Skillos Privacy Policy
Effective as of: 2022-02-20ScopeSkillos Global Inc., its affiliates and subsidiaries (“we”, “us”, “our”, “Skillos”) recognizes that your privacy isimportant and we take it seriously. This Privacy Policy describes how we collect, receive, use, store, share,transfer and process your information, as well as your rights in determining what we do with theinformation that we collect or hold about you when you access or use (a) our websites and onlineproperties, including www.Skillos.com and our career portal (collectively, the “Sites”), (b) our Cloud-basedIoT Platform, including Skillos.systems or developer.Skillos.com and any dashboards or portals that wemake available to our customers, users and others (collectively, the “IoT Platform”) and (c) the Skillos SmartCloud. The Sites, the IoT Platform and any services we provide in connection with one or more of theforegoing are collectively referred to as the “Services.”The processing of such information is limited to the purpose of providing the service for which our Clientshas engaged us and Skillos has no direct relationship with the individuals whose Personal Data itprocesses. If you are a customer of our Clients and would no longer like to be contacted by one of ourClients that use our service, please contact the Client that you interact with directly.The Services may contain links to other websites or online services that are operated and maintained bythird parties and that are not under the control of or maintained by us. This Privacy Policy does not applyto how third parties collect, use, disclose or retain information. We encourage you to review the privacypolicies of these third-party websites or services.If you have any questions or concerns regarding the data protection practices, please do not hesitate tocontact:Skillos Customer Service Department: dial +447488818335; email to support@skillos.systemsor ,Skillos Privacy Office: support@skillos.systemsYou are not obliged to provide to us your Personal Data (as defined below). However, we may be unableto provide you with certain products and/or Services if you decline to provide such data.In this Privacy Policy,Personal Data means, unless otherwise provided by applicable laws in your region of residence,information that can be used to identify a particular individual, either by that information alone, or incombination with other information.User Data refers to the data submitted by users or collected by Skillos in order to provide its services, suchas user name, contact information, etc., when user registers for an account on Skillos's website, interfaceswith Skillos's products or services. For clarity, User Data includes, but is not limited to, Personal Data.Smart Devices refers to those nonstandard computing devices produced or manufactured by hardwaremanufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to anetwork, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.What Personal Data do We Collect1. Information You Voluntarily Provide Us.• Account Data: When you register an account with us, we may collect your name and contact details,such as your name, email address, mailing address, phone number, user name, and login credentials.• Transactional And Purchase/Payment Details: If you purchase Skillos’s Services, either online or offline,we may collect your records/dates of purchases, invoice information, billing address, payment method, orbank account, account holder information, and debit card numbers for the business partnership.• Session Data: During your sessions of communications with our staff, such as consultations with ourbusiness team, or online interactions with the customer service team about our products or Services, wewill collect your session records and relevant information, which is limited to the following: customizedsession ID, session time, your company name, as well as information you voluntarily provide. The purposeof such collection is to analyze your concerns raised during the session, so that we can enhance andimprove our services and identify usage trends, or in order to address your problems. However, please bereminded that we will not collect any sensitive personal information related to your identity.• Name and Occupational Information in Communications with Us: When you visit our websites, fill outour online forms, or engage with our support team, we may collect your name and occupationalinformation, such us your name, email address, and work/company information.• Job Application Information: When you apply to work for us, we may collect your education andprofessional experience related information, such as school attended, course of study, academic degreeobtained, grades, employment history, professional certification/licenses received.2. Information We Collect Automatically.When you use our Sites and Services, we may collect certain information, including Personal Data, aboutyour use of the Sites and Services:• Device Information: When you interact with our Sites and Services through hardware, we mayautomatically collect device information, such as the unique device ID number of your device, IP address,wireless connection information, operating system type and version, browser type and version, pushnotification identifier, and mobile network information.• Usage Data: During your interaction with our Sites and Services, we may automatically collect usagedata relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites andServices.The major purpose of collecting and using such data is to improve the products or services we provide toyou, and to collect different volumes of data because of the different types functions of the products orservices.• Log Data: When you access or use our Sites and Services, any act you engage that may pose any risk tous will be recorded in form of log files. This may include without limitation, system logs, exception logs, orlogs describing how your operations may pose risk to us. Logs may be uploaded to backend.Please note that one cannot identify a specific individual by using device information or log informationalone. However, if these types of non-personal information, combined with other information, may beused to identify a specific individual, such non-personal information will be treated as Personal Data.Unless we have obtained your consent or unless otherwise provided by data protection laws andregulations, we will aggregate and desensitize such non-personal information.3. Information We Acquire from Third PartiesIn some cases, and as permitted by law, we may obtain your Personal Data from a third party. Forinstance:• You may authorize a third party to transmit data to us;• We may obtain certain data from third-party partners, for instance, public information, includingcompany name, company contact person, company email address, etc.;• Data related to you provided by others, for example, when other users purchase products or services foryou, they may provide us with your Personal Data, which may include your name, mailing address, andcontact information.Cookies and Similar Tracking TechnologiesWhen you visit the Sites and Services, we and service providers on our behalf may send one or more“cookies,” which are small data files, to your devices to uniquely identify your browser and let us help youlog in faster and enhance your navigation through the Sites. Cookies help us measure, for example, thetotal number of visitors to our Sites, the number of visitors to each page of our Sites, how our users useand interact with the Services, and the domain names of our visitors” Internet service providers. You canreset your web browser to refuse all cookies or to indicate when a cookie is being sent. If you do not wantcookies to be installed on your device, there is a simple procedure in most browsers that allows you todecline the use of cookies. Please be aware that some features of the Sites and Services will not functionproperly if the ability of your device to accept cookies is disabled.We may also use web beacons to track usage patterns of users of the Services. Additionally, we may useHTML-based emails sent to our users to track which emails are opened by recipients. The information isused to enable more accurate reporting and make the Services better for you.We honor do-not-track signals or similar technologies that our systems detect and identify. We do nottrack, plant cookies, or use advertising when such do-not-track (DNT) browser mechanism is in place onyour device.Purpose and Legal Basis for Processing Personal DataThe purpose for which we may process information about you are as follows:To Provide Our Services to You. We process your account data, device information, User Data, log data,location information(such as IP address), and Smart Device data in order to provide Services that you haverequested or purchased. For example, you can connect the App and Smart Devices and control SmartDevices through Apps, and securely store your pictures and videos when purchasing cloud storageservices.• To Operate and Improve Our Services. We process your device information, usage data, locationinformation and Smart Device data to analyze trends and to track your usage of our Sites and Services asnecessary to develop and improve our websites, and provide our users with more relevant and usefulcontent. The legal basis for this processing is to perform our contract with you according to our Terms ofUse.• Account Management. We process your Personal Data to create and manage accounts when youregister with us. The legal basis for this processing is to perform our contract with you according to ourTerms of Use.• Handle Contact and Support Request. We process your Personal Data to contact you to offer help basedon diagnostic information about your Smart Devices, to fulfill your requests, respond to your inquiries andto provide support; Especially when you encounter usage problems when using Skillos products orservices, please contact Skillos customer service team in time so that we can locate your problem morequickly and provide solutions. The legal basis for this processing is to perform our contract with youaccording to our Terms of Use.• Marketing Communication. We process your Personal Data to inform you about Services that we believemay be of interest to you. If we do so, each communication we send you will contain instructionspermitting you to opt-out of receiving future communications of that nature. The legal basis for thisprocessing is your consent.• Non-Marketing Communication: We process your Personal Data to send you important informationregarding the Services, changes to our terms, conditions, and policies and/or other administrativeinformation. Because this information may be important, you may not opt-out of receiving suchcommunications. The legal basis for this processing is to perform our contract with you according to ourTerms of Use.• Research. We process your Personal Data for our internal business purposes, such as data analysis,audits, developing new products or services, enhancing and improving the Services and identifying usagetrends. The legal basis for this processing is to perform our contract with you according to our Terms ofUse.• Legal Compliance. We disclose information if we are legally required to do so, or if we have a good faithbelief that such use is reasonably necessary to:• comply with a legal obligation, process or request;• enforce our Terms of Use and other agreements, policies, and standards, including investigation of anypotential violation thereof;• protect the rights, property or safety of us, our users, a third party or the public as required or permittedby law; or• detect, prevent or otherwise address security, fraud or technical issues.If there is any change in the purposes for processing your Personal Data, we will inform such change toyou via email and/or a prominent notice on our website of such changes of purposes, and choices you mayhave regarding your Personal Data.Who do We Share Personal Data with?At Skillos, we only share Personal Data in ways that we tell you about. Without your consent, we will notdisclose your Personal Data to third-party companies, organizations, or individuals except in the followingcases:• Sharing subject to your express consent: upon your express consent, we may transfer your UserInformation to third parties. For instance, if you have indicated that you wish to receive accurate pushnotifications and diversified services that we provide, we may share your Personal Data with certain thirdparties.• To our third-party service providers who perform certain business-related functions for us, including:- cloud service providers who provide Skillos with fundamental structural plans regarding cloudservices, including network, server and virtual services, website hosting, data analysis, payment and creditcard processing, infrastructure provision, IT services, e-mail delivery services, and other similar services toenable them to provide services to us;- customer service providers who provide Skillos with customer support services, including customerservice system support and personnel service support;- enterprise authentication service providers who helps us with verification of enterprise accounts,contract signing and authentication of enterprise status;- when place an order on Skillos’s websites, we may share your information with third parties toallow you to receive our products and/or services that you order.• To our customers and other business partners who provide you, directly or indirectly, with your SmartDevices, and/or networks and systems through which you access and use our Sites and Services.• To subsidiaries or affiliates within our corporate family for purpose of regular business activities basedon our instructions and in compliance with applicable law, this Privacy Policy and other appropriateconfidentiality and security measures.• To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture,assignment, transfer or other disposition of all or any portion of our business, assets or stock (includingwithout limitation in connection with any bankruptcy or similar proceedings). In such an event, you will benotified via email and/or a prominent notice on our website of any change in ownership, and choices youmay have regarding your Personal Data.• As we believe in good faith that access to, or use, preservation, or disclosure of the information isreasonably necessary or appropriate to:(a) Comply with applicable law, regulation, legal process, or lawful governmental request;(b) Enforce our Terms of Use and other agreements, policies, and standards, including investigation of anypotential violation thereof(c) Protect the rights, property or safety of us, our users, a third party or the public as required orpermitted by law.(d) Perform risk management, screening and checks for unlawful, fraudulent, deceptive or maliciousactivities.Data TransferSkillos operates globally, and Personal Data may be transferred, stored and processed outside of thecountry or region where it was initially collected. Also, the applicable laws in the countries and regionswhere we operate may differ from the laws applicable to your country of residence. Under the PersonalData protection framework and in order to facilitate our operation, we may transfer, store and processyour Personal Data in jurisdictions other than where you live.We protect Personal Data in accordance with this Privacy Policy wherever it is processed and takeappropriate contractual or other steps to protect it under applicable laws.The European Commission has determined that certain countries outside of the European Economic Area(EEA), the UK or Switzerland can provide adequate protection of Personal Data. Where Personal Data ofusers in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside theEEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection,we ensure that the transfer is governed by the European Commission’s standard contractual clauses. Youcan review the agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. Formore information, see here.If you would like further details on the safeguards we have in place under the data transfer, you cancontact us directly as described in this Privacy Policy.SecurityWe use commercially reasonable physical, administrative, and technical safeguards to preserve theintegrity and security of your Personal Data. Skillos provides various security strategies to effectivelyensure data security of user and device. As for device access, Skillos proprietary algorithms are employedto ensure data isolation, access authentication, applying for authorization. As for data communication,communication using security algorithms and transmission encryption protocols and commercial levelinformation encryption transmission based on dynamic keys are supported. As for data processing, strictdata filtering and validation and complete data audit are applied. As for data storage, all confidentialinformation of users will be safely encrypted for storage. If you have reason to believe that yourinteraction with us is no longer secure (for example, if you feel that the security of any account you mighthave with us has been compromised), you could immediately notify us of the problem byemailing support@skillos.systems in accordance with the section below.Data Subject RightsWe respect your rights and control over your Personal Data. You may exercise any of the following rightsby:a) Forward your privacy request on Email us at support@skillos.systems.You do not have to pay a fee for executing your personal rights. According to different data protectionlaws, your request of personal rights will be handled within 15 business days, or within 30 calendar daysdue to different response requirement.In your request, please make clear what information you would like to have changed, whether you wouldlike to have your Personal Data deleted from our database or otherwise let us know what limitations youwould like to put on our use of your Personal Data. Please note that we may ask you to verify youridentity before taking further action on your request, for security purposes.You may:• Request access to the Personal Data that we process about you;• Request that we correct inaccurate or incomplete Personal Data about you;• Request deletion of Personal Data about you;• Request restrictions, temporarily or permanently, on our processing of some or all Personal Data aboutyou;• Request transfer of Personal Data to you or a third party where we process the data based on yourconsent or a contract with you, and where our processing is automated;• Opt-out or object to our use of Personal Data about you where our use is based on your consent or ourlegitimate interests.You may opt-out from receiving marketing-related emails through the email selection or othercommunications from us on a going-forward basis by emailing support@skillos.systems. We will complywith your opt-out request as soon as reasonably practicable. Please also note that if you do opt-out ofreceiving marketing-related messages from us, we may still send you important administrative messages,and you cannot opt-out from receiving administrative messages. We partner with a third party to displayadvertising on our website or to manage our advertising on other sites. Our third-party partner may usecookies or similar technologies in order to provide you advertising based upon your browsing activities andinterests. If you wish to opt out of interest-based advertising click here or if located in the European Unionclick here. Please note you will continue to receive generic ads.Your California Privacy RightsCalifornia Civil Code Section 1798.83 permits users of the Software that are California residents torequest certain information regarding our disclosure of Personal Data to third parties for their directmarketing purposes. To make such a request, please contact us in accordance with the“support@skillos.systems” section below. We do not disclose Personal Data to third parties for their directmarketing purposes without your consent.Data RetentionWe process your Personal Data for the minimum period necessary for the purposes set out in this PrivacyPolicy, unless there is a specific legal requirement for us to keep the data for a longer retention period. Wedetermine the appropriate retention period based on the amount, nature, and sensitivity of your PersonalData, and after the retention period ends, we will destruct your Personal Data.1- For as long as you require us to fulfill the products and services you request from us as defined in theTerms of Use;2- Personal Data will no longer be retained when you request to remove your Personal Data, we willaccordingly complete the task.When we are unable to do so for technical reasons, we will ensure that appropriate measures are put inplace to prevent any further such use of your Personal Data.Children’s PrivacyProtecting the privacy of young children is especially important to us. The Services are not directed toindividuals under the age of thirteen (13) (or such other age provided by applicable law in yourcountry/region of residence), and we request that these individuals do not provide any Personal Data tous. We do not knowingly collect Personal Data from any child unless we first obtain permission from thatchild’s parent or legal guardian. If we become aware that we have collected Personal Data from any childwithout permission from that child’s parent or legal guardian, we will take steps to remove thatinformation.Changes to this Privacy PolicyWe may update this Privacy Policy to reflect changes to our information practices. If we make any materialchanges, we will notify you by email (send to the e-mail address specified in your account) or by means ofa notice on this website prior to the change becoming effective. We encourage you to periodically reviewthis page for the latest information on our privacy practices.Dispute ResolutionIf you have an unresolved privacy or data use concern that we have not addressed satisfactorily, pleasecontact our U.S.-based third-party dispute resolution provider (free of charge) at support@skillos.systems