Privacy Notice

Welcome to the website www.skilljar.com (part of the “Site,” as defined in the Membership and Use Agreement) of Skilljar Inc. (“we”, “us” or “our”). This Privacy Notice applies to the Site and Services (as defined in the Membership and Use Agreement) and describes the information that we collect on the Site and through the use of our Services, how we use it, how we protect it, and the choices you can make about your information.

The terms of this Privacy Notice apply to all users of the Site. If you do not agree with the terms of this Privacy Notice or the Terms (as defined in the Membership and Use Agreement), you should immediately stop using or visiting the Site.

Table of Contents
Information We Collect

We collect the following types of information in the manner described below.

  1. You may voluntarily provide us with information, including:
    • Your name, email address, and any other information that you provide in registering to use the Site and Services;
    • Information when you contact us; and
    • Any other information you voluntarily provide us within using the Site and Services, including comments and other content.
  2. We automatically collect other information about you, including:
    • Your Internet Protocol address;
    • Domain name of your Internet service provider;
    • Your approximate geographic location;
    • The Site pages that you visit and the time of your visits; and
    • Aggregated information that cannot be used to specifically identify you when you use or visit the Site and Services.
  3. We may combine all of the information we collect from or about you and use it in the manner described in this Privacy Notice.

The information we have collected that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular individual or device (“personal information”) within the last twelve months includes the following categories:

Category Examples
A. Identifiers. A real name, alias, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, profile image,job title, or employer.

Some personal information included in this category may overlap with other categories.
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data. Approximate physical location or movements based on Internet information. 

Personal information does not include: publicly available information from government records; deidentified or aggregated information; and information excluded from the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

You, directly and indirectly, are the source of the categories of personal information listed above.

How We Use Your Information

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

  • The purposes for which you provided it;
  • To administer and provide you with information about your account;
  • To send you information about your relationship with us;
  • To develop new services;
  • To process and respond to your inquiries and comments;
  • To personalize and enhance your experience using the Site and Services;
  • To generate and review reports and data about our user base and service usage patterns;
  • To compile aggregate data for internal and external business purposes;
  • To prevent fraud and abuse of the Site and Services and to otherwise protect members and visitors and our business;
  • To respond to law enforcement requests as required by applicable law, court order, or governmental regulations; 
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale of transfer of some or all of our assets; and
  • To administer, operate and improve the Site and Services and for internal business purposes.

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

How Your Information is Disclosed

Personal information may be disclosed to third parties for a business purpose in accordance with our Privacy Notice. We do not sell (as that term is defined by the CCPA) your personal information. 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 other purpose. Please note that a user may choose not to share certain information as described in Your Choices Regarding Your Information below. We may share personal information with the following categories of parties:

  1. Third Party Service Providers and Business Partners. We may use third party service providers and business partners to perform functions in connection with the Site and Services. Examples include account management ticketing and sending you notifications of key platform improvements via email. We only share information about you that they need to perform their functions and they are not allowed to use your information for any other purposes.
  2. Business Changes. If we become involved in a merger, acquisition, sale of assets, bankruptcy, reorganization, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may transfer your information to a third party or parties in connection therewith.
  3. Investigations and Law. We reserve the right to investigate any possible fraud and abuse on the Site and Services and enforce and apply the Terms. We may disclose information about you to third parties if we have a good faith belief that such disclosure is reasonably necessary to:
    • Take action regarding suspected illegal activities;
    • Enforce or apply the Terms;
    • Comply with the law or guidance and cooperate with government or law enforcement officials or private parties;
    • Protect our rights, reputation, safety, and property, or that of users or others;
    • Respond to claims and legal process (for example, subpoenas); and/or
    • Protect against legal liability.
  4. Anonymous Aggregated Information. We may share anonymous aggregated
    information relating to users of the Site and Services with affiliated or unaffiliated
    third parties.
  5. Cookies, Other Storage and Web Beacons. Please see Cookies, Other Storage and
    Web Beacons below.

In the past twelve months, we have disclosed the following categories of personal information for a business purpose: A. Identifiers; B. California Customer Records categories; F. Internet or other network activity; and G. Geolocation data. These categories of personal information were disclosed to the following categories of parties: Third party service providers and business partners.

Cookies, Other Storage and Web Beacons

We, along with our third party service partners and business partners, use cookies, other storage and Web beacons. These technologies are used for tracking, analytics and personalization and optimization of the Site and Services.

  1. Cookies: Cookies are small bits of information that are transferred to and stored in separate files within your computer’s browser. You can instruct your browser to stop accepting cookies. But if you do not accept cookies, you may not be able to use all portions or all functionality of the Site and Services.
    • Persistent cookies remain on the visitor’s computer after the browser has been closed.
    • Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer when they close the browser software.
  2. Other Storage: Flash cookies (also known as local stored objects) are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Flash cookies are stored in different parts of your computer from ordinary browser cookies. You can disable the storage of flash cookies. For additional information about managing and disabling flash cookies, please visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
  3. Web Beacons: Web beacons are small strings of code that provide a method for delivering a graphic image on a Web page or in an email message for the purpose of transferring data. You can disable the ability of Web beacons to capture information by blocking cookies.

We use Google Analytics to better understand who is using the Site and how people are using it. Google Analytics uses cookies to collect and store anonymous information such as Site pages visited, time spent on each Site page, Internet Protocol address and type of operating system used. We use this information to improve the Site. Please see https://tools.google.com/dlpage/gaoptout for information about Google Analytics Opt-out Browser Add-on.

Security

While we take reasonable measures to protect the information you submit via the Site and Services against loss, theft and unauthorized use, disclosure, or modification, we cannot guarantee its absolute security. Please keep your password secure. Do not share your password with anyone else. No Internet or email transmission is ever fully secure or error free. You should use caution whenever submitting information online and take special care in deciding with which information you provide us.

This Privacy Notice applies only to the Site and Services. The Site may contain links to third-party websites that we do not own or operate. We do not guarantee that we have endorsed or reviewed any links to third-party websites. The notice we describe here does not apply to third-party websites. We cannot control nor are we responsible for the privacy practices or content of these third-party websites. We suggest contacting these websites directly for information on their privacy policies.

Your Rights and Choices Regarding Your Information

You have rights to request access to specific information, data portability and deletion. These rights are not absolute, and in some instances, we may decline your request as permitted by law. Skilljar does not “sell” your personal information as that term is defined in the CCPA, and therefore your right to opt out of the sale of personal information under the CCPA does not apply. You have the right to exercise your rights free from discrimination as prohibited by the CCPA.

  1. Access to Specific Information and Data Portability. You can request the following information about how we have collected and used your personal information during the past 12 months:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • The business or commercial purpose for collecting personal information.
  • The categories of third parties with whom we share the personal information.
  • The categories of personal information that we disclosed for a business purpose.
  • The categories of third parties to whom the personal information was disclosed for a business purpose.
  • A copy of the specific pieces of personal information we collected about you (also called a data portability request).
  1. Deletion. You can request that we delete the personal information that we collect from you.

To exercise the access, data portability, and deletion request rights described above, submit a request to us by either: emailing us at [email protected] or visiting https://info.skilljar.com/contact-us. We will need to verify your identity to process your requests and reserve the right to confirm your California residency if you are making a request under the CCPA. To verify your identity, we may require you to log into your Skilljar account (if applicable), provide government identification, give a declaration as to your identity under the penalty of perjury and/or provide additional information.

Your authorized agent may make a request on your behalf upon verification of the agent’s identity and our receipt of a copy of the valid power of attorney given to your authorized agent.  If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.

You may only make a verifiable request twice within a twelve month period. We will not discriminate against you for exercising any of your rights regarding your information.

You have choices regarding the use of information on our Site and Services.

  1. Changing Your Information. To change your information, including keeping your information accurate, please contact us at [email protected]. We will take reasonable steps to change your information in our possession that you have submitted via the Site.
  2. Email Communications. To change your information regarding email communications, please unsubscribe from the footer of any communication or contact us at [email protected].
  3. Cookies, Other Storage and Web Beacons. Please see the Cookies, Other Storage and Web Beacons section above.
  4. Closing Your Account. You may close your account by contacting us at [email protected]. If the email account associated with your email address is not active, we may close your account on the Site without notice in our sole discretion.
EU Data Subject Rights
  1. Lawful Grounds. If you reside in the European Economic Area or Switzerland (collectively the “EU”), we rely on the following lawful grounds under the General Data Protection Regulation (“GDPR”) to process (collect, store, and use) your personal data: (a) it is necessary for the performance of a contract with you; (b) our or a third-party’s legitimate business interest; or (c) your consent. Our Subscribers determine the lawful grounds for the processing of personal data submitted through their use of our Services and we limit such processing to our Subscribers’ instructions.
  2. Data Transfer Notice. We are located in the United States and transfer your personal data for processing in the United States. We make the transfer to the United States in the absence of an adequacy decision because it is necessary for the performance of a contract with you, or with your explicit consent. We also use model contractual clauses with our Subscribers to provide adequate protection for the transfer and processing of your personal data in the United States.
  3. Individual Rights and Data Requests. We provide tools to our Subscriber to respond directly to data subject requests to access, transfer, rectify or erase their personal data, or to restrict or object to the processing of their personal data. You may also contact us at [email protected] to request access to, transfer of, and rectification or erasure of your personal data, or restriction of processing, or to object to processing of your personal data. Please specify the nature of your request and the information that is the subject of your request. We may require you to submit additional information necessary to verify your identity and status as an EU data subject. If we are processing your personal data for a Subscriber, we will forward your request to our Subscriber and assist the Subscriber in responding within 30 days. If you are a visitor to our Site, we will respond to your request directly within 30 days. If we are processing your personal data based upon the lawful ground of your consent, you have the right to withdraw your consent for such processing at anytime without affecting the lawfulness of processing based on consent before it is withdrawn. To withdraw consent, email us at [email protected].
  4. Retention. At a minimum, we will retain your personal data for as long as necessary for the purpose in which it was collected such as to perform a contract, for our or a third-party’s legitimate interest, or your consent.
Children

We do not knowingly collect personal information from an individual under age 13. If you are under the age of 13, please do not submit any personal information through the Site. If you have reason to believe that we may have accidentally received personal information from an individual under age 13, please contact us immediately at [email protected].

Data Retention

How long we retain your information depends on the type of data and the purpose for which we process the data. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

Changes to Privacy Notice

We reserve the right to update or modify this Privacy Notice at any time and from time to time. Please review this Privacy Notice periodically, and especially before you provide any information. This Privacy Notice was last updated on the date indicated below.

How to Contact Us

Please also feel free to contact us at [email protected] if you have any questions about this Privacy Notice. As noted above, please contact us at [email protected] with requests regarding your personal information.

California Shine the Light Law

Under California’s Shine the Light law, you may also ask companies with whom you have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may make one request each year by emailing us at [email protected] or writing us at Skilljar Inc., PO Box 22296, Seattle, WA 98122. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.

Last Updated: October 9, 2020

Last Reviewed: October 9, 2020