This website, the related applications, portals, platforms, and services (collectively, “Site”) is brought to you by EdInvent, Inc. dba TrueSkills (“TrueSkills,” “we,” or “us”).

TrueSkills provides a digital badge and certificate platform to allow our users to create, manage, issue and share Credentials. This Privacy Policy (“Privacy Policy” or “policy”) explains how we collect, use and disclose the information we collect from those who use or interact with the Site and our Services (“you”), your choices about our collection and use of your information, and how we protect your information.

We may use and collect information in various ways, depending on who you are, and how you interact with us and our Site and Services. This Privacy Policy provides specific provisions for how we handle the data of our Customers, Recipients, Students, and Site Visitors, as well as general provisions that may apply to all.

We may, from time to time, update this policy to address new issues or changes to our Site and/or Services. In the event we make material changes to the use of personally identifiable information, we will attempt to provide you with notice of those changes. We reserve the right to revise this policy, with such revisions taking effect immediately upon the posting of the revised policy. Your use of the Site and Services after such posting constitutes your acceptance of those terms as revised.

BY USING THIS SITE, YOU REPRESENT, ACKNOWLEDGE AND AGREE THAT YOU ARE AT LEAST 18 YEARS OF AGE, OR IF YOU ARE UNDER 18 YEARS OF AGE BUT ARE AT LEAST 13 YEARS OF AGE (A “MINOR”), THAT YOU ARE USING THE SITE WITH THE CONSENT OF YOUR PARENT OR LEGAL GUARDIAN, WHO HAS CONSENTED TO THESE TERMS.  IN ADDITION, IF YOU ARE A MINOR USING THIS SITE, YOU MAY NOT SUBMIT ANY PERSONAL INFORMATION TO THIS SITE. IF YOU ARE NOT AT LEAST 13 YEARS OF AGE, YOU MAY NOT USE THIS SITE.

YOUR USE OF THIS SITE CONSTITUTES ACCEPTANCE BY YOU OF THIS PRIVACY STATEMENT.

1. DEFINITIONS
2. SCOPE
3. CUSTOMERS
4. STUDENTS
5. RECIPIENTS
6. SITE VISITORS
7. GENERAL PROVISIONS
8. YOUR PRIVACY CHOICES AND RIGHTS
9. SECURITY OF YOUR INFORMATION
10. INTERNATIONAL DATA TRANSFERS
11. RETENTION OF PERSONAL INFORMATION
12. CHILDREN’S INFORMATION
13. COPPA
14. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
15. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
16. OTHER PROVISIONS
17. CONTACT US

1. Definitions

Capitalized terms not defined in this Definitions section shall have the meaning set forth by applicable law when a citation is present.

“Agreement” means the underlying service agreement between TrueSkills and a School, Customer, or Recipient.

“Customers” means our customers(including, but not limited to, businesses, testing bodies, Schools, and teachers)who use our Services to issue electronic badges, certificates, or credentials(“Credentials”).

“Customer Data” means the personally identifiable information TrueSkills receives regarding Customers.

“Recipients,” means authenticated end users who use our Services to receive, manage, and display their Credentials.

“Recipient Data” means the personally identifiable information TrueSkills receives regarding Recipients.

“Services” means our services, which include, but are not limited to, those services and products offered on the Site, including those related to TrueSkills.com, credential.net, coursefinder.io, and any other offerings, collectively.

“School” means a K-12 local education agency, school, school district, that has purchased and is using Services pursuant to an Agreement with TrueSkills.

“Student Data” means the personally identifiable information TrueSkills receives regarding a student of a School.

“Student Recipients” means Recipients who are students of a School.

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2. Scope

This Privacy Policy applies to personal information processed by us, including on our websites, our online platform, and other online or offline offerings.

An Important Note: When our Customers use our Services to issue a Credential to a Recipient, we process the Recipient’s personal information provided to us by the Customer solely on the Customer’s behalf (in legal terms, we act as the Customer’s “data processor”). As such, our processing of Recipient personal information provided to us by the Customer is governed by the contracts we have with that Customer, not this Privacy Policy. If you have any questions or requests relating to data Customers share with us, you should direct them to the Customer. For information on how to contact us, please refer to “Contact Us” below.

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3. Customers

3.1. Data we collect from Customers.

We collect information directly from our Customers. For example, we will collect a Customer’s contact details when a Customer enters a contractual relationship with TrueSkills, creates an account on any of our Sites, or uses the Services. When a Customer sends us an email asking a question, signs up to receive our email newsletters, sends us a message or submits a form through our Sites or via email or otherwise, we will collect the information the Customer submits to us. We may also collect information from prospective customers through publicly available sources.

Customer Account and Billing. When a Customer signs up to use our Services or uses TrueSkills’s customer platform and related webpages, we collect information such as the Customer’s name, contact information, email address, payment card and billing information, the name and URL of the organization where you work, how many Recipients you expect to issue Credentials to in a year, your job title, any referral information, and any other information the Customer may choose to provide to us on the platform or during onboarding. We may also work with third-party vendors to process payments to or from our Customers on our behalf. These vendors currently include Stripe and HubSpot but are subject to change at any time. We do not directly collect or store any payment card information entered through our Services, nor do we have access to the information you provide to these third parties, but we may receive information associated with your payment card information (e.g., your billing details) and encourage you to visit their privacy policies to understand their practices.

Credentials. Before issuing Credentials, Customers will need to provide a group display name and identifier, Credential name, Credential requirements, applicable skills, and the applicable website for the course or group. Customers may also upload reference tags, the language used in your emails and Credential pages, the expiration period for your Credentials, and other information as needed to create your Credentials, and any other custom metadata or attributes about your group.

Recipient Information. To issue Credentials, Customers must upload the name and email address of each Recipient, along with the issue date for each Credential. Customers also have the option to upload a CredentialLicense ID, an Expiration date, Grade, UUID, and/or Recipient ID as part of each Credential.

3.2. How We Use Customer Data

We use Customer Data for the following purposes:

Providing our Service. We use Customer Data to provide our Sites and Services and for other customer service purposes in relation to Customer accounts.

Communicating with You About Your Account. We use Customer Data to communicate, via email or otherwise, about your Customer account(s); about TrueSkills’s products or services that we think may interest you; to respond to Customer inquiries, requests, or complaints; and to provide Customers with product updates, news, best practices, and other helpful or interesting information that can enhance your use of TrueSkills’s Services, in accordance with your communication preferences. When we communicate in this way, our emails may deploy a cookie that tracks when the emails are opened to measure Customer engagement. For more information about cookies, please see “Information Collected Automatically” under General Provisions below.

Marketing and Advertising. We use Customer Data to provide Customers with newsletters, special offers, and promotions, including via email; and for other marketing, advertising, and promotional purposes, including general updates about TrueSkills. These communications will be sent in accordance with our Customers’ communications preferences.

3.3 How We Disclose Customer Data

We may disclose Customer Data as follows:

Affiliates. We may disclose Customer Data to any current or future Affiliates, parent companies, or subsidiaries to process for the purposes described in this Privacy Policy.

Service Providers. We may disclose Customer Data to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, fraud detection) on our behalf.

Customers. We may disclose Customer Data to other Customers where relevant to the Service we provide. For example, we may show Credentials issues by another issuer on the wallet view of a Recipient that you have issued credentials to.

3.4. Customer Choices

Customers may access, correct, or update the information they’ve provided to us by either updating the information in their account, by emailing their dedicated account manager, or by contacting us using the information at “Contact Us” below.

We may send periodic promotional or informational emails to Customers in accordance with their communications preferences. At any time, Customers may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving marketing and advertising emails from TrueSkills, we will still send you emails about your account and any Services that you have requested or received from us.

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4. Students

Student Data, Schools and FERPA.  

All ofTrueSkills’s systems, procedures, use of data, and Services are in accordance with the Family Education Rights and Privacy Act of 1974 (“FERPA”) (20U.S.C. § 1232g; 34 CFR Part 99) governing the use of Student Data. TrueSkills receives Student Data from Schools, Customers, and Recipients in order to provide Services under its Agreement with the School. Please note that we do not consider any information that is not associated with your personally identifiable information (anonymized, de-identified, or aggregate information)to be personally identifying information.

Student Data we collect and store from Schools includes, but is not limited to, the student’s and/or Student Recipient’s:

• First and last name
• Address
• Educational records and transcripts
• Recipient, Customer, or Student-generated content

Cookies and Internet Tags Specific to Student Data and K-12 Student Recipients and Schools.  TrueSkills may use cookies, server logs and similar technology to help us improve the Services and to compile aggregate statistics about the use of Services for internal purposes. References to cookies in this Privacy Policy apply to Student Data as well.

No Marketing or Ownership of Student Data. We will never: 1) rent or sell any Student Data to third parties; 2) share Student Data with third parties for the purpose of targeted advertising; 3) use Student Data for marketing purposes; or 4) claim ownership of Student Data. ​

Security of Student Data. We take steps to ensure Student Data is treated securely and in accordance with this Privacy Policy. Unfortunately, the internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information provided to us. ​ TrueSkills stores and processes Student Data in accordance with industry standards and applicable law. In this regard, TrueSkills ensures Student Data is protected from unauthorized access, use, and disclosure. In the event that TrueSkills learns that the security of Student Data has been compromised, TrueSkills will notify you pursuant to the terms of the Agreement and as required by applicable law. TrueSkills will attempt to notify you as promptly as possible under the circumstances of any security breach affecting Student Data that TrueSkills believes may pose a material risk of harm. ​

Deletion of Student Data. If TrueSkills receives notice from a School to delete or destroy Student Data, we will take steps to make sure that the deletion of Student Data complies with FERPA standards. ​

Protection of Student Data. TrueSkills maintains an information security program that implements appropriate physical, administrative, and technical safeguards. TrueSkills conducts risk assessments and regular audits of its information security program and remediates potential security vulnerabilities if identified. Our servers storing and managing Student Data are located within the United States. See also “COPPA” and “Children’s Information” below.

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5. Recipients

5.1 Data We Collect from Recipients

Recipients may provide us with information through the Services. This information may include, but is not limited to, personal information such as your first and last name, relevant Customer name, login credentials, email address, school district affiliation, and any other information necessary to provide the Services.

Your Credential Account and Wallet. When you receive a Credential, you have the option to create an account using the email address and name provided to us by the Customer and adding a password. You also have the option to edit these fields and add other information such as an avatar image, a LinkedIn Profile URL, or a Twitter URL. In your account settings, you can choose whether to make your credential wallet public, private, or adjust the privacy settings of each Credential in your account.

Sharing Credentials. If you use our Services to add or share your Credential to your LinkedIn account or Twitter feed, you will be required to log into your account using your account credentials – we do not store your login information to your other accounts. You can also share your Credential manually to other social networks, or send your Credential to someone else via email, in which case we will collect your intended recipient’s email address.

5.2 How We Use Recipient Data. We use Recipient Data for the following purposes:

Providing our Service. We use Recipient Data to provide our Services to Recipients and our Customers, and may provide it to third parties to allow us to facilitate the Service. We may use and retain data we collect to provide and improve our services. ​

Aggregate Data. We may anonymize and aggregate data collected pursuant to the Agreement we have with the Customer or School and use it for the purposes of providing Services under that Agreement and to improve our Services. 

Recipient Support. We may collect Recipient Data when Recipients communicate with Recipient support services. ​By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service. ​

Tailoring Content. We may use Recipient Data to tailor the content and information that we may send or display to Recipients; to retarget content to Recipients through our Services; and to otherwise personalize your experiences while using our Services.

Offering our Customers Data Segments. A data segment is a grouping of users who share one or more attributes (e.g., travel enthusiasts). We offer a number of proprietary data segments to our Customers so that they may better target Recipients who are more likely to be interested in their content. TrueSkills does not create segments that are based upon sensitive information(for example, Personal Data revealing your racial or ethnic origin or your religious affiliations, or Personal Data concerning your sensitive health information, sex life or sexual orientation, or genetic or biometric data).

5.3 How We Disclose Recipient Data

We may disclose Recipient Data as follows:

Customers. We may disclose Recipient Data to Customers where relevant to the Service we provide those Customers. For example, we may share information about your use of the Services with Customers, such as if or when you received, viewed, or engaged with your Credential.

Credentials You Choose to Share. As described above in “Sharing Credentials,” our Services allow you to share your profile and/or Credentials with other Recipients, employers, publicly via social networks, including to those who do not use our Services.

Affiliates. We may disclose Recipient Data to any current or future Affiliates, parent companies, or subsidiaries to process for the purposes described in this Privacy Policy.

Service Providers. We may disclose Recipient Data to vendors, service providers, agents, contractors, or others who perform functions retained in connection with the provision of the Service. We may share information, including Student Data, with our third-party transportation providers as necessary to provide the Service. If we transfer personal information to a third party, we will take reasonable and appropriate steps to ensure that the third party collects, processes and discloses personal information only for limited and specified purposes in order to provide Services under the Agreement.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose RecipientData, including Student Data, if we believe doing so is required or permitted by law or appropriate to: comply with law enforcement requests and legal processes, such as a court order or subpoena or to meet national security requirements; respond to your requests; or protect your, our or others’ rights, property, or safety. 

5.4 Recipient Choices and Opting Out

TrueSkills supports initiatives to offer our Recipients greater transparency and control over the uses of their information. Recipients and students have the right to request that TrueSkills provide you with access to the personal information we hold about you, correct your personal information, delete your personal information, and cease or restrict processing of your personal information. You may access, correct, or update information you’ve provided to us by logging in and updating your information in your account or by contacting us using the information at “Contact Us” below.

To learn more about your choices and privacy rights, please see “Your Privacy Choices and Rights” below.

We may send periodic promotional or informational emails to Recipients and students in accordance with the communications preferences you choose. At any time, you may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving promotional or informational emails from TrueSkills, we will still send you emails about your account, any Credentials issued to you by our Customers, and any Services you’ve requested or receive from us.

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6. Site Visitors

6.1 Data We Collect from Site Visitors

TrueSkills collects Site Visitor Data either directly from you or from third parties that collect this information during your use of our Sites. We may combine all the information that we collect from various sources.

Your Preferences, Requests, and Forms. We may collect Site Visitor Data directly from you. For example, when you send us an email asking a question, or submit a form on our Sites to receive marketing materials or email newsletters, we will collect the information that you submit to us. We may also collect any other information that you choose to provide to us, such as the contents of a message that you submit through our Sites.

Information You’ve Made Available. We may obtain Site Visitor Data from third parties, including from other services and organizations you interact with that collect your information through your interaction with them. For example, if you access our Site or Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party that you have made available in your privacy settings. Such information may include, without limitation, information about your operating system, IP address, settings and system configurations, device model, device ID and other unique device identifiers, mobile-related information, the website that led you to our Sites, the website to which you go after leaving our Sites, the dates and times that you access our Sites, event information (e.g., system crashes) and web log data.

6.2 How We Use Site Visitor Data

We use your Site Visitor Data for the following purposes:

Providing and Improving our Services. We use Site Visitor Data to provide our Services, such as honoring requests and preferences and may provide it to third parties to allow us to facilitate the Service. We may use and retain data we collect to improve our Site and Services by analyzing the use and access to better understand how individuals access and use our Sites, both on an aggregated and individualized basis, and for other research, analytical or statistical purposes.

TailoringContent. We may use Site Visitor Data to tailor the content and information that we send or display to you on our Site and to personalize your experiences while using our Site.

Communicating with You. We use Site Visitor Data to communicate with you, including via email, about our Services; to respond to your inquiries via our website request forms; to answer any questions or complaints you submit; and to provide you with news, best practices or other information you may have requested or may be related to your inquires or questions.

Marketing and Advertising. We may use Site Visitor Data to provide you with newsletters, special offers, and promotions, including via email; to contact you about products or services we think may interest you; and for other marketing, advertising, and promotional purposes. These communications will be sent based on your communications preferences.

6.3 How We Disclose Site Visitor Data

We may disclose Site Visitor Data as follows:

Affiliates. We may disclose Site VisitorData to any current or future Affiliates, parent companies, or subsidiaries to process for the purposes described in this Privacy Policy.

ServiceProviders. We may disclose Site Visitor Data to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, fraud detection) on our behalf.

Third Parties. We may disclose Site Visitor Data to other third parties, specifically to those other services and organizations you’ve interacted with through which you accessed our Site, such as third-party applications, app stores, third-party login services, or social networking sites, or our data partners so that we can connect you with relevant content and tailored advertisements.

Customers. We may disclose Site VisitorData to Customers where relevant to the Services we provide to those Customers. For example, we may provide Customers with information about the viewing and click-through patterns of the content they publish on our Site and may provide advertisers with information about conversion rates for analytics purposes.

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7. General Provisions

We collect, use and disclose your information, including the specific provisions for Customers, Students, Recipients, and Site Visitors respectively set forth above, as follows:

7.1. Your Personal Information We Collect

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us directly, information we obtain automatically when you use our Site and/or Services, and information from other sources such as third-party services and organizations, as described below.

7.1.1 Information You Provide to Us Directly.

We may collect the following personal information that you provide to us:

Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.

Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services, including resumes, work samples, Certificate information, or biographical information will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced in this policy.

Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Job Applications. We may post job openings and opportunities. If you reply to one of these postings by submitting your application, CV, and/or cover letter to us, we will collect and use this information to assess your qualifications.

7.1.2 Information Collected Automatically

Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, and/or our service providers, like many businesses, as well as third parties that provide content, advertising, or other functionality on our Site or for our Services, may automatically collect and/or store information using cookies, pixel tags, local storage, and other technologies (“Technologies”)through your use of our Site and Services. This information may include:

• your internet protocol (IP) address
• user settings
• MAC address
• cookie identifiers
• mobile carrier
• mobile advertising
• other unique identifiers
• browser or device information
• location information (including approximate location derived from IP address)
• Internet service provider

We may also automatically collect information regarding your use of our Services, such as when you open an email to measure engagement, the pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Site and Services.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary.This includes Technologies that allow you access to our Site and Services, including applications and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
• ‍Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and/or Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising or Targeting-Related.We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on third-party websites.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:

• Google Analytics. We use analytics services provided by Google Inc. This allows us to process usage data to better understand how our Site and web-related Services are used. This enables us to continually improve our website, making it relevant to your interests and needs. This may involve personal data, such as cookie and other device identifiers. The data collected by     Google Analytics is usually transferred to a Google server in the USA and processed there. In addition, Google uses your data for its own purposes, e.g., for profiling or linking it to other data. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information.

Social Media Platforms. Our Services may contain social media buttons, such LinkedIn, Facebook, Twitter, WhatsApp, Tumble, and others, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address and which page you are visiting on our Site and/or Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company that provides them.

7.1.3 Information Collected from Other Sources

Information Made Available. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

Third-partyAnalytics. We may collect information from third parties that collect information on our behalf through your use of the Site, such as web analytics companies. Such information may include, without limitation, information about your operating system, IP address, settings and system configurations, device model, device ID and other unique device identifiers, mobile related information, the web pages you access within our Sites, the website that led you to our Sites, the website to which you go after leaving our Sites, the dates and times that you access our Sites, event information (e.g., system crashes) and web log data.

Referrals and Sharing Features. Our Site and Services may offer various tools and functionalities that allow you to provide information about your friends through our sharing and/or referral service; third parties may also use these services to upload information about you. In addition, we may collect information that other people provide about you when they use our Site and Services, including information about you when they provide us with your email address. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

APIs/SDKs. We may use third-party ApplicationProgram Interfaces (“APIs”) and Software Development Kits (“SDKs”)as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

7.2. How WeUse Your Personal Information

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

7.2.1 Providing Our Services. We use your information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

7.2.2 Administrative Purposes. We use your information for our legitimate interest, or to comply with our legal obligations, such as:

• Pursuing our legitimate interests including direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement of our Services;
• Short-term, transient use, such as contextual customization of ads;
• Tailoring content and information and to otherwise personalize your experience while using the Site and Services
• Improving, upgrading, or enhancing our Services;
• Developing new products and Services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
• Debugging to identify and repair errors with our Site and Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Other uses as required to comply with our legal obligations.

7.2.3 Marketing and Advertising our Products and Services. We may use your information to tailor content and provide you with advertisements. Some of the ways we market to you include email campaigns, custom audiences advertising, “content-based” and“interest-based” or “personalized advertising.” We may provide you with these materials as permitted by applicable law. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

7.2.4 Other Purposes. We also use your information for other purposes as requested by you or as permitted by applicable law.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• ‍AutomatedDecision Making. We may engage in automated decision making, including profiling, such as to create Job Market Insights. TrueSkills’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
• ‍De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create. If we create or receive personal data that has been de-identified or aggregated, we will not attempt to reidentify it, except to comply with applicable law.

7.3. How We Disclose Your Personal Information

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

7.3.1 To Provide our Service and Fulfill Administrative Purposes. The categories of third parties with whom we may share your information to provide our Services and fulfill our administrative purposes include:

• ServiceProviders. We may share your personal information with our third-party service providers who use that information to help us provide our Services and for our administrative purposes. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
• ‍BusinessPartners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
• ‍Affiliates. We may share your personal information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide.
• ‍Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

7.3.2 To Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

7.3.3 In the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

7.3.4 Aggregate and De-identified Information. We may disclose to our Customers and other third parties aggregated or de-identified information about users for marketing, advertising, research, or other purposes.

7.4 Third-Party Links

Our Site and Services may contain links to our Customers’ or third-party partners’ websites. Any access to and use of such linked websites is not governed by this Privacy Policy but instead is governed by the privacy policies of the applicable Customers’ and those third-party websites. We are not responsible for the information security nor privacy practices of such third-party websites. For example, our Site includes features from third-party social networking platforms, such as the LinkedIn“share” button. These features may collect certain information, such as your IP address or the page you are visiting on our Site and may set a cookie to enable the feature to function properly.

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8. Your Privacy Choices and Rights

8.1. Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
• ‍“DoNot Track.” DoNot Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• ‍Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Site and Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the NetworkAdvertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

8.2. Your Privacy Rights.

In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;
• ‍Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;‍
• Request Restriction of or Object to our processing of your personal information when processing is noncompliant;‍
• Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;
• ‍Request data portability and receive an electronic copy of personal information that you have provided to us;
• Be informed about third parties with which your personal information has been shared; and
• ‍Request the review of decisions taken exclusively based on automated processing if these decisions could affect your data subject rights.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

9. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy, including attaining System and Organization Controls (SOC) 2 Type II certification through a third-party auditor. The SOC 2 report validates thatTrueSkills meets the requirements of customers in highly controlled industries who need expert evaluation about how vendors handle the principles of security. In addition, we receive and review our data hosting providers’ SOC 2 reports every 12 months under NDA. Our data center provider maintains certification and compliance (as of this date), with ISO27001, SOC2 Type II, and many other certifications.

Unfortunately, however, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected, and take steps to require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

10. International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

11. Retention of Personal Information

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

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12. Children’s Information

Our Services are not directed to children, and we do not knowingly collect any information from any individual under 18 years of age, except in situations where we have the consent of that individual’s parent or legal guardian or are otherwise authorized to do so by applicable law.

If you are a parent or legal guardian and believe your minor child has uploaded personal information to our site without your consent, or wish to review information collected from your minor child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a minor child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the account if applicable.

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13. COPPA

Our Services comply with all applicable provisions of the Children’s Online Privacy Protection Act (“COPPA”) (15 U.S.C. 6501 et seq.). To the extent COPPA applies to the information we collect, we process such information for educational purposes only, at the direction of the partnering School and on the basis of educational institutional consent. ​

14. Supplemental Notice for California Residents

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information TrueSkills has collected about them, and whetherTrueSkills disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

14.1 Categories of Purpose of Collection. The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth below, respectively.

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14.2 “Sales” of Personal Information under the CCPA

For purposes of the CCPA, TrueSkills does not “sell” personal information, nor do we have actual knowledge of any“sale” of personal information of minors under 16 years of age, as the term“sell” is commonly understood. That said, we do share information with third-party advertisers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device, or by contacting us as set forth in “Contact Us” below.

14.3 Additional Privacy Rights for California Residents

• ‍Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
• ‍Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
• ‍Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

14.4 Refer-a-Friend and Similar Incentive Programs. As described above in “How We Use Your Personal Information” (“Share Content with Friends or Colleagues”), we may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide your personal information in exchange for a reward, or provide personal information regarding your friends or colleagues(such as their email address, which will be stored according to this Privacy Policy) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.)These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depends on whether the referred party ultimately becomes a Customer/Recipient and uses our Services. Said value will be reflected in the incentive offered in connection with each program.

14.5 Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

14.6 Right for Minors to Remove Posted Content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in Contact Us below or logging into their account and removing the content or information using ourself-service tools.

15. Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.  Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

16. Other Provisions

16.1 Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

16.2 Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

16.3 GOVERNING LAW. BY USING THE SERVICE OR BY OTHERWISE PROVIDING INFORMATION TO US, YOU AGREE THAT ANY DISPUTE OVER PRIVACY OR THE TERMS CONTAINED IN THIS PRIVACY POLICY WILL BE GOVERNED BY THE LAWS OF THE STATE OF CALIFORNIA AND THE ADJUDICATION OF ANY DISPUTES ARISING IN CONNECTION WITH TRUESKILLS OR THE SERVICE WILL BE IN ACCORDANCE WITH OUR TERMS OF SERVICE LOCATED AT TRUESKILLS.ORG/TERMS-OF-SERVICE.

16.4 Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

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17. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

TrueSkills
Attn: Privacy
rueSkills, Inc. Sidney, Australia.
[email protected]