Data Privacy Notice
This is the Data Privacy Notice of Skillkeepr, Inc. (“Skillkeepr” or the “Company”). This Data Privacy Notice
(“Privacy Notice” ) describes how we collect, use, disclose, transfer and store your personal information.
Skillkeepr as a Processor
Skillkeepr processes the personal information of its customer’s data subjects on our websites and mobile applications (together, the “Website”) only in accordance with our customer’s instructions and this Privacy Notice does not apply. Where Skillkeepr acts as a processor (or “service provider”) for the personal information of our customer’s data subjects, the privacy notice of our customer applies. Should you have questions about your personal data or wish to exercise your privacy rights, please contact the relevant customer with whom you engaged with using our website.
Skillkeepr as a Controller
This Privacy Notice applies to activities where Skillkeepr acts as a controller, including when you visit or engage with our website, when you engage with us through marketing campaigns and at trade events (both online and offline), and for our website account management.
The Company is committed to protecting the information that our customers, employees, suppliers, and others have entrusted to us. This Privacy Notice sets forth the principles that govern our treatment of personal information. We expect all employees and those with whom we share personal information to adhere to this Privacy Notice.
Specific disclosures required for residents of California, Virginia, Colorado, Connecticut and Utah, as well as individuals located in Canada can be found in the section below titled Required Disclosures.
By using our websites, purchasing our products, or providing your information to us, your personal information will be transferred to and stored in Canada and/or the United States.
1. Personal information we collect and use
Personal Information You Provide
Your privacy is important to us, and we take care to only collect the information we need, and only if we need it. The website may ask for and collect your personal information in order to provide you with our services, enhance your experience, and provide you with other relevant information about our offerings. The types of personal information we collect from you will depend on how you are interacting with us while using our website and services. Depending on how you interact with our website, we may collect the following personal information about you:
- To respond to your questions, requests, or communications, including any feedback or requests relating to our website and services, we may collect your name, email address, phone number, address, location, title, company name, company size, and any other information by which you provide so you may be contacted online or offline, and any other information you choose to provide to us.
- To create and maintain your membership account, we will collect your name, membership card number, email address, phone number, educational information, resume, employment history including job titles and companies employed in, birthday, social media name, and any other information you choose to provide to us.
- When you place an order or subscribe for our services, we will collect your name, email address, phone number, and payment card information.
- To give you information about our products and services, we may collect your name, email address, phone number, and order history.
- When you post or publish information on our website or transmit information to other users of our website or third parties, we will collect your name, email address, and any other information you choose to provide, post, or publish.
- When you apply for a job using our website, we will collect your name, email address, phone number, resume, desired position, and location.
Information Collected From Your Devices
We may collect the following information automatically from your devices when you use our website or services:
- When you use our website to access, we will collect your precise geolocation with your permission.
- For data analytics, including to audit, research, and conduct analysis in order to maintain and improve our services and to protect people who use our services, we may use cookies and similar technologies to collect log information (including IP address, browser type, domain names, access times, referring website addresses, app usage, events that occur within the app, performance data, and download sources) and device information (including computer or mobile device used to access the website, hardware model, operating system, and device identifiers).
Personal information provided by others
Depending on how you interact with our website, we may collect cookies and browsing data from our service providers. This includes online activity information and browsing and usage information. When you use our website or services, we may collect the following information from third parties:
- To integrate with third-party apps and services, such as social media websites and applications, we will collect your unique identifiers, first and last name, phone number, and email address.
- When you engage with us on social media, we may collect your social media usernames, posts, and media (video, audio, images) from the social media platform.
- Third party websites and social media services. Our website may include links to third party websites or social media services where you may be able to post comments, reviews, or other information. We may monitor comments and reviews regarding us, our products, or our website that you publicly post on social media or customer review sites. In addition, please note that your use of these third party websites or social media services may result in those sites collecting information about you.
We are not responsible for these third party websites or social media services and you should review their privacy policies to make sure you understand the information that may be collected, used, and shared by those sites.
Where permitted by law, we may also receive your personal information from third parties in order to connect with you regarding our products and services. When we receive information about you for direct marketing, we may collect the following information from third parties:
- To contact you about our products and services relevant to you, such as your name, job title, company you work for, business contact details (including email, company headquarters, office address, and phone number), education, and any other information available through the public directory.
Skillkeepr uses ZoomInfo to reach out to potential customers. You can control your privacy preferences on ZoomInfo directly through their Privacy Center located at: https://www.zoominfo.com/privacy-center/manage-profile.
Where you no longer wish to receive direct marketing communications from Company, you may unsubscribe through the email which you received or make a request via the Contact Us section of this Notice.
Other Ways We Use The Information We Collect
In addition to the uses we identified above, we may also use any of the information collected above for the following purposes:
- To enforce our agreements, including agreements with you when you use our website and services;
- To operate, evaluate, and improve our business, including improving and personalizing the experience for you and others, to complete and maintain records of transactions with individual customers following use of our website or services;
- For safety and security, by making sure third parties protect your information, monitoring the technical functioning and security of our network;
- For legal and compliance, including complying with applicable laws, regulations, and legal obligations; and
- To protect the rights or property of the Company, its employees, and people who use its website or services.
2. Cookies and similar technologies
Our website uses cookies, web beacons, java scripts, and similar technologies to automatically collect certain information about your activity relating to your visit to our website. These technologies collect your Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We use this data to analyze trends, administer our website, track users’ movements through our website, and gather demographic information about our user base as a whole. We may receive reports based on these technologies on an individual or aggregated basis.
A “cookie” is a small text file that websites send to your computer or device other Internet- connected device to identify your browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes information on your interaction with a website, application, or advertisement, your Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Our website uses first-party cookies (served directly by our website domain when you visit our website) and third-party cookies (served by a third-party website when you visit our website and our marketing partners’ websites). We and other third parties may collect information about your online activities over time and across different sites and services when you visit our website.
Do not track signals
Some web browsers allow you to turn on Do Not Track (“DNT”), which sends signals to websites you visit, telling those sites that you do not want your online activities to be tracked. Our website currently is not designed to respond to DNT signals received from web browsers.
3. How we share personal information
We may share information about you with third parties as indicated below:
Service Providers, Suppliers, Agents, and Business Partners: Other companies sometimes provide certain services to us or on our behalf (e.g., maintenance, Tech support, human resources, analysis, development, security, orders and delivery). Unless we tell you differently or as described elsewhere in this Privacy Notice, our service providers are not permitted to use your information except to assist us.
Third Party Integrations: Your use of our website and services will sometimes involve integrations with other third-party platforms or applications, such as LinkedIn or Facebook. We will share your information with that third party so that you are able to make full use of our website and services, including those integrations.
Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals in order to comply with laws that apply to us, or other legal obligations such as contractual requirements.
Changes in Business Structure/Ownership: We may disclose or transfer your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Company’s business, assets, or ownership interest (including any bankruptcy or similar proceedings).
Skillkeepr does not sell any individuals’ personal information, including children under 16, to anyone and does not share personal information with third parties for those parties’ commercial use.
4. “LEGAL CATEGORIES” Of personal information
The law requires us to tell you about the personal information we collect about you in a certain way – specifically, we need to tie it back to “legal categories” of personal information that are listed in the law. To do this, we bundled up the information we gave you above in this Privacy Notice and matched the different types of personal information we collect about you with the legal category. To make things easier to understand, we’ve put this information in a chart that shows you four things:
- The legal category of personal information,
- Examples of the types of personal information included in each legal category,
- The purpose for why we collect and use your personal information for each legal category; and
- The business purposes for which we share your personal information and with whom.
The Privacy Chart at the end of this Privacy Notice. At the end of the Privacy Chart, we also included a list of Information We Disclose for a Business Purpose.
5. Required disclosures
In certain circumstances, we may choose or may be required to provide additional or different disclosures to residents of different countries or states. Below are the disclosures that may be applicable to you.
Privacy Rights and Choices
Some privacy laws require that we disclose to you the privacy rights that you have regarding personal information. We have defined the various privacy rights below. These rights may be subject to certain limitations or exceptions depending on (1) your state of residency or country from which you are accessing our website, and (2) the purposes for which we process personal information about you. To see which rights apply to you, refer to the “Privacy Rights Chart” immediately following this subsection.
For all personal information that we collect about you, you may have the following rights or choices that we will accommodate where your requests meet legal and regulatory requirements and do not risk making our other data less secure or changing our other data. You may also designate an authorized agent to make a request on your behalf.
- Right to Know: You may have the right to know what information is being collected about you, and to know whether your personal information is disclosed and to whom.
- Correction: If your personal information changes and you need to update it with us, you can do so by logging into your account with us (if you have one) and making any changes to the information stored there. Likewise, if you believe the information we have about you is incorrect or incomplete, you can challenge the accuracy of that information and ask us to correct it.
- Access to Your Information: You may have the right to obtain a copy of the personal information collected about you.
- Limit Sensitive Data: In some circumstances, you may have the right to request that we limit the use and disclosure of your sensitive information to that which is necessary to perform the services or provide the goods, or as required by applicable law.
- Opt Out of Sale: You may have the right to ask us not to sell your personal information. We do not sell your personal information, but if you wish to make a request, we are happy to confirm that we do not sell your personal information.
Opt Out of Targeted Advertising:
- Opting Out of Marketing or Profiling: If you wish to opt out of marketing communications you can do so any time. If you would like to make a request, you can click the link at the bottom of the marketing email you received, or you can contact us using one of the methods in the “Contact Us” section of this Privacy Notice.
- Right to Make a Complaint: You have a right to complain to us about our personal information practices, and you can do so using one of the methods in the “Contact Us” section below. We will evaluate your complaint and will contact you if we need further information to resolve it. In addition, you may have the option of complaining to the relevant supervisory authority, government regulator, or privacy commissioner in your state, country, province, or region of residency.
- Data portability: You may have the right to request a copy of your personal information be provided to you or to a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.·
- Non-Discrimination or Retaliation: You have the right not to receive discriminatory treatment by the Company because you exercise your privacy rights.
- Withdraw consent: Where we rely on consent or are required to obtain your consent to process your personal information, you may have the right to withdraw your consent if you change your mind. We will notify you when we rely on consent to process your personal information.
- Request Erasure or Deletion: Subject to some limitations you may have the right to deletion of your personal information where we no longer have a reason to continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.
For more information about the rights and choices applicable to you, please refer to the Privacy Rights Chart below.
To exercise any of these rights, or if you have any questions or concerns about our privacy practices, please contact us using one of the methods in the “Contact Us” section of this Privacy Notice.
Privacy Rights Chart
| Right to Know | Right to Correction | Right to Access | Right to Limit Sensitive Personal Information | Right to Opt Out of the Sale or Sharing | Right to Opt Out of Targeted Marketing or Cross- Context Behavioral Advertising | Right to Opt Out of Direct Marketing or Profiling | Right to Portability | Right to Non-Retaliation | Right to Withdraw Consent | Right to Deletion | |
| California Residents |  | |  | | | | | | | | |
| Virginia Residents | | | | | | | | | | | |
| Colorado Residents* | | | | | | | | | | | |
| Connecticut Residents* | | | | | | | | | | | |
| Utah Residents** | | | | | | | | | | | |
| Canada Residents | | | | | | | | | | | |
* Rights for Colorado and Connecticut Residents become effective July 1, 2023.
** Rights for Utah Residents become effective December 31, 2023.
What to Expect When Exercising a Privacy Right
How to Make a Request:
If you would like to make a request to exercise your privacy rights, please contact us using the information in the “Contact Us” section of this Privacy Notice. Please include your name, email, phone number, and the specific type of request you would like to make.
Responding to Requests:
Your request will be evaluated to determine whether the request meets legal regulatory requirements and does not risk making our other data less secure or changing our other data. If we aren’t able to honor any part of your request, we will tell you that in our response, as well as the reason(s) we cannot do so. We reserve the right not to change your information if we believe the rights of another individual might be violated.
Verifying Your Identity:
To protect you and your information, we may ask you to confirm certain information before we honor your request. For example, if you make a request, we will ask you to confirm your email address and phone number. For certain requests, we will use a combination of your email address, phone number, zip code, and/or birth date to verify your identity, so that we can help protect your information.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.
Canadian Specific Disclosures
You have a right to complain to us about our personal information practices, and you can do so using one of the methods in the “Contact Us” section below. We will evaluate your complaint and will contact you if we need further information to resolve it. In addition, you may have the option of complaining to the Office of the Privacy Commissioner of Canada or to your province or territory’s privacy commissioner.
6. Data retention
We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. How we protect your personal information
We strive to take appropriate security measures to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are allowed to access personal information, and they may only access it for permitted business functions. We also use technology to protect your information, including encrypting sensitive personal information that is transferred to or from our systems.
In general, we keep your information for as long as we need it to carry out the purposes described in this Privacy Notice, and as necessary to comply with our records-management policies and laws that apply to us. We also keep your information when we need to comply with other legal obligations we might have, such as in connection with a lawsuit, complaint, or investigation.
While we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it. Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our services and provision of information to us is at your own risk.
Our website may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linked to our website are not covered by this Privacy Notice. We are not responsible for the privacy policies of other websites to which our website links.
8. Changes to this notice
We reserve the right to modify or change this Privacy Notice at any time. When we make a material change to this Privacy Notice, we will inform you by changing the date on this page noting when the Privacy Notice was last updated.
9. Contact us
For questions regarding this Privacy Notice or to submit any of the requests mentioned above relating to your personal information, contact us using any of the following options:
Skillkeepr, Inc.
990 Suite 503 Biscayne Blvd
Miami, Florida 33132
Email: privacy@skillkeepr.com
Tel: + 1 416 857 3979
10. Privacy chart
| Legal Category* | Examples of Information Collected | Source | Purposes for Collection and Use | Sharing with Third Parties for a Business Purpose |
|---|---|---|---|---|
| A. Identifiers. | Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
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| B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information (for organization accounts only, and only in rare circumstances), medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
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| C. Protected classification characteristics under California or federal law | Age (40 years or older), race, color ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
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| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. (this refers to your activities and interactions with our products and services) |
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| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns |
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| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, device type. |
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| G. Geolocation data. | Physical location or movements. |
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| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. |
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| I. Professional or employment-related information. | Current or past job history or performance evaluations. |
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| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
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| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
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| L. Sensitive Personal Information | Social Security number, driver’s license, state/government ID card, passport number, account login, financial account, debit/credit card number (w/ access code), credentials allowing access to an account, precise geolocation, race or ethnic origin, religious or philosophical beliefs, or union membership, contents of personal communications, genetic data, biometric data, health data, and sex life or sexual orientation |
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*We may also collect your information to comply with laws or regulations or with legal requests that don’t fit into one of the categories we’ve described for you, or to enforce our rights, prevent fraud, and protect our systems, users, and customers.
+ In the preceding twelve (12) months, we have shared the following categories of personal information about you for business purposes:
A. Identifiers.
B. California Customer Records Categories
C. Protected Classifications
D. Commercial Information
E. Internet Activity
F. Geolocation
G. Professional or Employment-Related Information
H. Sensitive Personal Information