Please review the entire policy to learn the types of information Skills System gathers about you, how Skills System uses that your information, what your information is disclosed and to what third parties, and how Skills System safeguards your information.
1. Information Collected About You
(a) Personal Information and Non-Identifying Information
We may ask you for personally identifiable information when using the Site, for example, when registering as a User. This refers to information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your full name, email address, and any other information that could be used to personally identify you.
We also collect other information that you provide as part of any registration and the administration and personalization of your account with us that does not identify you (“Non-Identifying Information”). Non-Identifying Information includes, but is not limited to, your zip code (on its own) and individual preferences. Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your gender only or your viewing preferences).
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the features and functionality of the Site, to facilitate and complete transactions between you and Skills System, and to communicate with you.
We may also combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Users to attempt to provide you with a better experience, to improve the quality and value of the Site, and to analyze and understand how the Site is used.
(b) Email Newsletters and Blogs
At registration and at various times as you use the Site, you will be given the option of providing us with personal information in order to receive informational/promotional newsletters or blogs via email from Skills System and/or directly from third parties.
(c) Usage Data
When you visit the Site, including where you are just visiting without logging in, our servers or the third party servers that we retain automatically record information that your browser or device may send whenever you visit a website or use a similar application or online service. The information sent automatically by your device is referred to as “Usage Data.” This Usage Data may include information such as the manufacturer and model of your device; your Internet Service Provider (ISP); your device’s Internet Protocol (“IP”) address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; Site access times and dates, pages or areas of the Site that you visit, the time spent on those pages, and information you search for on the Site; and other statistics. Usage Data also includes geolocation data, which the Site collects and uses to facilitate search functionality, connectivity and communication.
We use this information for technical administration of the Site, including to monitor and analyze use of the Site, to increase the functionality and user-friendliness of the Site, and to better tailor the Site to Users’ needs.
Usage Data may be non-identifying or it may be associated with you. Whenever we associate Usage Data with Personal Information, we will treat it as Personal Information.
2. Collection of Information
We request certain information from you through the use of forms or emails when you initiate a transaction with us, or communicate with us through the Site.
(c) Usage Data
Usage Data are collected automatically by the Site’s servers and software. For example, because the Site automatically collects Usage Data for all Users that visit the Site, your Site session will be tracked. You agree that we may collect and use technical data and related information, including technical information about your device, system and application software, and peripherals, to maintain and support the Site generally.
Additionally, in some of our email messages, Skills System may use a “click-through URL” linked to content on the Site. When a User clicks onto one of these URLs, the User will pass through our server before arriving at the destination Web page. Skills System tracks this click-through data to help us determine User interest in certain subject matter and measure the effectiveness of these User communications. You can avoid being tracked in this way by not clicking text or graphic links in emails from Skills System.
Finally, we may use clear gifs or pixel tags, which are tiny graphic images, in order: (i) to advise us of what parts of the Site Users have visited, (ii) to measure the effectiveness of any searches Users perform, and (iii) to enable us to send emails in a format that Users can read and tell us whether such emails have been opened in order to ensure us that we are sending messages that are of interest to Users.
Some Web browsers may be configured to send Do Not Track signals to online platforms, or Users may use similar mechanisms, to indicate a User’s preference that certain web technologies not be used to track the User’s online activity. Skills System makes provides no guaranty that the Site will operate with such browsers.
3. Use and Sharing of Information by Skills System
The User information that Skills System collects may be added to our databases and used for business purposes, including for marketing and promotional purposes, for a statistical analysis of Users’ behavior, for product development, for content improvement, to customize the content and layout of the Site, obtain your feedback from you, to detect and defend against fraud and other threats to the Site, or conduct research and measurement activities. In addition, Skills System will, on occasion, send emails to you about the Site or any of its services or programs or about other information, programs or services offered or provided by third parties.
Skills System will not sell your personal information to third parties for their use without your consent.
Skills System ’s policy is not to share the User information it collects with third parties other than as specified below, or where a User expressly consents to our sharing of certain information with a third party. We may share User information with third parties under the following circumstances:
(a) Companies and contractors that work with Skills System
We may employ third party companies and contractors for any of the following: to facilitate the Site; to provide the Site or portions of the Site on our behalf; to perform related services, including without limitation, maintenance services, database management, fulfillment, web analytics, data analysis, research, email management and deployment and improvement of the features or functionality; or to assist us in analyzing how the Site is being used.
Skills Systems contractors sometimes have limited access to your information in the course of providing products or services to Skills System. We contractually require that our contractors not use or disclose your information for any purpose other than providing the limited service or function for Skills System.
(c) Third Party Websites
(d) Business Transfers
As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, information about you is often a transferred business asset. In the event that Skills System itself or substantially all of Skills System’s assets are acquired, information about our Users may be one of the transferred assets.
(e) Compliance with Law and Protection of Skills System and Others
We may release your information when we believe, in our sole discretion, that release is appropriate: to comply with the law, including but not limited to, in response to a subpoena served on Skills System; to enforce or apply the Agreement, including the Skills System Terms and Conditions and other applicable agreements, rules, and policies; to protect the rights, property, or safety of Skills System, our Users, or others; or to prevent activity that we believe, in our sole discretion, may be or may become illegal, unethical, or legally actionable (including exchanging User information with other companies and organizations for fraud protection).
(f) Aggregate Site Use Information
We may release aggregate User information (without revealing any Personal Information about you) to advertisers and other third parties in order to promote or describe use of the Site.
4. International Transfer
By accessing and using the Site, you acknowledge and agree that Skills System controls and operates all parts of the Site from its offices in the United States of America and that the Site is intended for use by Users located in the United States of America. Unless expressly stated to the contrary, Skills System makes no representation that the Site is appropriate or will be available for use in other locations.
5. Changing or Deleting Your Information
All Users who have created an account on the Site may review, update, correct or delete the Personal Information in their registration profile by contacting us as set forth below. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law or for legitimate business purposes.
6. Receipt of Communications and Opt-Out
If you would prefer not to receive marketing or promotional e-mails from us that may relate, for example, to new product or services or offerings, you may opt-out of receiving these communications by writing to us at [email protected] or by using the opt-out mechanism that is contained in an email, where applicable. Following your opt-out, please be aware that we may continue to contact you by email or postal mail or other means for administrative or informational purposes, including, but not limited to, follow-up messages regarding the administration of your account; any products, services, features or functions you have affirmatively enrolled in or registered to use; goods, services or products you have ordered; or other transactions you have undertaken across the Sites.
7. Your California Privacy Rights
California residents who have an established business relationship with Skills System may choose to opt out of Skills System’s disclosing personal information about them to third parties for marketing purposes. If you do not want us to share your personal information with such third parties, please send us your name, email address, street address and phone number to [email protected]. Your opt out request will be processed within 30 days of the date it was received.
8. Additional Information for Skills System Visitors from the European Economic Area (“EEA”)
If you are a Skills System user in the EEA, you can: (i) access personal information we have about you (we will try to provide information within 30 days of your request); (ii) have your personal information corrected or deleted (in most cases you can correct personal information you have submitted to us by going back to the specific Site, logging-in and making the desired change); (iii) in certain circumstances, you can object to our processing of your personal information and we will discontinue such processing unless we have compelling legitimate grounds to continue; (iv) withdraw consent previously provided (however a withdrawal does not affect the lawfulness of processing of your personal data that occurred prior to the date of withdrawal); or (v) if you believe that we have not complied with applicable data protection laws, you may lodge a complaint with your local supervisory authority. If you wish to inquire as to whether we maintain any of your personal information and if so, whether you wish to exercise any of those rights that are available to you with respect to such personal information, you may contact us as described in the Contacting Skills System About Your Personal Information or Privacy section below. We will respond to your request within a reasonable timeframe. Please understand that any of the actions above my affect, suspend or make it unable to provide any services to you on the Site.
We employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. For example, we use or require the use by out third party providers commercially reasonable security measures such as encryption and firewalls to protect User information.
Please note that no security system is impenetrable. Accordingly, we do not guarantee the security of our databases, nor that information you supply won’t be intercepted while being transmitted to us over the Internet or other network. Any information you transmit to Skills System, you do at your own risk. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting through the Site in the most expedient time possible and without unreasonable delay, as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
10. Children’s Privacy
We are committed to protecting the privacy of children. Users must be at least thirteen (13) years of age to access and use the Site. By using the Site, you represent and warrant that you are thirteen years of age or older and that you agree to and agree to abide by all of the terms and conditions of the Agreement. If Skills System believes that you are under the age of thirteen or that you are not old enough to consent to and be legally bound by the Agreement, Skills System may, at any time, in its sole discretion, and with or without notice: (i) terminate your access to or use of the Site (or any portion, aspect, or feature of them), or (ii) delete any content or information that you have posted through the Site.
12. Contacting Us
Skills System LLC
P.O. Box 3237
Westport, MA 0279
Revised: May 14, 2019