SKILLIFY Privacy Policy for our online eLearning library

This Privacy Statement was created on 26th October 2020.

About us

‍Skillify, together with its affiliates provides cloud-based learning and customer experience solutions. Skillify is committed to protecting your privacy and the personal information collected and processed about you.

About this policy

This is the Privacy and Cookies Policy (“Policy”) for the websites operated by or on behalf of Skillify and hosted at pages on the following domain http:skillify.com.au

This Policy describes our general privacy policy and practices in relation to Skillify’s services offered through the Site, or providing your personal information to us at our corporate events (collectively, the “Services”).

This Policy also describes how we collect information about you, what we do with that information, and also what controls you have over that information in relation to your use of our Site and Services.

By visiting and using Skillify’s Websites, mobile site, and/or applications (together, the “Site”) or using our Services, you acknowledge you have read and understood this Policy.

General information

Who is the Data Controller?

The data controller for the Site and Services is Skillify, 425 Smith Street, Fitzroy, Victoria 3065, Australia and can be reached at info@skillify.com.au

What “Personal Data” does Skillify collect?

How we collect and store information depends on the Site you visit, the activities in which you participate, and the Services you use. You can use some of the Services without providing any information, although several categories of information are automatically collected from you when you use the Services via the Site.

When using the Services, we may collect and process the following information about you:

Information provided directly by you

Information (such as your name, company name, email address, postal address, telephone number and other contact details) that you provide by registering on online on our learning platform Site or using the Service, including information about you if you register as a user of the Site or subscribe to a Service, information about you that you upload or submit to the Site or Service, or information you provide to us when requesting information or material from us;
Information and other details of any transactions made by you through any third party credit providers or processors including but not limited to financial and billing information, including account numbers, billing name and address, birth year, credit card number, the total number of employees within the organization that will be using the Services and other financial-related information (“Billing Information”) provided by you when making transactions through third party sites when paying to use our Services;
Information contained in communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site (or its content) or the Services;
Questionnaires and surveys. We may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, we may use such Personal Data to improve its products and services
Information from any employment materials you send us, for example, a CV, resumé or other details of your employment history; or
Other additional information that you provide to us when attending our corporate events.

Information that we may collect from you when you use our Site

We may automatically collect certain information about the computer or other devices that you use to access the Site or use the Services, including mobile devices, through commonly-used information-gathering tools, such as cookies and web beacons (see our Cookies section below).

We may also collect information when you access the Site or use our Services such as: (i) location information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s) such as your Internet Protocol (“IP”) address, browser types, browser language, operating system, the state or country from which you accessed the Services; and (ii) information related to the ways in which you interact with the Services, such as referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. If you do not want to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device; provided your device allows you to do this.

Creation of anonymized data sets. We may aggregate and/or de-identify information collected by the use of the Site or the Services so that the information is not intended to identify you. We may anonymize Personal Data provided under this Privacy Policy to create anonymized data sets, which will then be used to improve Skillify and its affiliates’ products and services. This Policy does not restrict our use or disclosure of aggregated and/or de-identified information.

Information about you collected from third parties

We may process your personal information that we have either obtained from you, or obtained from somewhere else. Personal information which is not collected directly from you may be collected:

From your employer in connection with your job and how it relates to us.
If you use any Site operated by us.
From third parties we work closely with (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

If you access the Site or use the Services through a third-party connection or log-in, you authorize Skillify to collect, store, and use, in accordance with this Policy, any and all information available to Skillify through the third-party interface.

Why Skillify needs your Personal Data?

We will collect and use your information as described in this Policy and as permitted by applicable laws (including, if you are located in Australia, the Privacy Act 1988 and the Australian Privacy Principles), including in circumstances where it is necessary: (i) to provide or fulfill Services requested by or for you; (ii) for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract; (iii) for compliance with a legal obligation to which we are a subject; (iv) to pursue our legitimate interests; or (v) where you have given us your express consent.

We collect and use your information for the following purposes:

To perform the Services requested by you.
For marketing purposes. For example, we may use your information to further discuss your interest in the Services and to send you information regarding Skillify and our group companies and our partners such as information about promotions, events, products or services. We will only send you marketing communications and updates about our products, services and events with your prior consent, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. You can withdraw your consent at any time.
In order to keep you up-to-date/request feedback. Within an existing business relationship between you and us, we may inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from us. Furthermore, where you have attended a webinar, seminar or event of Skillify or purchased products or services from us, we may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service. You can object to further marketing at any time by checking and updating your contact details within your account, or/and selecting the “unsubscribe” link located on the bottom of Skillify’s marketing emails. Additionally, you may send a request to info@skillify.com.au.You have the right to contact us at any time to object to the further processing of your information for the purposes of direct marketing to you, including any profiling related to such marketing.
For operating and improving Skillify’s Site and your customer experience. For example, we may collect and analyze data on your use of our website and process it for the purpose of improving our online customer experience. Data collected could include data about your device, such as unique device identifiers, information about your mobile phone or other mobile device(s), browser types, browser language, operating system, and the state or country from which you accessed the Services. Data collected could also include information related to the ways in which you interact with the Services, such as referring and exit pages and URLs, platform type, the number of clicks and domain names. This data allows us to understand our customers, their interaction with our website and improve our website to better serve our customers.
For security purposes. For example, we may use your data to protect Skillify and its third parties against security breaches and to prevent fraud and violation of Skillify’s applicable agreements. Data processing for security purposes is a legitimate business interest.
Protection of Skillify and Others. For example, we may disclose your information to: (i) comply with legal obligations; (ii) enforce any agreements that you entered into with us; (iii) respond to claims that any content violates the rights of third parties; (iv) respond to your requests for customer service; and/or (v) the extent necessary for the purposes of the legitimate interests pursued by us or by the third party or parties to whom the data are disclosed, except where such interests are overridden by the interests for fundamental rights and freedoms of the data subjects. We may also disclose information to law enforcement agencies in emergency circumstances, where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law. This is data processing for compliance with a legal obligation.
Business Transfers. For example, we reserve the right to disclose and transfer all of your information, to a successor (or potential successor) company in connection with a merger, acquisition, or sale of all, or components, of our business, or in connection with due diligence associated with any such transaction. Data processing for this purpose is a legitimate business interest.

From What Types of Third Parties does Skillify obtain Personal Data?

In most cases Skillify collects Personal Data from you. Skillify might also obtain Personal Data from third parties, if the applicable national law allows Skillify to do so. Skillify will treat this Personal Data according to this Privacy Statement, plus any additional restrictions imposed by the third party that provided Skillify with it or the applicable national law. These third-party sources include:

Skillify and/or Skillify Group’s business dealings with your employer
Third parties you directed to share your Personal Data with Skillify

How long will Skillify store my Personal Data?

SKILLIFY will only keep your information as long as it remains necessary for the identified purpose(s) for which it was originally collected and for up to eight (8) years afterwards or otherwise permitted by local laws, or as required for our business operations.

We may need to retain certain personal information even once a customer account has been closed or deleted to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes. We may also retain a record of any stated objection by you to receiving our updates for the purpose of ensuring we can continue to respect your wishes and not contact you further. For example, if you request to stop receiving emails from us, we will retain your email address for use on an email “suppression list” to ensure you do not receive further emails, as requested.

All retained information will remain subject to the terms of this Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your information due to technological and legal constraints.

Skillify will also retain your Personal Data for additional periods if applicable laws require it.

Who are the recipients of your Personal Data and where will it be processed?

Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:

Vicarious agents, e.g. third party servicers for consulting services and other additional related services
Other service providers, e.g. for the provision of the website or newsletter dispatch
State agencies and bodies, e.g. based on entry requirements or police activities and investigations
Our agents, partners or contractors who assist us in providing the Services we offer through our Site. The assistance provided by our agents, partners or contractors may be related to our marketing activities such as: updating marketing lists, data analytics, advertising, market research, participation in a contest or sweepstakes, and receiving and sending communications. Transactional assistance may also be provided by our agents, partners or contractors, including: processing transactions, fulfilling requests for information, billing, sales execution, and fulfilment of orders. Other support services provided may include: data storage, transfer, analysis and processing, legal services, providing IT, and in other tasks as requested, from time to time. Our agents, partners and contractors will only use your information to the extent necessary to perform their functions under this Policy and are subject to contractual restrictions prohibiting them from using your information for any other purpose.
From time to time, Skillify may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from Skillify, we may share information about you collected in connection with your purchase or expression of interest with our joint promotion partner(s). If you do not want your information to be shared in this manner, you may email info@skillify.com.au. However, we do not control our business partners’ use of the information that we share with them about you that we collect, and their use of the information will be in accordance with their own privacy policies.
To protect Skillify and others: We may disclose any of your information to: (i) comply with legal process; (ii) enforce any agreements that you entered into with us; (iii) respond to claims that any content violates the rights of third parties; (iv) respond to your requests for customer service; and/or (v) the extent necessary for the purposes of the legitimate interests pursued by us or by the third party or parties to whom the data are disclosed, except where such interests are overridden by the interests for fundamental rights and freedoms of the data subjects. We may also disclose information to law enforcement agencies in emergency circumstances, where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law.

What are your data protection rights?

You can request from Skillify: access at any time to information about which Personal Data Skillify processes about you and the correction or deletion of such Personal Data. Please note, however, that Skillify can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Skillify to retain it. Kindly note further that if you request that Skillify deletes your Personal Data, you will not be able to continue to use any Skillify service that requires Skillify’s use of your Personal Data.

If Skillify uses your Personal Data based on your consent or to perform a contract with you, you can further request from Skillify a copy of the Personal Data that you have provided to Skillify. In this case, please contact info@skillify.com.au and specify the information or processing activities to which your request relates, the format in which you would like to receive this information, and whether the Personal Data should be sent to you or another recipient. Skillify will carefully consider your request and discuss with you how it can best fulfill it.

Furthermore, you can request from Skillify that Skillify restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data Skillify has about you is incorrect, subject to the time Skillify requires to check the accuracy of the relevant Personal Data, (ii) there is no legal basis for Skillify processing your Personal Data and you demand that Skillify restricts your Personal Data from further processing, (iii) Skillify no longer requires your Personal Data but you state that you require Skillify to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Data by Skillify based on Skillify’s legitimate interest (as further set out below), subject to the time required for Skillify to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.

How can you exercise your data protection rights?

Please direct any requests to exercise your rights to info@skillify.com.au. You can also designate another person to submit requests to exercise your data protection rights to Skillify. You can give authorization to such person by granting them a limited power of attorney to exercise your data protection rights on your behalf.

How will Skillify verify requests to exercise data protection rights?

Skillify will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, Skillify will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by Skillify. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by us.

Skillify will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.

You can at any time object to Skillify’s use of your Personal Data as set forth in this section by sending an email to info@skillify.com.au. In this case, Skillify will carefully review your objection and cease further use of the relevant information, subject to Skillify’s compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if Skillify requires the information for the establishment, exercise or defense of legal claims.

Processing under applicable national laws

If the applicable national law allows Skillify to do so, Skillify will use information about you for a business purpose, some of which is Personal Data

to plan and host events
to host online forums or webinars
for marketing purposes such as to keep you updated on Skillify’s latest products and services and upcoming events
to contact you to discuss further your interest in Skillify services and offerings
to help Skillify create, develop, operate, deliver and improve Skillify services, products, content and advertising and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Skillify
to provide more personalized information to you
for loss prevention
for account and network security purposes
for internal purposes such as auditing, analysis, and research to improve Skillify’s products or services
to verify your identity and determine appropriate services
to assert or defend against legal claims
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
debugging to identify and repair errors that impair existing intended functionality
Short-term, transient use, provided the personal information is not disclosed to a third party and is not used to build a profile about you or otherwise alter your individual experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Skillify.

News about Skillify’s Products and Services. Skillify will use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with Skillify (prior purchases, participation in webinars, seminars or events or the use of (web) services in order to keep you up to date on the latest product announcements, special offers, and other information about Skillify’s services (including marketing-related newsletters) as well as events of Skillify and in order to display relevant content on Skillify’s websites. In connection with these marketing-related activities, Skillify will provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own databases in order to display to you more relevant information.

Forwarding your Personal Data within the Skillify Group. Skillify will transfer your Personal Data to other affiliated companies within the Skillify Group of undertakings for the purpose to inform you about their latest products, service offers and events in the same way Skillify does under this Privacy Statement. In such cases, the Skillify Group will use the Personal Data for the same purposes and under the same conditions as set forth in this Privacy Statement.

Forwarding your Personal Data to other third Parties. Skillify will transfer your Personal Data to partners for the purpose that such partners inform you about Skillify’s or the partners latest products, service offers and events. Any such use of information is based on the consent you grant.

Social media features

Skillify offers social network functionality in various parts of our website and on apps. We give you the opportunity to share and recommend your content in social networks in our online offerings. If you visit our website and use the recommendation features, we pass on the URL to the social network you select where your Personal Data will be then used by the social network according to the social network’s own privacy statement. We recommend that you read the privacy statement of the respective social networks carefully.

Profiles

Skillify offers you the option to use services, including to view tutorials or take trainings, that require you to register and allow you to create a user profile. User profiles provide the option to display personal information about you, including but not limited to your name, photo, address, email, telephone number, personal interests, skills, etc. Profile data is processed to personalize the interaction with other users to foster the quality of communication and collaboration via such services. Profile data might also be shared with other web offerings and services across the Skillify Group. The provision of any such information about you as well as the decision to share information with other services is at your free will and based on the consent that you grant.

Does Skillify.com.au use cookies?

Yes. Skillify.com.au uses cookies and other technologies to ensure everyone who uses Skillify.com.au has the best possible experience. Cookies also help us keep your account safe. By continuing to visit or use our services, you agree to the use of cookies and similar technologies for the purposes we describe in this policy.

What is a cookie?

A cookie is a small file placed onto your device that enables Skillify.com.au features and functionality. For example, cookies enable us to identify your device, secure your access to Skillify.com.au and our sites generally, and even help us know if someone attempts to access your account from a different device. Cookies also enable you to share content on Skillify.com.au easily.

What are clear gifs?

Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded on Web pages.

What is a Flash cookie?

Local shared objects, also known as “Flash cookies”, are similar in function to browser cookies in that they store some information about you or your activities on our Websites. We use Flash cookies in certain situations where we use Flash to provide some content such as video clips or animation. The options within your browser may not prevent the setting of Flash cookies. To manage Flash cookies, please click here.

When does Skillify.com.au place cookies?

We use cookies on our Services, including our Websites and App. Any browser visiting our Websites will receive cookies from us.

What types of cookies does Skillify.com.au use?

We use two types: persistent cookies and session cookies. A persistent cookie helps us recognize you as an existing user, so it’s easier to return to Skillify.com.au.com or interact with our Services without signing in again. After you sign in, a persistent cookie stays in your browser and will be read by Skillify.com.au when you return to one of our Websites or a partner site that uses our Services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

Your Rights:

This section provides details about your rights in relation to your personal information.

You may ask us to:

Access all the personal information about you held by us, including where applicable, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. On request, we will provide you with a copy of this information. Where a request is manifestly unfounded or excessive (for example, because it is repetitive) we reserve the right to charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested. You can exercise your right of access to your personal information:
By emailing us at info@skillify.com.au; or
By writing to us at the address below.

Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.

Correct or erase your personal information where appropriate. Please note, you may review and update certain user profile information by logging in, as applicable, to the relevant portions of the Services where such information may be updated;
Restrict the processing of your personal information whilst we investigate your concern;
Where your processing is based on your consent, you have a right to receive your information in a commonly used electronic format or ask we move the data in that format to another provider where your request relates to the data that you gave us direct and where technically possible (data portability);
Object to the further processing of your personal data, including the right to object to marketing;
Request that your provided personal data be moved to a third party;
You may opt out at any time from allowing further access by us to your location data by exiting the site. You can also stop all information collection by un-installing the applicable app. You may use the standard un-install processes as may be available for your mobile device.; and
Withdraw your consent at any time when the processing relies upon consent. You can also change your marketing preferences at any time;

If you remain unhappy with a response you receive you can also refer the matter to your data protection supervisory authority to the Office of the Australian Information Commissioner.

Changes to this Policy

Skillify reserves the right to change this Policy from time to time. Please check this page periodically for changes. If we make any material changes to this Policy we will notify you before they take effect either through the Site or by sending you a notification. Any such material changes will only apply to personal information collected after the revised Policy took effect.

Contact us

Have additional privacy questions or need further info? This section is about how to contact us.

If you have any questions, comments, or concerns regarding this Policy or SKILLIFY’s privacy practices, they may be submitted via email to info@skillify.com.au, or in writing by addressing your inquiries to: Skillify, 425 Smith Street, Fitzroy, Victoria 3065, Australia

Right of access

You have a legal right to request the personal information about you held by us. On request, we will provide you with a copy of this information. You also have a right to correct, amend or delete such personal information where it is inaccurate or has been processed in violation of data protection laws.