PRIVACY POLICY

Last Updated: November 8, 2023

Thank you for choosing to be part of our community. We are committed to protecting your personal data and respecting your privacy rights at Skillsun. This Privacy Policy (“Policy”) explains what personal data is collected and how it is used by Skillsun Inc. (collectively, “Company“, “ we”, “us”, or “our”) when you access or use the Skillsun as well as any other website, mobile website or mobile application related or linked to Skillsun.com (collectively, the “Platform”).  This Policy and other documents referenced in it apply to all personal data collected through our Platform and any related services, sales, marketing or events.

Based on our terms, personal data includes but not limited to email addresses, phone numbers, mailing addresses, payment card information, account numbers, and government-issued identification numbers. We are based in Canada and operate globally. We apply local rules regarding the use and sale of personal data, as well as the choice to receive communications from us and our affiliate companies.  This Policy generally describes our collection and use practices.

We hope you take some time to read through this Policy carefully, because it is important. If there are any terms in this Policy that you do not agree with, please immediately discontinue use of the Platform and our services. If you have any questions or concerns about our collection or use of your information, please contact us at privacy@skillsun.com.

1. WHAT PERSONAL DATA DO WE COLLECT?
2. Personal data you disclose to us

We collect personal data you voluntarily provide to us when registering to use the Platform, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Platform or otherwise contacting us.

The personal data we collect depends on the context of your interactions with us and the Platform, the choices you make and the products and features you use. The personal data we collect may include the following:

Name and Contact Data. We collect your first and last name, email address, mailing address, phone number, and other similar contact data.

Credentials. We collect usernames, passwords, password hints, and similar security information used for authentication and account access.

Employment, Resume, CV and other Job-Related Data. We collect the employment, resume, CV and other job-related data that you submit to us or provide us access to in connection with the Platform.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our third-party payment service providers and you should review their privacy policies and contact the payment processor directly to respond to your questions.

Social Media Login Data. We might provide you with the option to register using social media account details, like your Google, LinkedIn, Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section “SOCIAL LOGIN.”

All personal data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal data.

2. Data automatically collected

We automatically collect certain information when you visit, use or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. This information is primarily used to maintain the security and operation of the Platform, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and other/similar technologies.  This information may include what URL you visited before visiting our Platform, how long you spend on a particular page, and how you navigate our Platform.

3. Data collected from other sources

We and our affiliates generally share personal data with each other so that we can provide our services to you.  We also may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties. 

Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).  When you choose to, for example, obtain feedback on a resume through one of our third-party marketing partner sites, your contact information and resume will be sent to us.

1. DO WE COLLECT DATA FROM MINORS?

Our Platform is not directed to minors and we do not intend to collect personal data from children under the age of 18. Therefore, we recommend that parents or legal guardians be involved in the online activities of their children to prevent the collection of their personal data without parental consent. If you believe that we inadvertently have collected personal data about your child, please contact us at privacy@skillsun.com and we will promptly delete or anonymize this information.

1. HOW DO WE USE YOUR PERSONAL DATA?

We use personal data collected through our Platform for a variety of business purposes described below. We process your personal data for these purposes in reliance on our legitimate business interests, to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We use the information we collect or receive:

• To facilitate account creation and logon process. We use information you provide to create an account with us. If you choose to link your account with us through a third-party account (such as your Google or LinkedIn), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below “SOCIAL LOGIN” for further information.
• To send administrative information to you. We may use your personal data to send you information about products or services you have purchased and/or information about changes to our terms, conditions, and policies.
• To fulfill and manage your orders for services. We may use your information to fulfill and manage your orders for services, subscriptions, and payments, and to address any issues with services provided through the Platform. Our services may include automated decision making and analysis technologies which are used at your request. Our services may also include distributing your resume, CV, and other related information to third party job sites with your consent and at your request.  Should you elect to receive such services, your information shall be governed by and subject to the privacy policy on the respective sites to which your information is sent.  We are unable to effectuate any changes or deletions to your information on such sites once your information has been sent and any communications regarding your information on such sites must be made with those sites directly.  
• To deliver job alerts via email. We may use your email address and job-related preferences to provide you with email job alerts when you sign up for such service. You may unsubscribe from such alerts using the unsubscribe link in such emails.
• To post testimonials. We post testimonials on the Platform that may contain personal data. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at privacy@skillsun.com and be sure to include your name, testimonial location, and contact information.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences. These communications may include information about new products, services, or features. You can opt-out of our marketing emails at any time (see the section “YOUR PRIVACY RIGHTS” below).
• To deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• To request feedback. We may use your information to request feedback and to contact you about your use of our Platform so that we can improve our products and services and develop additional products and services to better serve our users.
• To develop our products and services.  We may use your information to further develop our existing products and services or to develop new products and services.
• To protect the Platform, us, and others. We may use your information as part of our efforts to keep the Platform safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse.
• To enforce our terms, conditions and policies.  We may use your information to ensure you and others are complying with our terms, conditions and policies, including providing your information to law enforcement if we believe it is appropriate to do so and using your information in connection with legal proceedings brought by us or against us.
• To respond to legal requests and comply with applicable law. If we receive a subpoena, discovery request, or other legal request, we may need to review and evaluate your information and potentially provide your information in response to the request.  We may also need to use your information as needed to comply with applicable laws and regulations.
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Platform, products, services, and your experience.

 

1. WILL YOUR PERSONAL DATA BE SHARED?

Yes, your personal data will be shared between Skillsun Inc. In addition, we may share your personal data with the following categories of third-party service providers for one or more of the purposes described above.

• Chat service providers
• Content optimization service providers
• Invoice and billing service providers
• Social media companies to which you enable access
• Software service providers that parse and match resumes with job postings
• Email job alert providers
• Website and application analytics providers
• Website hosting providers
• Website testing and optimization service providers

In addition, we may share your information with the following types of marketing and advertising service providers.  Depending on your location of residence, you may have certain rights regarding sharing of your information for marketing purposes.  For more information or, where applicable, to opt out of such sharing, you can email us at privacy@skillsun.com.

• Advertising, direct marketing, and lead generation providers
• Social media site advertising providers
• Targeted advertising platforms

 

Where we believe it necessary or appropriate to do so, we may share your information with: law enforcement; government agencies or regulators; courts; parties to legal proceedings in which a subpoena or legal request has been propounded to which such information would be responsive.  In those circumstances we will make reasonable efforts to disclose only that information that is relevant to the reason for disclosure and to protect the privacy of such information to the extent reasonably possible. 

Finally, we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and any similar tracking technologies to collect or store information. You can refuse or disable certain cookies while using the service.

1. SOCIAL LOGIN

The Platform, one of our websites or mobile applications may offer you the ability to register and login using your third-party social media account details (like your Facebook or LinkedIn logins). If you choose to do this, we will receive certain profile information about you from the social media company. The profile information we receive may vary depending on the social media provider, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive for the purposes that are described in this Policy. For more information about your rights with respect to this information, please see the section “YOUR PRIVACY RIGHTS” below.

Please note that we do not control, and are not responsible for, other uses of your personal data by the social media company. We recommend that you review their privacy policy to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and applications.

1. KEEPING YOUR INFORMATION

We will only keep your personal data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as business records, tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it and we will make such determination based on applicable laws.

1. YOUR INFORMATION SAFETY

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we collect, receive, use, or store, including measures designed to protect data transferred to different countries for use or processing in accordance with this Privacy Policy. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal data, transmission of personal data to and from the Platform is at your own risk. You should only access the Platform within a secure environment.  If you believe your account has been compromised or suspect any type of data breach, please contact us at privacy@skillsun.com.

1. YOUR PRIVACY RIGHTS

The rights described in this section apply to all users. As noted above, if you reside in a particular state or country, you may have additional rights as required by applicable law.

Account Information

If you would at any time like to review or change the information in your account to make sure it is accurate and up to date, please log into your user account and update the information as needed.

If you terminate your subscription or account with us, then we will deactivate your account. However, we retain a copy of all resumes created by us or on the Platform, and some additional information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, or comply with applicable legal requirements. We try to minimize the data we retain to only that which is necessary for these purposes.

Opt Out of Email Marketing:

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. Even if you opt out of marketing emails, we may still send you service-related emails that are necessary for the administration and use of your account.

1. POLICY UPDATES

We may update this Policy from time to time. The updated version will be indicated by the “Last Updated” date and the updated version will be effective as soon as it is accessible. We encourage you to review the posted Policy frequently to stay informed about how your information is being used.

1. CONTACT US ABOUT THE POLICY

If you have questions or comments about this Policy, you may contact us by email at privacy@skillsun.com.

EUROPEAN ECONOMIC AREA RESIDENTS NOTICE

We offer our Platform and services within the European Union and therefore the General Data Protection Regulation (“GDPR”) applies. This notice applies to you if you are resident in the European Economic Area (“EEA”: the countries of the European Union as well as Norway, Liechtenstein and Iceland) (“GDPR notice”).

Therefore, if you are located in the EEA, the general considerations in the Policy and the considerations specifically set out in this GDPR notice will apply. If there is a conflict between the Policy and the GDPR notice and this GDPR notice applies to you, then the GDPR notice will prevail.

Unless otherwise specified, definitions in this EU Supplemental Terms will have the same meaning as the definitions used in the Terms of Use. If you have any questions or concerns about our collection or use of your information, please contact us at privacy@skillsun.com.

Requesting for Consent

1. Collecting and sharing your personal data

As set out in the Policy, we may collect your personal data from other sources and we may share your personal data with affiliated companies, group companies and subsidiaries, third-party services providers, and marketing partners. In these cases and to the extent that the receiving party is not a processor on our behalf, we will only collect or share your personal data if we have obtained your consent. This consent is obtained for example via a consent banner or a cookie banner depending on the receiving party.

2. Marketing purposes

We will not use your electronic contact details for marketing purposes, unless you are our customer or meet another exception under the applicable telecommunications laws. As mentioned in the Policy, you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send (this is also called ‘OPT OUT’). If you are not our existing customer, we will ask for your consent to send direct marketing messages (this is also called ‘OPT IN’).

For the underlying processing of your personal data for marketing purposes, we may process your personal data based on our legitimate interest, except when your interests or your fundamental rights and freedoms outweigh our interests. This legal basis is referred to below as ‘legitimate interest’.

3. Special categories of personal data

Our Platform does not intend to collect special categories of personal data, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs. However, we cannot fully guarantee that we will not collect such data if you provide it to us (for example, in your resume). We will not use it for purposes other than creating your resume.

Additional Privacy Rights

If you are a resident of the EEA, you may invoke a number of privacy rights additional to those mentioned in the Policy, which are the right to review or change the information in your account to make sure it is accurate and up to date. The additional rights include:

Right to Erasure. You generally have a right to erasure; however, we may not always erase your personal data because sometimes the processing is still necessary: for example, for complying with statutory obligations or for lodging, exercising or substantiating legal claims. Therefore, we will weigh your interest in having your personal data erased against the necessity of maintaining the personal data for other legitimate interests. Regarding the deactivation of your account we refer to the information mentioned in the Policy.

Right to Restriction of Processing. Under certain circumstances, you may have us restrict the processing of your personal data. For example, if the accuracy of your personal data are contested.

Notification of Rectification, Deletion or Restriction. Unless it is impossible or involves a disproportionate effort, we will inform the recipients of your personal data about rectification, deletion or restriction of processing.

Right to Data Portability. Under certain circumstances, you may request us to transfer your personal data to another party.

Right of Objection. Furthermore, under certain circumstances you may object to the processing of your personal data by us (or third parties engaged by us). For example, you may object to the use of your personal data for marketing purposes.

Right to Withdraw Consent. If we have requested your consent for data processing, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing prior to the withdrawal.

Right of Complaint. If you believe that the processing of your personal data violates applicable laws and regulations, please contact us at privacy@skillsun.com. We will always try to find a solution together. Should this not be possible, you can lodge a complaint with the Dutch Data Protection Authority, or any other competent authority in the European Union, or to take legal action.

Exercising your rights

You can submit your request(s) for exercising these rights to us at privacy@skillsun.com, please provide your name, telephone number, and type of request. To protect your privacy and security, we will take reasonable steps to verify your identity before responding to your request(s). Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal data. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information we in our records to verify your identity. This is a security measure to ensure that personal data are not disclosed to someone who has no right to receive it.

We will respond to your request as soon as possible, and no later than one month from receipt of your request. In doing so, we will also assess whether, and if so to what extent, we can or must comply with your request under the law. If a longer period of up to two months is needed, we will inform you within one month of receipt of the request. The submission and processing of your request is free of charge, unless your request is manifestly unfounded or excessive, in particular because of a repetitive character.

Representative In The EEA

If you have questions or comments about this GDPR notice, you may contact our Data Protection Officer (DPO) by email at privacy@skillsun.com and our representative in the EEA, which is established in the Netherlands:

U.S. RESIDENTS NOTICE

This Notice provides more information about specific disclosures and rights we provide to residents of the U.S. in accordance with U.S. law.

Sensitive Personal Information. Some types of personal information are subject to a heightened level of protection under data privacy laws. These types of personal information are called “sensitive personal information” and include social security numbers, driver’s license numbers, passport numbers, precise geolocation data, racial or ethnic origin information, and genetic data. If and to the extent we collect, receive, or process sensitive personal information of Platform users, potential Platform users, or website visitors, we apply security measures designed to protect such information. We do collect or receive certain sensitive personal information from job applicants and employees, which is addressed in a separate notice.

Categories of Information Disclosed

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected characteristics information.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category I: Professional or employment-related information.

Category J: Education information.

Category K: Inferences drawn from other personal information.

Categories of Information “Sold”

We do not sell your personal data for a monetary fee; however, some U.S. privacy laws define a “sale” very broadly such that it may include our sharing of your personal data with certain third parties if we receive anything of value in return.  In that regard, we share your personal data with certain third-party marketing partners and in exchange we receive the ability to market or offer our products and services through their websites and applications.  This may be considered a “sale” under some laws.

The personal data that may be shared or sold in this context is: your name; email address; other contact information; and information obtained through cookies about, for example, your location, the website that directed you to our Platform, how you navigate our sites, and what purchases you make. Other than these third-party marketing partners, there are no other third parties to which we will sell your personal data.  

Do-Not-Track Features

Many web browsers and some mobile operating systems and mobile applications include a “do-not-track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  We will update this Policy if that changes in the future.

Additional Privacy Rights

Right to Information.  Subject to certain limits, you may ask us to provide the following information: 

• The categories of personal information we collected about you;
• The categories of sources from which the personal information was collected;
• The business or commercial purpose for collecting the personal information;
• The categories of third parties with whom we shared the personal information;
• The specific pieces of personal information we collected about you; and
• Whether your personal information was sold or shared (“shared” in this context means sharing for the specific purpose of cross-context behavioral advertising) and, if so, the categories of personal information that was sold or shared, the categories of third parties to which your personal information was sold or shared, and the business purpose for the sale or sharing.

Right to Delete.  You also have the right to ask us to delete any personal information that we have collected about you, subject to certain limitations. We may deny your deletion request if the information is necessary for us or our service providers to, among other things, provide a service you requested, take actions reasonably anticipated in the context of our business relationship with you, perform a contract we have with you, detect and protect against security incidents or illegal activity, comply with a legal obligation, or exercise a right provided for by law. 

Right to Opt Out of Sale or Sharing.  Certain states provide residents with the right to opt out of the sale of personal information.  If you are a resident of a state that provides such right, you have the right to opt out of the sale of your personal information.  You may exercise this right by clicking on the “Do Not Sell My Personal Information – U.S.” link located at the bottom of our homepage or by submitting a request as described in the “Submission of Requests” section below. In addition, if you are a California resident, you have the right to opt out of the sharing of your personal information with any third party for the purpose of targeted advertising. You may exercise this right by clicking on the “Do Not Sell My Personal Information – U.S.” link located at the bottom of our homepage or by submitting a request as described in the “Submission of Requests” section below. 

Right to Nondiscrimination.  We will not discriminate against you if you exercise your privacy rights under any applicable privacy law, including by:

• Denying you goods or services.
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Providing you a different level or quality of goods or services.
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We are permitted under applicable law to offer you certain financial incentives that can result in different prices, rates, or quality levels, which are related to your personal information’s value.  Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Submission of Requests.  You may submit a request regarding your personal information by emailing us at privacy@skillsun.com – please provide your name, telephone number, and type of request (that is, a request for categories of information, a request for specific pieces of information, a request to delete, or a request to opt out the sale of your information).

What We May Need from You.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to someone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Verifying Your Identity: To protect your privacy and security, we will take reasonable steps to verify your identity before providing your personal information and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal information. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information we in our records to verify your identity, so that we can help protect your information.  

Requests from Authorized Agents:  You may designate an authorized agent to make a request for you.  If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.

Responses to Requests.  We will confirm receipt of your request within 10 business days of receipt and generally will respond to your request within 45 days of receipt.  If we need more time to respond, we will inform you of the reason and we may take up to an additional 45 days to respond.  

No Fee Usually Required.  You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.  

© 2023 Skillsun Inc.