Privacy Policy
Updated: July 22, 2025
Skillable values your privacy. This Privacy Policy (“Policy”) describes the personal information that we collect, how that personal information is processed, and your rights and choices in relation to it. Please read this Policy carefully.
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1. SCOPE OF THIS POLICY
This Policy applies to the collection and use of personal information of the following categories of individuals:
- Customers: purchasers/licensees of the services we offer (“Services”) (including resellers) or their staff or representatives;
- Business Contacts: anyone else that we deal with in the context of our business, including potential customers, suppliers of goods or services (or potential suppliers), investors (or potential investors), and any other business contacts, such as journalists or influencers; and
- Website Visitors: any person who visits our website. When Website Visitors engage with certain features of the website such as contact forms or questionnaires they may volunteer certain information to us, and we may also collect certain information automatically as referred to in Section 2.
When we collect personal information about Website Visitors, Customers, and Business Contacts as part of our business activities, we are considered a data “controller” or a “business”. This Policy only applies to cases where we process information in our capacity as a “controller” or “business”.
When providing our Services, we may also process certain personal information relating to Customer staff, students or other end users of the Services (“End Users”) on our Customers’ behalf. This personal information is processed on the instructions of the relevant Customer. In this context, we are acting as a data “processor”, “service provider” or “contractor” (as these terms are defined under applicable data protection laws). In relation to that activity, the primary legal responsibility for the data processing, including permitting exercise of End Users’ rights or answering questions about personal information processing, lies with each of our Customers as the relevant data controller or business. Therefore, if you are an End User, while we are happy to assist where we can, if you request from us information regarding our Customer’s practices, or send us any request to exercise your legal rights under data protection or privacy laws, we will generally not be able to respond, and will pass that request on to the relevant Customer for action or response.
If you have any additional questions or comments, please contact us as set out in Section 15 below.
2. OUR COLLECTION OF PERSONAL INFORMATION
Customers:
If you are or work for one of our Customers, we collect your email address and other contact data (e.g., name, phone number, organization) to identify you and your organization. This personal information is required to identify our Customers’ authorized users and permit them to access and use their accounts.
Business Contacts:
If you are or work for one of our Business Contacts, we may store and process information needed for managing our relationship with you or your organization which may include: your name, organization name, position, professional qualifications or interests, mailing address, website, telephone numbers, e-mail addresses, details of products and services, payment information, and information provided to us in the course of correspondence with you (e.g. by email, phone, or messaging).
Website Visitors:
The information we collect depends upon your interactions with us and your internet browser settings. The personal information we collect includes:
- Contact data, such as your first and last name, email address, mailing address, home and work telephone number, company name, job title, work mailing address, facsimile number, and other similar contact information;
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them, information you share when you sign up for special offers, or information you share when you complete a survey;
- Communications that we exchange with you, including when you contact us with questions or feedback; and
- Automatically collected device data, such as your device type, the name of the internet browser you use to browse our website, Internet Protocol (“IP”) address, general location, network name, and internet or telecommunication services provider name.
When you visit or access our website or Services, we may use cookies, pixels, beacons, local storage and similar technologies. For more information, please see Section 12.
3. HOW WE USE YOUR PERSONAL INFORMATION
We use the collected personal information for the following broad purposes:
| Purpose | Legal basis |
| Provision of our Services and support. We use your personal information, such as your name, phone number and email address, for the purposes of providing access to our Services and responding to support requests. | The legal bases for processing this data are the performance of our contractual obligations towards you (if you are an individual Customer); and, for Customers that are organizations, our legitimate interests. Our legitimate interests in this case relate to providing and managing our Services and enforcing our contracts. |
| Payments. We may need to send statements, invoices, and payment reminders to you, and collect and recover (overdue) payments, including through third parties. | The legal bases for processing this data are the performance of our contractual obligations (if you are an individual Customer); or that it is necessary for our legitimate interests, in this case in billing for our Services and collecting payments. |
| Research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services, website, and business. | The legal basis for processing this data is our legitimate interests, in this case in providing and improving our Services. |
| Procurement of Goods and Services. We store and process personal information to communicate with you and manage our relationship with you or your organization, including in order to make payments for products and services supplied to us and to evaluate new services and products. | The legal basis for processing this data is our legitimate interests, in this case in improving and expanding our business and resources. |
| Compliance and Legal. We may be required to collect, retain for reporting, recordkeeping, audits, or accounting, or disclose your personal information to meet our legal obligations; in response to lawful requests and legal process; and for the protection of our, your or others’ rights, safety, or property. | The legal basis for processing this data is to meet our legal obligations. |
Business Communications.
| The legal basis for processing this data is that it is necessary for our legitimate interests, in this case in managing our business relationships and improving our website. |
| Marketing, Sales and Advertising. We and our third‑party advertising partners may process personal information to provide you with personalized advertisements and marketing content. | The legal bases for processing this data are your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests or general information regarding our activities or Services. |
| With your consent. We may specifically ask for your consent to collect, use, or share your personal information for a particular purpose. | Processing will be based on your consent. |
Where we rely on our legitimate interests as a legal basis for processing personal information, we ensure that we consider your expectations and rights, and that they are not overridden by such interests.
Where we rely on your consent to process your personal information, you have the right to withdraw or decline consent at any time (although this will not affect the lawfulness of our processing based on such consent before its withdrawal).
Where we act as a data processor, service provider, or contractor, our Customers will define and communicate the applicable legal basis for the collection and use of the personal information that we process on their behalf.
4. HOW WE SHARE YOUR PERSONAL INFORMATION
In order to provide our Services and manage our business, we need to provide personal information to certain third parties, including service providers and/or contractors, as described in this Section. The personal information will be disclosed to third parties only to the extent required for the intended purpose. Such third parties may include:
- Our Affiliates. Entities in our corporate group that assist us in providing the Services (e.g. training or support);
- Authorities. e.g., law enforcement or regulatory authorities that request provision of personal information from us;
- Investors and finance. Participants in actual or potential business transactions, such as divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the ownership or assets of our company or our affiliates; and
- Service providers. Other organizations that provide services in support of our services and business such as:
- providers of IT-related services (e.g. cloud computing. data storage, website development, hosting, support, management, or maintenance);
- data analytics providers;
- marketing, advertising, and communications service providers; or
- auditing, accounting, legal, compliance, insurance, or banking service providers;
- payment service providers and payment processors.
These organizations process personal information on our behalf, but our contracts with them oblige them to meet data protection standards as strictly as those that apply to us, and not to use your personal information for any other purpose.
5. INTERNATIONAL DATA TRANSFERS
We may transfer or disclose personal information to our affiliated companies, or other third-party service providers or contractors for the purposes described in this Policy. We are headquartered in the United States and may use service providers that operate in the United States or other countries. Your personal information may be transferred to locations where privacy laws may not be as protective as those in your state, province, or country.
We ensure that, if we transfer your personal information from the United Kingdom or the European Economic Area to another country that is not regarded as having equivalent data protection laws, then we apply legally required safeguards to protect your personal information. These may include standard contract clauses for international data transfers as approved by the European Commission or other supervisory authorities. A copy of these safeguards may be made available if we receive a valid request.
6. THIRD PARTY SERVICES
This Policy does not apply to the practices of third parties that we do not own or control. The website and Services may enable you to interact with third party websites, mobile applications, and services that are not owned or controlled by us (“Third Party Services”). We are not responsible for any goods, services, or content from, or the privacy practices of any Third-Party Services. Please be aware that the Third-Party Services may collect personal information from you. Accordingly, we encourage you to read the terms of service and privacy policy of each Third-Party Service that you choose to use or interact with.
We exclude all liability with respect to such Third-Party Services and your usage of or interactions with them.
When we collect personal information in connection with Microsoft offered content, the Microsoft Privacy Statement at https://privacy.microsoft.com/en-us/privacystatement applies to the use and protection of such personal information.
7. HOW WE KEEP YOUR INFORMATION SECURE
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. Although we endeavour to ensure that our safeguards are sufficient and up to date, security risk is inherent in all internet and information technologies, and we cannot fully guarantee the security of your personal information.
8. RETENTION AND DELETION
We retain personal information for as long as necessary to fulfill the purposes for which we collected it. When a Customer’s agreement for the Services ends, all personal information collected through the Services may be deleted as required by applicable law, the Customer’s agreement with us, or the Customer’s request, unless we need to retain it for our legitimate interests or compliance with our obligations, including for the purposes of satisfying any legal, accounting, or reporting requirements, or to establish or defend legal claims.
9. CHILDREN’S INFORMATION
Our website and Services are not directed or intended for children under 16 years of age. We do not knowingly collect or solicit information from individuals under 16 years of age. If we later become aware that a user is under 16 years of age, we will take steps to remove that user’s information from our systems.
10. YOUR RIGHTS
You may have certain rights in relation to your personal information under applicable data protection laws which, depending on your location, may include the rights:
- To ask for access to it;
- To ask for errors in it to be corrected;
- To ask for it to be erased or deleted;
- If not erased, then to ask us to restrict its processing;
- To object to its processing for specific purposes;
- To ask for a copy to take to another service provider;
- To know what personal information we have collected about you, whether it is sold or shared, and to access a copy of it;
- If applicable, to opt out of sales or sharing of that personal information (please see Section 11);
- If applicable, to limit the use or disclosure of your sensitive personal information (please see Section 11); and
- Not to be discriminated against for exercising any of your rights under applicable privacy legislation (for example we would not deny you service, charge you a different price, or provide you a different quality of service for doing so).
However, please note that these rights are not absolute, and we may not in all cases be able to fulfill requests, e.g. if our own legitimate interests and regulatory requirements require us to retain certain data.
If you are dissatisfied with our handling of your request, you also have a right to lodge a complaint with a supervisory authority.
Users that receive email communications regarding our products and services have the option to unsubscribe from such email communications at any time by clicking the unsubscribe link at the bottom of promotional emails or by emailing updates@skillable.com.
You can exercise your rights by submitting a request using our contact details in Section 15 below.
We may not be able to process your request unless you:
- Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information (or an authorized representative); and
- Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
In appropriate cases we may ask for verification of your identity or, if you are an agent, your authority to make the request on behalf of the individual.
11. ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS
In addition to the information provided in Sections 2, 3 and 4 of this Policy, we inform you that during the twelve months before the publication of this Policy, we collected:
(1) the following categories of personal information:
- Identifiers such as a real name, postal address, online identifier, Internet Protocol address, email address, account name;
- Other personal information such as name, signature, address, telephone number;
- Commercial information, including records of products or services purchased, obtained, or considered;
- Internet or other electronic network activity information including information regarding interactions with our website or ads; and
- Professional or employment-related information.
(2) the following categories of sensitive personal information:
- Account log-in, password, or credentials allowing access to an account.
These categories of information were obtained directly from you or from our Customers or Business Contacts. For marketing purposes, we may also obtain information from directories, online and offline networking or events.
These categories of information were disclosed to our providers of IT-related services (e.g. cloud computing, data storage, website development, hosting, support, management, maintenance, or analytics services), and/or (excluding any information processed by us as a service provider on behalf of our Customers) marketing, advertising, and communications services, for our business purposes, as also referred to in Section 4.
The business purposes referred to in this Section include:
- Helping to ensure security and integrity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use as part of your current interaction with us;
- Performing services on our behalf;
- Obtaining advertising and marketing services (excluding any account data or other information processed by us as a service provider on behalf of our customers);
- Undertaking internal research for technological development and demonstration; and
- Undertaking activities to verify or maintain the quality or safety of our services or devices.
None of the above categories of information were sold or shared as referred to in applicable California data privacy laws.
12. COOKIES
Our website utilizes cookies. When you use our website we will collect information from and store cookies on your device in order to optimize your user experience. A cookie is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends cookie information back to the server to notify the website that it recognizes the user. You can find more information about different types of cookies at https://allaboutcookies.org/.
Use of cookies helps us to improve our website and to deliver a better and more personalized service by enabling us to:
- Recognize you when you use the Services or our website;
- Store information about your preferences;
- Perform analytics and improve our Services’ performance; and
- Estimate our audience size and usage patterns.
You may refuse to accept cookies by activating the appropriate setting on your device and/or browser. You can also remove cookies from your browser by following the directions provided in your browser’s “help” section. Some cookies are essential for securing access to and using features of our Services or website, so if you clear all cookies then those features may not work as expected or at all, or you may need to accept some cookies on your next visit.
13. OPTIONAL PROVISION OF PERSONAL INFORMATION
As a Website Visitor, you can browse our website without providing any personal information. If you are or work for a Customer or Business Contact, we may not be able to provide Services to you or work with you if you ask us to delete or do not provide necessary personal information.
14. CHANGES TO THIS PRIVACY POLICY
We will occasionally update this privacy policy to reflect changes in our business and applicable law. When we post changes to this Policy, we will revise the “updated” date at the top of this policy. We encourage you to periodically review this policy to be informed of how Skillable is using your information.
15. DATA CONTROLLER AND CONTACTS
The entity that decides on the ways your personal information is processed and for what purposes (also referred to as a data “controller” or “business”) is:
Hands-On Learning Solutions LLC d.b.a. Skillable
7143 State Road 54, #153
New Port Richey, Florida 34653
United States
If you have any questions regarding this Policy or our privacy practices, you may contact us as set out above or at privacy@skillable.com.
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