PRIVACY POLICY

Date of Last Revision: May 13, 2020

The Skills (“The Skills,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use and disclose information that identifies or is associated with you (“Personal Information”), and what choices you have with respect to Personal Information. This Privacy Policy applies to our websites including theskills.com, and any other website that links to this Privacy Policy (our “Websites”), and our mobile applications for iPhone, Windows or Android mobile devices (collectively, our “Services”).

The Skills is the controller responsible for the Personal Information we hold about you. If you have a question about this Privacy Policy or how we use information collected about you, we encourage you to contact us using the details set out in the Contact Us section below.

By accessing or using our Services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy and our Terms of Use.

Information We Collect
Our Use of Information
How We Share Your Information
Control Over Your Information
How We Use Cookies and Other Tracking Technology to Collect Information
Third-Party Tracking and Online Advertising
How We Store and Protect Your Information
Children’s Privacy
Links to Third-Party Websites and Services
Region-Specific Disclosures
Changes to This Privacy Policy
Contact Us
Additional EEA, Switzerland and UK Privacy Disclosures
Annex - Cookie Declaration

INFORMATION WE COLLECT

The Skills is a web-based platform and by its very nature will be accessing Personal Information for the purpose of providing its functions. Sometimes we collect information automatically when an individual interacts with our Services and sometimes, we collect information directly from an individual. At times, we may collect Personal Information about an individual from other sources and third parties, even before our first direct interaction.

We collect your Personal Information in a variety of ways:

Information you provide to us directly. We may collect Personal Information, such as your name, profile picture, phone number, location, email address, login credentials if you create an account, and subscription information when you when you register for our Services, sign up for our mailing list, enter a contest or sweepstakes, or otherwise communicate with us. We also collect Personal Information, such as payment method, through our third-party payment processors. We may also collect any communications between you and The Skills, and any other information you provide to The Skills, such as feedback information, information about your customer service interactions with us, classes in which you enroll, and user-generated content.
Data collected through the use of our Services. We collect information about how you use the Services, your actions on the Services, and content you post to the Services, including the discussion groups you belong to, your interaction with your friends and with others on the Services, and photos and videos you post to the Services, and any content you provide through in-app messages, chat, or other functionality ("User Content"). To share photos and video, we will access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in the "Settings" app of your device. Please remember that The Skills may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Services, you consent to the recording, storage and disclosure of such communications you send or receive for these purposes.
Information we receive from third party sites you connect to our Services. We may receive Personal Information about you from third parties and combine that with information we collect through our Services. For example, we may obtain information when you login through a third-party social network or authentication service, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain Personal Information with us, which could include your name, email address, address book and contacts, or other information. Similarly, when you interact with us through a social media site or third party service, such as when you like, follow or share The Skills content or User Content on Facebook, Twitter, Pinterest, Instagram or other websites, we may receive information from the social network including your profile information, picture, and user ID associated with your social media account, and any other information you permit the social network to share with third parties. If you permit the third-party social network to share your friends list or address book with us, we may use this information to let you know what your friends are doing on our Services, and to let your friends know what you are doing on our Services. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Services.
Location information. We may collect location information, including general geographic location based on IP address, or more precise location information when accessing our Services through a mobile device. We maintain location information only so long as is reasonable to provide the Services and then delete location data tied to your Personal Information. We may maintain de-identified location data for a longer period of time in order to analyze aggregate trends and metrics.

OUR USE OF INFORMATION

We may use your information, including your Personal Information, as follows:

To operate, maintain, and provide to you the features and functionality of the Services, including provide product support, product enhancements and other services to you related to our Services;
To provide you with products or services that you request or in which you express interest;
For billing purposes and to process your subscription choices;

To enable you to participate in interactive features of the Services (such as communications with other users);
To remember your information so you will not have to re-enter it during a subsequent visit; help you efficiently access your information after you sign in; recognize and contact you across multiple devices; provide, improve, test, enhance, update and monitor our Services; or diagnose or fix technology problems;

To improve, market or promote The Skills’ products and services, for research and product development, and to perform analytics;

To communicate directly with you, such as to send you email messages and push notifications in connection with our Services or your account (e.g., account verification, change or updates to features of our Services, technical and security notices). We may also use your information to permit you to communicate with others on our Services or on social media, or invite others to join our Services.
To customize the advertising and content you see;

To alert you to product upgrades, special offers, updated information and other new products and services offered by The Skills, our users and our third-party partners;

To respond to comments, questions or requests for customer service;

To display advertisements, including advertisements from third parties;
For any other purpose we may describe when you provide the information.

HOW WE SHARE YOUR INFORMATION

We may share your Personal Information in the instances described below. For further information on your choices regarding your information, see the Control Over Your Information section below.

Remember, our Services allow you to connect and interact with others. Your profile information, including your name, photo and other Personal Information you choose to make public, will be available publicly to other members of our Services by default when you create a profile, interact with others on our Services in public discussion groups, and post content to public spaces.

We may share your Personal Information with:

The public and other members of our Services. Your profile information and User Content you post to public areas of our Services, including public discussion groups, will be viewable by others on our Services and the public. Please do not provide Personal Information you would not want to be public. You may be able to control the visibility of some of your information and actions in your settings (see the Control Over Your Information section below);
Service providers. Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, contest fulfilment, web hosting, or providing analytic services;
Business partners. At your request or for purposes consistent with this Privacy Policy, we may disclose Personal Information to our third-party business partners to promote their products or services. We may also disclose your Personal Information to third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the official rules of the contest or sweepstakes. Additionally, we may also share your Personal Information with third party marketing or promotional partners, who may use your information for their own purposes as well as for the benefit of our marketing and promotional activities;
Within The Skills. We may share your information with other companies and brands owned or controlled by The Skills, and other companies owned by or under common ownership as The Skills, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies may use your Personal Information in the same way as we can under this Privacy Policy;
Business Transfers. We may disclose personal information as part of an organizational business transaction, such as a merger, sale of The Skills’ assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
Regulatory or Legal Requirements, Safety and Terms Enforcement. We may disclose your Personal Information to third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Use or to protect the security or integrity of our Services; and/or (c) exercise or protect the rights, property, or personal safety of The Skills, our visitors, or others.
Third parties at your request. For example, you may have the option to share your activities on our Services with your friends through email, text or on various social media sites;

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

CONTROL OVER YOUR INFORMATION

Profile and Data Sharing Settings. You may update your profile information, such as your first and last name, password, email address and profile photo, and may change some of your data sharing preferences through your settings page or by emailing us at support@theskills.com.

Access to your Device Information. We do not ask for access to your Device information.

How to control your communications preferences. You can stop receiving push notifications by changing your settings page. From time to time we may contact you with information about our products and services, including sending you email marketing messages and asking for your feedback on our products and services. If you are located in the European Economic Area (EEA), Switzerland or the United Kingdom (UK), we will only send you marketing messages if you have given us your consent to do so. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of our Services, and technical and security notices).

Modifying or deleting your information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacy@theskills.com. We may not be able to modify or delete your information in all circumstances. If you are ordinarily resident in the EEA, you will have rights under applicable law to access information about you, have that information rectified, deleted or transferred to another person, or restrict to or object to certain uses of that information. Please refer to the Additional EEA, Switzerland and UK Privacy Disclosures for further information about your rights and how to exercise them.

HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

We and our third-party partners automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, file information and similar technology (collectively, “tracking technologies”).

We and our third-party partners use tracking technologies to automatically collect usage and device information, such as:

Your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information.
We also collect information about the way you use our Services, for example, the site from which you came and the site to which you are going when you leave our Websites, the pages you visit, the links you click, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other actions you take on our Services.
When you access our Services from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system, brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Services and to understand more about our users by monitoring aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Websites. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
Additionally, we may collect a record of the videos and audio programs you have accessed on the Services, including titles, authors, date, time, duration of the content and the duration of your watching or listening.
Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

Cookies:

We use the following types of cookies:

Strictly necessary cookies. These cookies enable core functionality such as security, network management and accessibility. You may disable these by changing your browser settings, but this may affect how the Services function. The legal basis for our use of strictly necessary cookies is our legitimate interests, namely being able to provide and maintain our Services. Please see the Annex below for more information.

Functionality cookies. These enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. The legal basis for our use of functionality cookies is our legitimate interests, namely being able to provide and maintain our Services. Please see the Annex below for more information.

Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors to our Services, and to see how visitors move around our Services when they are using them. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily. If you are accessing our Websites with a European IP address, you have been asked to consent to the use of these cookies, and are free to deny your consent. Please see the Annex below for more information.

Targeting cookies. These cookies record your visit to our Services, the pages you have visited and the links you have followed. They are used to track visitors across our Websites. We will use this information to make our Websites and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose. If you are accessing our Websites with a European IP address, you have been asked to consent to the use of these cookies, and are free to deny your consent. Please see the Annex and the Third-Party Tracking and Online Advertising section below for more information.

Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our Services. These third parties are responsible for setting out their own cookie and privacy policies. Please see the Annex and the Third-Party Tracking and Online Advertising section below for more information.

We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our Services; (b) provide and monitor the effectiveness of our Services; (c) monitor online usage and activities of our Services; (d) diagnose errors and problems with our Services; (e) otherwise plan for and enhance our Services; and (f) facilitate the purposes identified in the Our Use of Information section below.

We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.

Please note that we link some of the Personal Information we collect through cookies with the other Personal Information that we collect about you and for the purposes described above.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Third-Party Tracking and Online Advertising below.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.

THIRD-PARTY TRACKING AND ONLINE ADVERTISING

Interest Based Advertising. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Services over time so that they may play or display ads on our Services, on other devices you may use, and on other websites, apps or services, including on Facebook. These third parties may collect information such as click stream information, browser type, time and date you visited the site, mobile device identifiers, app usage, and/or precise geolocation data and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, LinkedIn, Snapchat, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employee other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.

Cross-Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Services. We may also work with third party partners who employ tracking technologies, or the application of statistical modeling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.

Your Choices:

Cookies. If you would prefer not to accept cookies, most browsers will allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.

Blocking or deleting cookies may negatively impact your experience using our Services, as some features and services on our Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at: http://www.google.com/policies/privacy/partners. You can also view Google’s currently available opt-out options at: https://tools.google.com/dlpage/gaoptout.

Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe’s website or by clicking here. If you choose to delete Flash objects from our Services, then you may not be able to access and use all or part of our Services or benefit from the information and services offered.

Online advertising. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our Services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our Services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Google Analytics and Advertising. We use Google Analytics to understand the demographics of our users and how our users interact with our Services and to tailor our advertisements and content to you. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our Services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
Please note: Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

HOW WE STORE AND PROTECT YOUR INFORMATION

Data storage and transfer. Your information collected through our Websites may be stored and processed in the United States or any other country in which The Skills or its affiliates or service providers maintain facilities. If you are located in the EEA, Switzerland, the UK or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

Keeping your information safe. We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Websites. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

CHILDREN’S PRIVACY

The Skills does not knowingly collect or solicit any information from anyone under the age of 13 on our Services. In the event that we learn that we have inadvertently collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at privacy@theskills.com.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our Services may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

REGION-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

Your California Privacy Rights. If you are a California resident, California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please email us at privacy@theskills.com and provide your contact information to be added to our suppression list.
If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@theskills.com and provide your contact information to be added to our suppression list.
If you are a resident in the European Economic Area, Switzerland, or the United Kingdom, please see section below ADDITIONAL EEA, SWITZERLAND AND UK PRIVACY DISCLOSURES for further information about how we use your Personal Information, including the purposes for which we use your Personal Information, the legal basis we rely on for processing your Personal Information and your rights in respect of your Personal Information.

CHANGES TO THIS PRIVACY POLICY

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner, we will let you know on the web site and update the “Last Updated” date above. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Policy means that you are acknowledging and consenting to the changes.

CONTACT US

For any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@theskills.com.

Alternatively, inquiries may be addressed to:

Skills Annex Inc.

605 13th Street

Manhattan Beach, CA 90266

USA

ADDITIONAL EEA, SWITZERLAND AND UK PRIVACY DISCLOSURES

Last Updated: 5/13/2020

Unless otherwise expressly stated, all terms in these Additional EEA, Switzerland and UK Privacy Disclosures (the “European Privacy Disclosures”) have the same meaning as defined in the Privacy Policy.

SCOPE OF DISCLOSURES

The European Privacy Disclosures supplement the information contained in our Privacy Policy, but unlike the Privacy Policy, these European Privacy Disclosures apply only to our processing of your Personal Data where you are based in the European Economic Area (EEA), Switzerland or the United Kingdom (UK).

The Skills is the data controller responsible for the collection and use of such Personal Data.

PERSONAL DATA DISCLOSURES

When we use the term “Personal Data” in these European Privacy Disclosures, we mean any information relating to an identified or identifiable natural person.

Purposes and Legal Basis for Processing

We use the Personal Data we collect about you in the following ways:

Category of Personal Data	How We Use the Personal Data	Legal Basis for Processing
Contact and profile information, such as name, profile photo, phone number and email address.	We use this information to communicate with you, including sending service-related communications.	The processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
	We use this information to send you unsolicited marketing communications in accordance with your preferences.	We will only use your Personal Data in this way to the extent you have given us consent to do so.
	We use this information to deal with enquiries and complaints made by you relating to your use of our Services.	The processing is necessary for our legitimate interests, namely administering our Services and for communicating with you effectively to respond to your queries or complaints.
Data collected through the use of our Services, including information about how you use our Services, your actions on our Services, and content you post to our Services, including feedback through the Services.	We may use information about how you use and connect to our Services to present our Services to you on your device.	The processing is necessary for our legitimate interests, namely, to tailor our Services to the user.
	We may use this information to determine products and services that may be of interest to you for marketing purposes.	The processing is necessary for our legitimate interests, namely, to inform our direct marketing.
	We may use this information to monitor and improve our Services and business, resolve issues and to inform the development of new products and services.	The processing is necessary for our legitimate interests, namely, to monitor and resolve issues with our Services and to improve our Services generally.
Your preferences, such as preferences set for notifications and marketing communications.	We use this information to provide our Services to you in accordance with your choices.	The processing is necessary for our legitimate interests, namely ensuring our Services are displayed in accordance with the user's preferences.
	We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.	The processing is necessary for compliance with a legal obligation to which we are subject.
Subscription information. When you subscribe to our Services, we will collect confirmation of your subscription from the payment processor.	We use this information to record that your payment has been processed and to grant you access to the paid features of our Services.	The processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Location information, we do not collect information about your precise location (other than information you choose to provide us); however, your WiFi, wireless network triangulation, or your IP address may help us determine an approximate location.	Providing you with content that is more relevant to you based on your location.	We only process your Personal Data in this way to the extent that you have given us your consent.
Information provided by social networks you connect to our Services, including when you “Like”, follow or share The Skills content or User Content on Facebook, Twitter, Pinterest, Instagram or other sites. We also receive profile information, picture, user ID, and any other information associated with your social media account that you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.	We use this information to promote and market our Services and increase user engagement with our products and Services.	The processing is necessary for our legitimate interests, namely promoting our products and services and increasing user engagement with our products and services.
Information contained in communications between you and The Skills, including any information you provide when you contact us or interact with us directly, such as by participating in a contest or promotion, or submitting feedback or other information to us.	We use this information to respond to comments, questions or requests for customer service.	The processing is necessary for our legitimate interests, namely administering our Services and addressing your queries and concerns.
	We use this information to address any violations of our Terms of Use, or any other rules, regulations or policies relating to our Services.	The processing is necessary for the performance of a contract between you and us.
Information about how you access and use our Services, including usage and posting history, and your clicking and browsing patterns.	We use this information to operate, maintain and provide to you the features and functionality of our Services, to improve our products and services, for research and product development.	The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services.
Internet and network information, including device information, logs and analytics data.	We use this information to provide and monitor the effectiveness of our Services; monitor usage of and activities on our Services; diagnose errors and problems with our Services; otherwise plan for and enhance our Services; understand your activities when you use our Services to deliver ads and information about products and services that may be of interest to you.	The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services.
All Personal Information set out above.	We may use this information to comply with any professional or legal obligation to which we may be subject, such as disclosure of information to comply with a court order or at the request of a regulator.	The processing is necessary for the compliance with a legal obligation to which we are subject.
	We may use this information to facilitate our internal business operations that are put in place for compliance with our legal obligations.	The processing is necessary for our legitimate interests, namely the detection and prevention of fraud and the fulfilment of professional obligations.
	We may use this information to determine products and services that may be of interest to you for marketing purposes.	The processing is necessary for our legitimate interests, namely, to inform our direct marketing.

We use the Personal Data we automatically collect about you in the following ways:

Category of Personal Data	How We Use the Personal Data	Legal Basis for Processing
Information about how you access our Services. For example, the site from which you came and the site to which you are going when you leave our Websites, how frequently you access the Services, whether you open emails or click the links contained in emails, and whether you access the Services from multiple devices.	We or the third-party partners we use, may use the data collected through tracking technologies to: a) remember information so that you will not have to re-enter it during your visit or the next time you visit our Services; b) provide custom, personalized content and information, including targeted content and advertising; c) identify and contact you across multiple devices; d) provide and monitor the effectiveness of our Services; e) perform analytics and detect usage patterns on our Services; f) diagnose or fix technology problems; g) detect or prevent fraud or other harmful activities, and h) otherwise plan for and enhance our Services.	The processing is necessary for our legitimate interests, namely: to tailor our Services to the user and to improve our Services generally; to monitor and resolve issues; for marketing purposes; to communicate with users; to contact users; and for the detection and prevention of fraud. For more information on the legal basis for cookies, please see the Cookies section of the Privacy Policy.
Information about how you use our Services. For example, the pages you visit, the links you click, the ads you view and click on, your purchase and subscription information, your location when you access or interact with our Services and other similar actions.
Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a persistent device identifier or an Ad ID), and other such information.
Analytics information. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our Services and to understand more about the demographics and behaviors of our users.

You are not required to provide Personal Data to us, but you may need to provide certain Personal Data to us in order to use certain features and functionalities of our Services. If you choose not to provide us with such Personal Data, we may not be able to provide you with the applicable feature or functionality of our Services.

Data Retention

We retain Personal Data about you for as long as is necessary for the purposes set out in these European Privacy Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.

INTERNATIONAL DATA TRANSFERS

We may transfer Personal Data about you among us and to our subsidiaries or affiliates, as well as to the categories of third parties identified in the How We Share Your Information section of the Privacy Policy. Personal Data may be transferred to, stored and processed in a country other than the one in which it was collected, including, but not limited to, the United States.

When we transfer your Personal Data to another country, we rely on appropriate or suitable safeguards recognized under the GDPR including adequacy decisions, standard contractual clauses and the EU U.S. Privacy Shield program.

Adequacy Decisions

We may transfer Personal Data about you to countries that the European Commission has deemed to adequately safeguard Personal Data.

Standard Contractual Clauses

The European Commission has adopted Standard Contractual Clauses, which provide safeguards for Personal Data transferred outside of the EEA, Switzerland and the UK. We may use these Standard Contractual Clauses when transferring Personal Data from a country in the EEA, Switzerland or the UK to a country outside the EEA, Switzerland or the UK that has not been deemed to adequately safeguard Personal Data. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.

EU-U.S. Privacy Shield

The EU-U.S. Privacy Shield Framework (Privacy Shield) was designed by the U.S. Department of Commerce and the European Commission to ensure adequate protection for Personal Data transferred to a company certified under Privacy Shield. If we transfer any Personal Data about you from the EEA, Switzerland or the UK to a third party outside the EEA, Switzerland or the UK who is certified under Privacy Shield as set forth by the U.S. Department of Commerce, we may rely on such certification to ensure adequate protection for Personal Data so transferred.

YOUR PRIVACY RIGHTS

You have the following rights in relation to your Personal Data (subject to certain limitations at law):

Access	The right to obtain: confirmation of whether, and where, we are processing your Personal Data; information about the categories of Personal Data we are processing, the purposes for which we process your Personal Data and information as to how we determine applicable retention periods; information about the categories of recipients with whom we may share your Personal Data; and a copy of the Personal Data we hold about you.
Rectification	The right to correct or update any Personal Data about you that is inaccurate or incomplete.
Restriction of Processing	The right to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you.
Erasure	The right to request the deletion or erasure of Personal Data about you without undue delay if the continued processing of that Personal Data is not justified.
Portability	The right to obtain a copy of Personal Data about you in an easily accessible format and the right to transmit that Personal Data to another controller.
Objection to Processing	You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

Please note that if the exercise of these rights limits our ability to process Personal Data, we may not be able to provide our products or services to you, or otherwise engage with you going forward.

Right to Withdraw Consent

Where we rely on your consent for processing of your Personal Data, as identified in the Purposes and Legal Basis for Processing section above, you also have the right to withdraw your consent to such processing. You may withdraw your consent at any time by contacting us using the contact details at the end of these European Privacy Disclosures.

Submitting Requests

To submit a request, please contact us as set forth in the Contact Us section below. We may need to verify your identity before processing your request, which may require us to obtain additional Personal Data from you. In certain circumstances, we may decline a request to exercise the rights described above.

Right to Lodge a Complaint

If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority). If you are based in the EEA, Switzerland or UK, information about how to contact your local data protection authority is available here. However, we encourage you to first reach out to us by using the contact details set out in the Contact Us section below so that you have an opportunity to address your concerns directly and so that we may find a solution together before you do lodge a complaint.

UPDATES TO THESE DISCLOSURES

We may update these European Privacy Disclosures from time to time. When we make changes to these European Privacy Disclosures, we will change the "Last Updated" date at the beginning of these European Privacy Disclosures. If we make material changes to these European Privacy Disclosures, we will notify you by email to your registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

CONTACT US

If you have any questions or requests in connection with these European Privacy Disclosures or other privacy-related matters, please send an email to privacy@theskills.com.

Alternatively, inquiries may be addressed to:

Skills Annex Inc

605 13th Street

Manhattan Beach, CA 90266

USA

PRIVACY POLICY

INFORMATION WE COLLECT

OUR USE OF INFORMATION

HOW WE SHARE YOUR INFORMATION

CONTROL OVER YOUR INFORMATION

HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

THIRD-PARTY TRACKING AND ONLINE ADVERTISING

HOW WE STORE AND PROTECT YOUR INFORMATION

CHILDREN’S PRIVACY

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

REGION-SPECIFIC DISCLOSURES

CHANGES TO THIS PRIVACY POLICY

CONTACT US

ADDITIONAL EEA, SWITZERLAND AND UK PRIVACY DISCLOSURES

Annex - Cookie Declaration