SKILLSTRADER GENERAL PRIVACY NOTICE

Collectively, SkillsTrader Inc. is referred to in this General Privacy Notice as “SkillsTrader”, “we,” “us,” or “our”.

SkillsTrader is committed to protecting your personal and sensitive information and your right to privacy. If you have any questions or concerns about our approach to privacy, or our practices with regards to your personal and sensitive information, please contact us.

This GENERAL PRIVACY NOTICE governs our privacy practices applicable to our Platform (www.skillstrader.com). Please read this General Privacy Notice carefully as it will help you make informed decisions about sharing your personal and sensitive information with us.

As a visitor to our Platform, you can browse to find out more about us. You are not required to provide us with any of your personal information as a visitor.

PERSONAL AND SENSITIVE INFORMATION

We collect your personal and sensitive information when you register with us as a Platform user, when you express an interest in obtaining information about us, our services and/or products or when you expressly provide us with your personal information.

Generally, you control the amount and type of personal information you provide to us when using our Platform. The personal information that we collect depends on the context of your interaction with us and the Platform, the choices you make and the features that you use. The categories of personal and sensitive information that we collect can include the following:

LEGAL NAMES POSTAL ADDRESS(ES) EMAIL ADDRESS(ES)
PHONE NUMBER(S) PHOTO(S) SCHOOL(S) ATTENDED
MOBILE DEVICE IDENTIFICATION DATA INTERNET PROTOCOL ADDRESS(ES) OCCUPATION(S)
EDUCATION EMPLOYMENT HISTORY CURRENT EMPLOYMENT
COMPETENCIES ENDORSEMENTS ASSESSMENT RESULTS
MILITARY STATUS VISIBLE MINORITY STATUS PROTECTED GROUP STATUS
AUTOMATICALLY COLLECTED INFORMATION (INCLUDING SENSITIVE INFORMATION )

When you use our Platform, we automatically collect certain sensitive information by the interaction of your mobile device or web browser with our Platform. Such information is typically considered non-personal information, but we acknowledge that it is still sensitive information. We also automatically collect the following information:

PLATFORM SCREEN VISITS PLATFORM PAGES VISITS BUTTON CLICKS MOUSE MOVEMENT SCROLLING AND WAYFINDING
COOKIES

Our Platform uses "Cookies" to identify the areas of our Platform that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to personalize the Content that you see on our Platform. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Platform correctly or at all. We never place personal information in our Cookies.

LOG INFORMATION

We automatically receive information from your web browser or mobile device. This information includes the name of the website or application from which you entered our Platform, if any, as well as the name of the website or application to which you're headed when you leave our Platform. This information also includes the Internet protocol address of your computer/proxy server that you use to access the Internet, your Internet provider name, web browser type, type of mobile device, and computer operating system. We use all of this information to analyze trends among our visitors and users to help improve our Platform.

PAYMENT INFORMATION

We provide paid products and/or services on our Platform. In that case, we use third-party services for payment processing (otherwise known as ‘payment processors’).

We will not store or collect your payment card details on our Platform. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their respective privacy policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

We collect payment information through our payment processors. All payment information is securely stored by our payment processors and we do not have access to your sensitive information, such as credit card numbers or security codes.

INFORMATION REGARDING YOUR DATA PROTECTION RIGHTS UNDER CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

We are pleased to maintain a comprehensive CCPA Privacy Notice for our valued California-resident Platform visitors and users. Please review our SKILLSTRADER CALIFORNIA PRIVACY NOTICE.

INFORMATION REGARDING YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

For the purpose of this SKILLSTRADER GENERAL PRIVACY NOTICE, we are a GDPR Data Controller of your personal information.

If you are from the European Economic Area (EEA), our legal basis for collecting and using your personal information, as described in this SKILLSTRADER GENERAL PRIVACY NOTICE, depends on the information we collect and the specific context in which we collect it. We may process your personal information because:

  • We need to perform a contract with you, such as when you use our services;
  • You have given us permission to do so;
  • The processing is in our legitimate interests and it's not overridden by your rights;
  • For payment processing purposes; and
  • To comply with the law.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the personal information we have on you;
  • The right of rectification;
  • The right to object;
  • The right of restriction;
  • The right to data portability; and
  • The right to withdraw consent.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

SERVICE PROVIDERS

We may engage third party companies and individuals to facilitate our Platform ("Service Providers"), to provide our Platform on our behalf, to perform Platform-related services or to assist us in analyzing how our Platform is used. These Service Providers may have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

GOOGLE ANALYTICS

Google Analytics is a web analytics service offered by Google that tracks and reports Platform traffic. Google uses the data collected to track and monitor the use of our Platform. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having your activity on our Platform made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

CONTACTING US

If you have any questions regarding our privacy and data collection practices, please don’t hesitate to contact us at www.skillstrader.com

SKILLSTRADER PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This SKILLSTRADER PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“California Privacy Notice”) supplements the information contained in our SKILLSTRADER GENERAL PRIVACY NOTICE.

Collectively, SkillsTrader Inc. is referred to in this California Privacy Notice as “SkillsTrader”, “we,” “us,” or “our”. This California Privacy Notice applies solely to persons who reside in the State of California and are referred to herein as “users”, “you” or “your”.

We have adopted this California Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice.

Information That We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or electronic device (“personal information”). In particular, we may collect, have collected or shall continue to collect, the following categories of personal information from users. We have collected personal information from users within the last twelve (12) months:

CATEGORY EXAMPLES MAY COLLECT, HAVE COLLECTED OR SHALL COLLECT
YES/NO
A. Identifiers. A 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. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A 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, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
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). YES,
if disclosed by user
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
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, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. YES
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. YES
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Users shall note that personal information does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information;
  • Information excluded from the CCPA's scope, such as:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act(FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our users or their agents;
  • Indirectly from our users or their agents;
  • Directly and indirectly from activity on our platform (www.skillstrader.com).
  • From third-parties that interact with us in connection with the services we offer in person and from activity on our platform.
Using Personal Information

We may use or disclose the personal information that we collect for one or more of the following business purposes:

  • To fulfill or meet the business purpose for which the personal information was provided;
  • To provide users with information, products or services that you request from us;
  • To provide users with alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to users;
  • To carry out our obligations and enforce our rights arising from any contracts entered into with users;
  • To present and to improve our platform;
  • For testing, research, analysis and development of our platform;
  • As necessary or appropriate to protect the rights, property or safety of us, our users or others;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A Category B Category C Category D Category F
Category G Category I Category J Category K

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Our service providers. (Airtable, Microsoft Azure, Facebook, Google Analytics, Hotjar, Stripe, Sendgrid, Mailchimp, Twilio)
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers resident in the State of California with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable user request, we will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting or selling that personal information;
  • The categories of third parties with whom we share that personal information;
  • The specific pieces of personal information we collected about you (also called a data portability request);
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable user request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another user to exercise free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation;
  • Make other internal and lawful uses of that information that are compatible with the context in which a user provided it.
Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by visiting www.skillstrader.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable user request related to your personal information. You may also make a verifiable user request on behalf of your minor child.

You may only make a verifiable user request for access or data portability twice within a 12-month period. The verifiable user 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.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable user request does not require you to create an account with us.  We will only use personal information provided in a verifiable user request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable user request within 45 calendar days of its receipt. If we require more time (up to 90 calendar days), we will inform you of the reason and extension period in writing. 

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable user request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable user request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services;
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us:

Website: www.skillstrader.com
Email: info@skillstrader.com