful governmental requests or legal process (for example a subpoena, court order, or search warrant); to establish or exercise our legal rights, or to defend against claims; or to protect the safety or security of the public or of users of the Platform; or in other circumstances in which we have a good-faith belief that a crime has been or is being committed by a user of our Services, that an emergency exists that poses a threat to the safety of you or another person,
When necessary to protect either our rights or our property or for us to render the service you have requested.
We can disclose aggregate information and other non-individually identifiable information about users of the Platform to our service providers, partners, advertisers or others. For example, we may share information publicly to show trends about the general use of our websites and/or other products or services.

Use of Cookies

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser or mobile device that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. Cookies help us in many ways to make your use of the Platform more enjoyable and meaningful, such as understanding usage patterns and improving functionality of the Platform. For instance, we use cookies to help us understand your preferences based on previous or current Platform activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about Platform traffic and Platform interaction so that we can offer better Platform experiences and tools in the future.

We may contract with third-party service providers to assist us in better understanding our Platform visitors. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Platform and enhance your experience when you use the Platform. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

If you are using our website, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. If you are accessing our mobile app, you can choose to change your permissions and settings on your mobile device. Each browser and device is different, so look at your browser or devices Help or Settings menu to learn the correct way to modify them. If you turn cookies off or disable certain permissions, you won't have access to many features that make your Platform more efficient and some of our services will not function properly.

Our Platform currently does not respond to “Do Not Track” (DNT) signals and do not recognize browser-based “do-not-track” requests.

Safeguarding Your Personal Information

SKILLR follows generally accepted industry security standards to safeguard and help prevent unauthorized access and maintain data security of Personal Information. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of any Personal Information submitted to or otherwise collected during your use of any Platform. Accordingly, you understand and agree that you transmit all data, including Personal Information, to us at your own risk.

Privacy and Third-Party Links

This Privacy Policy applies solely to information collected by the Platform through our web site located at skillr.com and the mobile application(s) we make available. In an attempt to provide you with increased value, we may include third party links on the Platform. This Privacy Policy does not apply to the third-party sites and services that are accessible through these links and we suggest that you contact the operator of the third party service to obtain details about their privacy policies. We have no responsibility or liability for the content and activities of these linked sites or services. Nonetheless, we seek to protect the integrity of the Platform and welcome any feedback about these linked sites (including if a specific link does not work).

Children’s Privacy

The Platform is not directed to children under the age of 13, and we request that they not provide Personal Data through the Platform. In some countries, we may impose higher age limits as required by applicable law. SKILLR is committed to complying fully with the Children’s Online Privacy Protection Act of 1998 (“COPPA”).

We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any Personal Data through the Platform. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at Help@skillr.com .

California User Privacy Rights

For California residents: We may share your personal information with third parties and affiliated third parties (such as local, state and regional affiliates and affiliate alliances), some of which do not share the We name, for their direct marketing purposes. As these third parties and this category of affiliated third parties are considered an unaffiliated party under California law, you may opt-out of our disclosure of personal information to third parties for their direct marketing purposes. To opt out, please contact us as described in the “How to Contact Us” Section below.

We will continue to provide your information to local, state and regional affiliates and affiliate alliances identified in your membership application or account for the purpose of processing your membership in such affiliate and affiliate alliance programs.

The California Consumer Privacy Act (CCPA), effective January 1, 2020, gives California consumers enhanced rights with respect to their personal information that is collected by businesses. First, California consumers may opt out of having their personal information sold to other persons or parties. Second, they have a right to know:

What specific pieces of information a business has about the consumer;
Categories of personal information it has collected about the consumer;
Categories of sources from which the personal information is collected;
Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
The business or commercial purpose for collecting or selling personal information.

In addition, California consumers can request that the personal information a business has collected about them be deleted from the business’s systems and records. Company may be considered a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the Act.

We do not rent or sell your personally identifiable information (such as name, address, telephone number and credit card information) to unaffiliated third parties for their marketing purposes. We may share your information with third parties to provide products and services you have requested, when we have your consent, or as described in this Privacy Policy.

To make a “request to know” or request to delete your personal information, send us an e-mail at Help@skillr.com (Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.) We will use commercially reasonable efforts to honor these requests whether or not you would qualify as a California consumer under the CCPA. If and to the extent we are considered a covered business under the CCPA: We will confirm receipt of your request within 10 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your personal information within 45 days of receipt of your request but can use an additional 45 days, but we must let you know the additional time is needed.

When contacting us, we may ask you to provide certain, limited personal information, such as your name, email address and/or account login ID and/or password, to verify your request and to match with our records and systems. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months.

Residents of other states may also have similar rights to request information about or delete their personal information. To inquire about exercising these rights, please contact us at Help@skillr.com.

Pursuant to California’s “Shine The Light law (California Civil Code § 1798.983), California residents are entitled, once a year and free of charge, to request the disclosure of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year, if any. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing. You may request this information by contacting us at help @skillr.com and indicate in the email subject line, “California Shine The Light Request.” Please include your mailing address, state of residence and email address with your request.

International Data Transfers

We are a global business. Personal Information may be stored and processed in any country where we do business or our service providers do business. We may transfer your personal information to countries other than your own country, including to the United States and countries in the European Economic Area (“EEA”). These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. Officials (such as law enforcement or security authorities) in those other countries may be entitled to access your personal information.

If you are located in the EEA, the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Information to the US. Where applicable law requires that a data transfer legal mechanism, we use one or more of the following: EU Standard Contractual Clauses with a data recipient outside the EEA or the UK, verification that the recipient has implemented Binding Corporate Rules, or other legal method available to us under applicable law.

While SKILLR remains self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, it is not currently relying on these frameworks for the transfer of Personal Information to the U.S.

Exercising Your Rights

If you wish to submit a request to exercise one or more of the rights listed above, you can contact us. An e-mail requesting to exercise a right will not be construed as consent with the processing of your Personal Information beyond what is required for handling your request. Such request should meet the following conditions:

State clearly which right you wish to exercise; and
State clearly the reasons for exercising your right if such is required; and
Your request should be dated and signed; and
Your request should be accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, we may ask you for your signed confirmation and proof of identity.

We will promptly inform you of having received your request. If the request meets the conditions above and proves valid, we will honor it as soon as reasonably possible and at the latest thirty (30) days after having received your request.

Exclusions

This Privacy Policy applies only to information collected via the Platform and does not apply to information you disclose to SKILLR through other means. This Privacy Policy shall not apply to any unsolicited information you provide to us through the Platform or through any other means. This includes, but is not limited to, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Questions and Feedback

We welcome your questions, comments, and concerns about the Platform. Please send us any and all feedback pertaining to the Platform to Help@skillr.com.