Privacy Notice.
Effective: May 9, 2022
Skilling It, Inc., a Delaware corporation (“Skilling It,” “we,” “us,” and/or “our”) owns and operates (a) our website located at www.skillingit.com (the “Site”), and (b) the Skilling It mobile software application (the “Skilling It App”) which enables end users to take life skills courses (the “Courses”).
This Privacy Notice describes the data collection, use, protection, and privacy practices of Skilling It with respect to information and data we may collect in connection with your use of the Site, the Skilling It App (including, any Courses offered through the Skilling It App), and any related services we may provide and/or offer in connection with the use of the foregoing (collectively, the “Services”).
Please read this Privacy Notice carefully. It provides important information about your personal information and tells you about your rights under applicable privacy laws. If you have any questions, comments, or concerns regarding this Privacy Notice and/or our data practices, please contact us.
BY VISITING OUR SITE AND/OR USING ANY OF OUR SERVICES (INCLUDING, BUT NOT LIMITED TO, DOWNLOADING THE SKILLING IT APP), YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY NOTICE AND AGREE TO SKILLING IT’S COLLECTION AND USE OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN.
Table of Contents
Changes to this Privacy Notice
Information We Collect
Children’s Privacy
Sensitive Data
How Skilling It Uses Personal Information
Sharing Personal Information
Marketing Communications
Your Choices
Third Party Social Plug-Ins
App Stores & External Websites
Data Retention
Data Security and Protection
California Privacy Rights – Shine the Light
Nevada Privacy Rights
International Transfers
How to Contact Us
Changes to this Privacy Notice
Skilling It reserves the right to update or modify this Privacy Notice at any time. Except for material changes as described below in this Section, all updates and modifications to these documents will be effective from the day they are posted on the Site at www.skillingit.com/privacy. If we make any material changes to this Privacy Notice, we will provide reasonable prior notice of these changes by posting a prominent notice of any such changes on the Site and/or through the user-interface of the Skilling It App, and if we have an email address on file for you, sending a notification to your email address. Material changes to this Privacy Notice will become effective on the date set forth in the notice. It is your responsibility to regularly visit and review this Privacy Notice.
If you do not agree to any updates or modifications to the Privacy Notice, do not visit and/or use our Services. Your continued use of and of our Services after the applicable effective date of the revised Privacy Notice, signifies to us that you acknowledge and agree to be bound by the revised Privacy Notice.
Information We Collect
The term “personal information” or “personal data” means any information about an individual from which that person may be identified. For example, it may include a person’s name, telephone number, email address, or payment information, and in some jurisdictions, IP address. It does not include data from which the identity of an individual has been definitively removed along with any identifiers connected to such individual (also known as anonymous or anonymized data).
Generally, Skilling It collects and/or receives personal information when you:
Visit and/or browse the Site;
Register an account to access and use the Courses through the Skilling It App;
Download the Skilling It App;
Access and/or use any of our Services;
Interact with and/or use support and other services provided by us as part of or in connection with the Site and/or Skilling It App;
Interact with us or our account page, and/or our content or posts through social media platforms, such as, Instagram, Facebook, Twitter and/or YouTube (each, a “Social Media Platform”); and/or
Communicate with us directly.
In some instances, we collect information directly from you as explained in the Section Information Provided Directly to Skilling It, and in others, we may receive information from third parties, as explained in the Section Information Collected From Third Parties.
In addition, in certain circumstances, you will not provide any information to us directly, in which case we automatically collect certain information as explained Information Collected Indirectly.
Information Provided Directly to Skilling It
The personal information we collect directly from you depends on how and why you use the Services. Please be advised that we may ask you to update your information from time to time in order to keep it accurate.
If you provide personal information to us about someone else, you must ensure (1) that you are entitled to disclose that information to us, and (2) that we may collect, use and disclose such information for the purposes described in this Privacy Notice, without us having to take any further steps required by data protection laws. For example, you should ensure the individual concerned is aware of the terms detailed in this Privacy Notice and that they have not objected or do not object to you sharing their information with us.
Contact Information
If you register an account to access Courses through the Skilling It App, we will collect contact information such as:
Your identity (first name and last name);
Your email address; and/or
Your username, password and/or other login credentials.
Other Information You May Provide to Us
In addition to the above scenarios, there may be certain features of the Services which allow you to provide additional information to us directly, which may include:
Your name (first and last) and/or email address, when you sign up for our email marketing communications or to sign up to receive updates on the launch of the Skilling It App.
Messages, photos, video, audio, images, data, information, text and/or any other content or materials you post, submit, transmit, and/or upload, or otherwise provide us, in connection with the use of the Services (collectively, “User Content”), including, but not limited to, when you use any chats, blogs, forums, message boards, or other interactive communication tools and/or features available through the Services.
Information, data, content, documents and/or materials you provide to us when you fill out forms, answer surveys, or contact us (such as your feedback, requests for support, or other communications with us).
Information Collected from Third Parties or Through Third Party Sources
In some instances, we may process and/or receive personal information from third parties, which consists of:
Data from third party products and services that we have integrated into the Services, for example, the YouTube Player embedded in the Skilling It App that we use to deliver the Courses (collectively, “Third Party Integrations”).
Information and/or content that you provide and/or that may be provided to us, when you engage with and/or interact with us through a Social Media Platform. For example, if you like, comment, and/or view Courses we have made available through our YouTube account, or if you tag us in an of your social media posts, we will have access to that information and content. We only use this information to respond to and/or engage with you on Social Media Platforms and not for any other purposes.
Please note that we do not control or operate the Social Media Platforms or the use of your information by the providers of the Social Media Platforms and/or other users of the Social Media Platforms. You should review the privacy notices for any Social Media Platforms you use to understand how they collect, use, share and protect your information.
Information Collected Indirectly
Usage Information
Just like many websites and services, we, or our authorized third-party service providers, automatically collect technical and/or analytics information about how you use and/or interact with our Services (collectively, “Usage Information”).
Usage Information may include (but is not necessarily limited to) identifiers, commercial information, IP address (or proxy server), mobile device number, device and application information, identification numbers and features, your approximate location (as determined through your IP address), browser type, plug-ins, integrations, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, websites, apps and/or ads that referred you to the website, advertising and language preferences, operating system type and version, system configuration information, date and time stamps associated with your usage, and frequency of visits to the websites, details of which of our products and product versions you are using (e.g., the version of the Skilling It App you have downloaded), and/or a random unique application instance number assigned by us when you download a Skilling It App (the “Application Instance Number”).
Typically, all Usage Information is collected in anonymous form and does not identify you personally. For example, some of the device and usage information collected, whether alone or in conjunction with other data, could identify you, although, except where strictly required to identify an individual for security purposes, such data and information is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals). In addition, in some instances we may link and/or tie Usage Information to the Application Instance Number, which is considered “pseudonymized data.”
To the extent any Usage Information is linked or tied to personally identifiable information, such information is deemed “personal data” and we will use it and protect it in accordance with this Privacy Notice.
Cookies and Similar Technologies
We or authorized third parties may collect certain information (including, without limitation, Usage Information) by automated means using technologies such as cookies, web beacons, embedded scripts, pixels, browser analysis tools, server logs, and mobile identifiers, and similar technologies that are deployed, and typically stored on your device and have a unique identifier, when you visit a website, when you open an email or click on links or images within an email, and/or when you interact with online advertisements.
These technologies may be used for many different purposes. For example, they can be used to show that you have previously visited and/or used a feature of the Services and to identify which parts of the Services we offer you might be most interested in, or used to improve your online experience by storing your preferences during your visit and/or use of the Services. These technologies can also be used for security, fraud detection and authentication purposes.
In many cases, the information we collect using these technologies is only used in a non-identifiable manner without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize user experience. In other cases, we associate the information we collect using cookies and other technology with your personal information.
Skilling It does not directly track users across third party websites.
How to Manage Cookie Preferences
Where required by applicable law, we will obtain your consent prior to setting cookies (except for strictly necessary cookies). Most web and mobile device browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set.
In order to manage your cookie preferences, you may alter the cookie settings in your browser settings at any time. You may accept all, or certain, cookies. If you do disable our cookies in your browser settings, you may find that certain features and/or functionality of the Services do not work.
To learn more about cookies, including how to manage cookies and opt-out of cookies being placed on your device, please visit http://www.allaboutcookies.org/manage-cookies/index.html.
While tracking is widespread over the internet, there are things you can do to minimize these activities with respect to browser cookies.
Do Not Track Settings
You may turn on the Do Not Track (“DNT”) setting in your browser, which will enable your browser to send a special signal to websites, analytics companies, plug in providers, and other web services you encounter while browsing to stop tracking your activity. To turn on your DNT signal, please visit https://allaboutdnt.com/#adjust-settings. Please note that not all companies will respond to or honor DNT signals.
Note that Skilling It does not process or respond to web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who use the Site.
Aggregated Data
With the personal information and other data (including, Usage Information) collected by us, we process “Aggregated Data”, such as statistical or demographic data. Aggregated Data may be derived from personal information, but is not considered personal information under the law if it does not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information, which will be processed in accordance with this Privacy Notice.
Children’s Privacy
The Services are not intended for users under the age of 13, nor does Skilling It target the Services to persons under the age of 13, and Skilling It does not knowingly collect personal information from persons under the age of 13. Therefore, we ask you not to provide us with personal information of persons under the age of 13 and if you are under 13 years of age you are not permitted to use the Services. If we learn that personal information of persons under 13 years of age has been collected on or through the Services or otherwise provided to us, then we may deactivate the account or otherwise terminate access to the Services and/or make the content and/or information inaccessible.
Sensitive Data
Skilling It does not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health and genetics, or biometric data to use the Services.
Payment Processing
We do not collect or process any payment information in connection with the use of the Services.
How Skilling It Uses Personal Information
Depending on how you use the Services, we use your personal information in the following instances:
To provide the Site and perform our Services to you and other visitors/customers;
To deliver direct marketing communications regarding our products and services that we may think are of interest to you;
To respond to your queries and requests, or otherwise communicate directly with you;
To detect any fraudulent or illegal activity against you, our other users, and/or Skilling It;
To improve our Services and/or develop new products, services, features and/or functionality;
To perform system maintenance and upgrades, and enable new features;
To enforce and/or protect our rights and the rights of others;
To comply with a legal or regulatory obligation (for example, keeping records of our sales for tax compliance); and
To provide information to regulatory bodies when legally required, and only as outlined below in the Section title “Required Disclosures – Responding to Legal Orders” under Legal Obligations, Required Disclosures, and Exigent Circumstances.
Sharing Personal Information
Aside from disclosing your information to those of our personnel who are authorized to process the information in order to provide the Site and Services and who are committed to confidentiality, we disclose your personal information only to the third parties as described below.
Third-Party Service Providers
We share personal information with third parties that provide services to us that help us in the operation, provision, administration and management of the Site and Services (“Service Providers”), and to otherwise operate our business. Depending on how you use the Site and Services, the following categories of third parties collect data on our behalf or receive personal information:
Hosting and IT services providers,
Providers of the Skilling It App;
Providers of business operations and communication tools (e.g., email marketing service providers),
Other third-party service providers that help us provide features and functions for the Site and/or Services (e.g., customer support providers), and
Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.
For a list of all Service Providers we use, please contact us. We require all Service Providers to respect the security of your personal information and to treat it in accordance with the law.
Third Party Integrations
When you interact with and/or use Third Party Integrations in connection with the Services (for example, when you view Courses through the Skilling It App), certain data and information may be exchanged between us and the provider of the applicable Third Party Integration. Note that the Third Party Integrations you choose to interact with and/or use are not our service providers. The applicable providers of Third Party Integrations may use your personal information differently than we do and we do not control their use of your information.
Please review the privacy notices for our current Third Party Integrations:
YouTube Player (operated by Google, Inc. https://policies.google.com/privacy?hl=en
To Other Users of the Services
If you communicate through and/or comment or post any User Content using any public chats, blogs, forums, message boards, or other interactive communication tools and/or features available through the Services, your User Content, including any personal information contained therein, submitted or transmitted in connection with such communication features will be available to anyone engaged in communications with you and/or who has access to those communication features.
Please be aware that other users with whom you choose to share your information may use your personal information differently than we do, and we do not control their use of your information. Skilling It will not be able to contain or retrieve personal information once it has been shared or disclosed with other users, and Skilling It will have no responsibility or liability for any consequences that may result because you have released or shared personal information with others.
Please make your choice to share and/or publicly post information carefully.
Business Transfers
We may also share data with third parties to whom we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Notice.
Affiliates and Subsidiaries
Personal information that we collect about you through the Site and/or Services may be shared with the employees, contractors, and agents of Skilling It and our affiliated and subsidiary entities (“Affiliates”) who are involved in providing or improving the Services that we offer to you. We obligate the employees, contractors and agents of Skilling It and our Affiliates to ensure the security and confidentiality of your personal information and to act on that personal information only in a manner consistent with this Privacy Notice.
Legal Obligations and Security
Regulatory and Government Bodies – Compliance with Law
We may disclose your information to regulatory agencies and official government bodies, as required to comply with or satisfy any laws, rules, or regulations applicable to Skilling It.
Required Disclosures – Responding to Legal Orders
If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States. Under such circumstances, unless prohibited by applicable law, we will attempt to provide you with prior notice that a request for your personal information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address. However, government requests may include a court-granted non-disclosure order, which prohibits us from giving notice to the affected individual. In cases where we receive a non-disclosure order, we will notify you when it has expired or once we are authorized to do so.
Exigent Circumstances & Enforcement/Protection of Our Rights
Your information, including the contents of all of your online communications in our Services and between you and Skilling It may be accessed and monitored as needed to provide our Services and may be disclosed to law enforcement, regulatory agencies, official government bodies, and other third parties, as we, in our sole discretion, believe necessary or appropriate:
To enforce our rights under our Terms of Service, and/or other agreements we enter into with our customers;
In connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us or our affiliates, partners and/or agents to legal liability; and/or
If we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person.
With your Consent
There may be situations where you are asked to consent to share personal information with third parties for additional reasons not included in this Privacy Notice. In such event, we will only share such personal information if we have received your prior consent and only for the purposes as listed in the request to share such information.
Direct Marketing Communications
Email Communications
If you are a customer of ours and have not otherwise opted out (or with your consent where required by applicable law), or if you have opted in to receive direct marketing emails from us, we may use your personal information to send you marketing information about the Services, new product releases, new features releases of the Services, and/or other Skilling It products and services that we think may interest you.
You may manage the receipt of marketing and non-transactional email communications you receive from us by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails.
We will use commercially reasonable efforts to process such requests in a timely manner. Note that you cannot opt out of receiving transactional e-mails or communications related to the use of the Services (e.g., requests for support or notices, security notices, and/or notices of updates to this Privacy Notice), which, for clarification, are not marketing communications.
Accessing, Updating and Correcting Personal information
If you would like to correct or update certain personal information (such as your contact information), you can update this information in your account settings page in the Skilling It App. If there is other information that you have provided to us you wish to correct and/or update please contact us and we will use reasonable efforts to correct and/or update such information.
Third Party Social Plug-Ins
On or through the Site, we may provide third-party “share” buttons which enable you to share certain content via Social Media Platforms. These “share” buttons may function as web beacons when you interact with the button. Please note that when you “share” using the buttons for a Social Media Platform, you may send the information that you are viewing to the third party provider of the Social Media Platform and other users of the Social Media Platform. If you are not logged into your account with the third party provider, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the Site to your account with the applicable third party provider. Please refer to each third party’s privacy policies to learn more about its data practices.
App Stores & External Websites
Your app store (e.g., Apple App Store or Google Play) may collect certain information in connection with your use of the Skilling It App, including, without limitation, personal data, geolocational information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.
In addition, on or through the Site, we may provide or make available, for informational purposes only, links to other websites or resources with which we do not have a contractual relationship and over which we do not have control (“External Websites”). Such links are not paid advertisements, nor do they constitute an endorsement by Skilling It of those External Websites, and are provided to you only as a convenience. By clicking on links to External Websites, the operators of the External Websites may collect your personal information. We are not responsible for the content or data collection practices of those External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies.
Data Retention
Personal information is processed for the period necessary to fulfill the purposes for which it is collected (for example, in connection with the Services used and/or requested by you), to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights.
In some instances, we may choose to anonymize personal information instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal information can be linked back to any specific individual
Data Security and Protection
We have put in place reasonable and appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. For example, we use encryption, secure socket layer, firewalls, and password protection. In addition, we limit access to personal information to those employees, agents, contractors and the third parties who have a business need-to-know.
We also have procedures in place to deal with any suspected data security breach. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and while we take reasonable steps to provide secure services, by using the Services, you understand and assume the risks associated with your activities on the internet.
In addition, you have responsibility and control over protecting your personal information. For example, you, and not Skilling It is responsible for safeguarding your password, and other authentication information you use to access the Services. You should not disclose your password and/or authentication information to any third party and should immediately contact us of any unauthorized use of your password or you have reason to believe that your information and/or account is no longer secure.
California Privacy Rights - Shine the Light
Skilling It does not share your personal information with any unaffiliated third party for its direct marketing purposes without your express consent.
California residents who have provided us with personal information have the right (under California Civil Code§ 1798.83) to request and obtain from us, once each year, the details of any personal information we shared with a third party for that third party’s direct marketing purposes during the prior calendar year. The details would include the categories of personal information and the names and addresses of the third party with which it was shared.
To request information about this sharing, you may submit a request with "Your California Privacy Rights" in the subject line, along with your first and last name, and complete mailing address (including street address, city, state, and zip code) by either: sending an email message or writing to us at the email and/or mailing address specified in the How to Contact Us Section.
If you do not submit and send your request with complete information as set forth above, we will not be able to process it.
Nevada Privacy Rights
Under Nevada law, certain Nevada residents may opt out of the sale of covered personal information (which includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online) to a person for that person to license or sell such information to additional persons.
Skilling It does not currently sell your covered information as defined under applicable Nevada law; however, you may submit an opt-out request, which we will honor as required by Nevada law should we engage in such a sale in the future.
You may submit an opt-out request by sending an email message or writing to us at the email and/or mailing address specified in the How to Contact Us Section; along with your full name, any user name, and complete mailing address (including street address, city, state, and zip code), email address (so that we can contact you, if needed, in connection with the request) and confirmation that you are a Nevada resident.
You must provide us with information reasonably requested by us to verify your identity and the authenticity of the request. We typically process these requests within 60 days from the day we receive it (and will notify you within that period if we need an additional 30 days to do so).
International Transfers
Skilling It is based in the United States. The personal information that we collect are sent to and stored on servers located in the United States. Such storage is necessary in order to process the information. Skilling It may transfer the personal data that we collect from you to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside of your country or regional area, and may be processed by staff operating outside of your country or regional area. In particular, information provided to us or collected by us likely will be transferred to and processed in the United States by us or our Affiliates and our respective agents and contractors. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your country of residence.
How to Contact Us
If you have any questions about this Privacy Notice, please contact us at: info@skillingit.com; Subject Line: Privacy Request.