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Last Modified in FEBRUARY 2021
collectively all information that you submit to INFINITE CREATION LTD via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below ( Cookies);
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK; the California Consumer Privacy Act, and the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).
the General Data Protection Regulation (EU) 2016/679;
INFINITE CREATION LTD
the company owner and operator of the Website
Means “Skillful”, “Us”, “We, “Our”
UK and EU Cookie Law
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or you
any third party that accesses the Website and is not either (i) employed by INFINITE CREATION LTD and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to INFINITE CREATION LTD and accessing the Website in connection with the provision of such services; and
Website or Site
the website that you are currently using, www.skillfulglobal.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
a.the singular includes the plural and vice versa;
c.a reference to a person includes firms, companies, government entities, trusts and partnerships;
d."including" is understood to mean "including without limitation";
e.reference to any statutory provision includes any modification or amendment of it;
For purposes of the applicable Data Protection Laws, INFINITE CREATION LTD is the "data controller". This means that INFINITE CREATION LTD determines the purposes for which, and the manner in which, your Data is processed.
Data We Collect
We collect personal information from you in order to provide our products, services, and customer support. These data may include the information you directly enter yourself and data from third-party platforms you connect with us. We also collect some data automatically like information about your device and the parts of our services you interact with or spend time using.
Our products, services, and customer support are provided through many platforms including but not limited to websites, mobile apps, email, and contact number (mobile or telephone). The specific platform and product, service, or support you interact with us may affect the personal data we collect.
We may collect the following Data, which includes personal Data, from you:
b.date of birth;
f.contact Information such as email addresses and telephone numbers;
g.demographic information such as postcode, preferences and interests;
h.financial information such as credit / debit card numbers, paypal;
i.IP address (automatically collected);
j.web browser type and version (automatically collected);
k.operating system (automatically collected);
l.a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
The Ways We Collect the Data
We collect Data in the following ways:
a.data is given to us by you ;
b.data is received from other sources; and
c.data is collected automatically.
Data Given to Us by You
INFINITE CREATION LTD through its Website will collect your Data from or about you depending on how you use our Services. Below are some examples to help you better understand the data we collect.
When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:
When you register with us and set up an account in order to use certain features or receive our products and services. When you create or update your account, we collect and store the data you provide like your email address, password, gender, and date of birth and assign you a unique identifying number (“Account Data”).
You can also choose to provide profile information like a photo, headline, website link, social media profiles, location, physical address, time zone, or other data. Your Profile Data will be publicly viewable by others.
Parts of the Services let you interact with other users or share content publicly, including by posting reviews, contract or job descriptions and attachments, asking or answering questions, sending messages to other users, or posting photos and videos or other work you upload. Such shared content may be publicly viewable by other depending on where it is posted.
Users Payment Data
If you make purchases, we collect certain data about your purchase such as your name as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address and post code. For security, INFINITE CREATION LTD does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
Data Received from Other Sources
We may obtain certain information through your social media or other online accounts if they are connected to your Website account. If you login via google, facebook, or another third-party platform or service, we ask for your permission to access certain information about the other account. For example, depending on the platform or service we may collect you name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday and list of friends or contacts.
Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
If you access or use our Service through a third-party platform or service, or click on any third-party links, the collection, use and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
Sweepstakes, Promotions and Surveys
Communications and Support
The data listed above is stored by us and associated with your account.
Data We Collected Automatically
When you access the Services, we collect certain data by automated means, including:
Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, language settings, time zone, domain, device plugins, and other systems data, and platform types (“System Data”).
Usage statistics about your interactions with the Services, including listings accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Services (“Usage Data”).
Approximate Geographic Data
An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.
We will collect your Data automatically via cookies, in line with the cookie settings on your browser. It is stored by us and associated with your account. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies"
In order to deliver certain products or services we may passively collect your GPS coordinates, where available from your device. Most modern devices such as smartphones will display a permission request when our platform requests this data.
How We Get a Data About You
We use tools like cookies, web beacons, analytics services and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
Cookies and Data Collection Tools
We use third-party browser and mobile analytics services like Google Analytics on the Services. These services use Data Collection Tools to help us analyse your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application was downloaded from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.
We use third-party advertising services like Facebook, Google’s ad services, and other ad networks and ad servers to deliver advertising about our Services on other websites and applications you use. The ads may be based on things we know about you, like you’re Usage Data and System Data, and things that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services, and may be tailored to your interests.
Depending on the types of advertising services we use, they may place cookies or other tracking technologies on your computer, phone, or other device to collect data about your use of our Services, and may access those tracking technologies in order to serve these tailored advertisements to you. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymised version of your email address (in a non-human-readable form) and content that you share publicly on the Services.
When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.
Our Use of Data
Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a.internal record keeping;
b.improvement of our Services, develop new products, services and features;
c.transmission by email of marketing materials that may be of interest to you;
d.contact for market research purposes, administer surveys and promotions
e.provide and administer the Services, including to display customised content and facilitate communication with other Users;
f.process your requests and orders for lessons, products, specific services, information, or features;
g.communicate with you about your account by:
·responding to your questions and concerns;
·sending you administrative messages and information, including messages, notifications about changes to our Service, and updates to our agreement;
·sending you information and in-app messages about the process of the contracts, rewards programs, new services, new features, promotions, newsletters, blogs, useful links, and other available information which you can opt out at any time;
·sending push notifications to your wireless device to provide updates and other relevant messages which you can manage from the “options” or “settings” page of the mobile app;
h.manage your account preferences;
i.facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
j.solicit feedback or reviews from Users;
k.learn more about you by linking your data with additional data through third-party data providers or analysing the data with the help of analytics service providers;
l.identify unique users across devices;
m.tailor advertisements across devices;
n.analyse trends and traffic, track purchases, and track usage data;
o.Advertise the Services on third-party websites and applications;
p.As required or permitted by law; or to comply with legal and regulatory obligations;
q.As we, in our sole discretion, otherwise determine to be necessary to ensure the safety and integrity or our users, employees, third parties, the public, or our Services.
r.We do not sell your information that you share with us to any third-party.
We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances.(see the section "Users’ Rights" below).
For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
a.soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
b.for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
c.if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section "Users’ Rights" below.
When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may use your Data to show you our adverts and other content on other websites. If you do not want us to use your data to show you adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).
Who We Share Your Data With
We share certain data about you to lessons providers or instructors; other students or other users in general; our business partners; analytics and data enrichment providers; your social media providers; companies who are helping us run promotions and surveys;and advertising companies who help us promote our Services.
We may also share your Data with the following groups of people for the following reasons:
a.any of our group companies or affiliates - to ensure the proper administration of the website's features and services ;
b.our employees, agents and/or professional advisors - to receive payments, to use the services and features of the website;
c.third party service providers who provide services to us which require the processing of personal data - to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly;
d.third party payment providers who process payments made over the Website - to enable third party payment providers to process user payments and refunds;
e.relevant authorities - for security and legal compliance; to facilitate the detection of crime or the collection of taxes or duties;
For security and legal compliance, we may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
·permitted or required by law;
·requested as part of a judicial, governmental, or legal inquiry, order or proceeding;
·reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
·required to detect, prevent or address fraud, abuse, misuse, potential violations of law (or rule or regulations), or security of technical issues;
·reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Agiyo Ltd, Skillful, our Users, employees, members of the public, or our Services.
Changes of Business Ownership and Control
We may also disclose Data to a prospective purchaser of our business or any part of it.
In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Keeping Data Secure
We will use technical and organisational measures to safeguard your Data, for example:
a.access to your account is controlled by a password and a user name that is unique to you.
b.we store your Data on secure servers.
c.payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
Technical and organisational measures include measures to deal with any suspected data breach. Unfortunately, however, no system can be 100% secured so we don’t not guarantee that the communications between you and us, the Services or any information provided to us in connection with the data we collect through the Services will be free from unauthorised access by third party. Your password is an important part of our security system and it is your responsibility to protect it. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
You have the following rights in relation to your Data:
a.Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b.Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c.Right to erase - the right to request that we delete or remove your Data from our systems.
d.Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
e.Right to data portability - the right to request that we move, copy or transfer your Data.
f.Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Transfers Outside the European Economic Area
Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.
We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.
To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.
Links to Other Websites
Accessing, Updating, and Deleting Your Personal Data
You can access and update your personal data that Skillful collects and maintains as follows:
·To update data you provide directly, log into your account and update your account at any time.
·To terminate your account, visit your profile settings page. If you have any issues terminating your account, email us at email@example.com .
·To request to access, correct, or delete your personal data, email firstname.lastname@example.org. Please allow up to 7 days for a response. For your protection, we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.
Our Policy Concerning Minor Children
We recognise the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children under 13 (or under 16 in the European Economic Area) should not register to use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.
Parents who believe that we may have collected personal data from a child under those ages can submit a request that it be removed to email@example.com
If you live in California, you have certain rights related to accessing and deleting your data as well as learning who we share your data with. If you live in Australia, you have the right to make a formal complaint with the appropriate government agency. Users outside of the United States should know that we transfer data to the US and other areas outside of the European Economic Area.
I.Users in California
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included in these rights are:
·“Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
·“Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
·“Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, we will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
To exercise any of these rights under CCPA, please email firstname.lastname@example.org. As part of the CCPA you may designate an authorised agent to make these requests on your behalf. For your protection, we may need to verify you and/or your agent’s identity before fulfilling your request.
Additionally, for more information about the personal information we collect and how we collect it, please see the sections above entitled “Data We Collect” and “How We Get Data About You.”
To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers who have access to your personal information, please see the sections above entitled “Our use of Data” and “Who We Share Your Data With.”
Most importantly, per the CCPA, INFINITE CREATION LTD does not sell your personal information or the personal information of any of our users.
As a California resident, you also have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to email@example.com.
Since the internet industry is still working on Do Not Track standards, solutions, and implementations, we do not currently recognise or respond to browser-initiated Do Not Track signals.
II.Users in Nevada
As is the case for all of its users, we do not sell its users’ personal information or personal data. Nonetheless, if you are a resident of Nevada, and would like to request that we do not sell your personal information, you can request to opt out of the sale of covered information by emailing firstname.lastname@example.org.
III.Users in Australia
If you are an Australia resident and you have a complaint, you may refer it to the office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by visiting www.oaic.gov.au; forwarding an email to email@example.com; telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001.
IV.Users Outside of the U.S.
If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in the United Kingdom (“UK”), Switzerland, and the European Economic Area (“EEA”) is transferred and stored outside those areas. Additionally, if you are located in the UK, EEA, or Switzerland, you also have the right to lodge a complaint with your data supervisory authority.
That data is also processed outside of the UK, Switzerland, and the EEA by us, or our service providers, including to process transactions, facilitate payments, and provide support services. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Skillful and its processors.
Modifications of this Policy
All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
·To log you into our Website
·To protect your security
·To help and detect and fight spam, abuse, and other activities that violate Skillful’s agreements
·To remember data about your browser and your preferences
·To remember your settings and other choices you’ve made
·To help us improve and understand how people use our Website
·To customize our Website with more relevant content
·To provide you with more relevant advertising
“Web beacons”, “tags” and “pixels” are electronic files used to record information about how you browse or use our Services. They also help us determine which email messages are opened and cookies help us see how you interact with us, like the links you click on.
Please note that where advertising technology is integrated into the Services, you may still receive advertising on other websites and applications, but it will not be tailored to your interests.
When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide its own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.
Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
This Website may place the following Cookies:
Type of Cookie
Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find a list of Cookies that we use in the Cookies Schedule.
For further information and support, you can also visit the specific help page of the web browser you are using:
·Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by consulting your browser’s support articles. If you decide to decline cookies, please note that you may not be able to sign in, customise, or use some interactive features in the Services.
You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.