Last updated March 15, 2022
Scope of this Notice
We are skillXchange LLC (“skillXchange,”, “we,” “us,” or “our”), a provider of tools for workplace learning, located at skillxchange LLC
16192 Coastal Highway Lewes, Delaware 19958. This Privacy Notice describes how we collect, use, share, and store your personal data when individuals visit our websites, access skillXchange, participate in our SkillXchange Communities, register to attend our events and webinars (online and in-person), participate in surveys or sweepstakes, apply to our job posting, and contact us through various communication methods. This Notice also describes your choices as related to your personal data.
Links to Other Websites -This Notice does not apply to websites we do not own or control. We are not responsible nor liable for how third parties manage their own sites. Please refer to the privacy notices posted on those sites for more information.
Personal Data – Personal data refers to information relating to an identified or identifiable individual including name, phone number, company name, job, email, and postal address. In the provision of skillXchange services, we do not knowingly collect sensitive personal data such as precise geolocation data, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Usage Data – Passively or automatically collected data (referred to as “Usage Data”) is collected as you use our websites or access our services. We, our affiliated entities, our service providers, and our marketing partners may use automated means to collect various types of information about you, your computer, or other device used to access the sites, services, related Web applications, and downloadable software. This information is based on your usage of our sites and services and may be based on your visitation to other websites. Usage Data could be used indirectly to identify a person.
Data Controller – We act as the data “Controller” of the personal data you provide directly to us. Examples include when you fill out the “Contact Us” form, create an account, participate in surveys or sweepstakes, participate in our skillXchange Communities, attend events, apply to one of our jobs, or contact us via other methods.
Data Processor – If you are an employee or an authorized user of one of our customers which have entered into an agreement with us for the provision of our services, we will be acting as the “Processor” of your personal data transmitted by such customers. That customer will be acting as the Controller of your information. As a processor, we do not own, control, or direct the use of any data provided to us by our customers who act as Controllers. If you have questions on how your personal data is being handled, please direct your inquiries to our customer, the Controller. If you contact us, we may be obligated to inform our customer of your request.
Changes to this Notice
We may update this Notice from time to time. If we make changes, we will revise the date at the top of this Notice. If we make material changes, we may provide additional notice such as sending you an email or posting a statement on our homepage prior to the changes taking effect. We encourage you to review this Notice periodically.
How We Collect Personal Data
Information You Provide to Us
We collect personal data directly from you such as when you make an inquiry through our “Contact Us” web page and other contact methods, apply to our job posting, and when you request that we send you emails. Depending on where you reside, you may have the option to provide your consent before we collect your personal data to send you marketing emails. You may unsubscribe to our marketing emails by using an opt-out link contained in every non-transactional email or by updating your marketing preferences on your account page. We also store the files or other information that you upload or provide to us (“Content”) as part of your subscription.
We collect information about you when you register with us for a skillXchange ID, create or modify your online account, join our skillXchange Communities, access and use our services, participate in a survey, contest, or event, make a purchase, apply for a job, request customer support, communicate with us via third-party social media sites, or otherwise communicate with us.
The types of information we may collect directly from you include your name, user name, email address, avatar, postal address, phone number, employer’s name, transactional information (including services purchased or subscribed to and billing address) as well as any contact or other information you choose to provide.
Please be aware that the information you choose to provide in your skillXchange ID profile may reveal information that is not expressly stated (for example, if you choose to provide your picture, your picture may reveal your gender).
We collect information from you when you apply to one of our posted positions. The types of information we may collect directly from you include your name, email address, phone number, LinkedIn Profile, personal website, and information in your résumé and cover letter. You have the option to provide demographic information that will be used on an aggregate basis (e.g. gender, ethnicity, veteran status, disability status). Demographic information will not be used to identify you nor used to evaluate your qualification for the role.
Personal Data We Collect from Third-Party Sources
We use third-party applications to add firmographic information to the data we collect from you. This data enhancement allows us to provide more helpful, personalized communication.
Personal Data We Collect Automatically
We collect Usage Data about you when you access and use skillXchange services, including your Internet Protocol (IP) address, access times, browser type and language, Internet Service Provider (ISP), the web pages that you visit, behavior during the visit, the content you use, and the URL of the web page you visited before navigating to our services.
We collect Usage Data through cookies and similar technologies. For additional information and how to set your browser to reject cookies, see the Cookies and Similar Technologies section below.
Subject to your right to opt out, we may combine Usage Data with personal data that we collect, and use the combined data to create profiles about you only for purposes of improving our products and services and your user experience with our products and services.
We may make full, unrestricted use of Usage Data for any purpose in our sole discretion, including without limitation, to customize re-marketing ads, offers and content made available to you based on your visits to and/or usage of our sites or its services, and to analyze the performance of those ads offers and content, as well as your interaction with them.
If you access skillXchange services from a mobile device, we collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network), or platform information (as allowed by the specific platform type). We do not ask for, access, or track any location-based information from your mobile device at any time while you are downloading or using our mobile apps.
How We Use Personal Data
We may use the information we collect about you for a variety of purposes, including to:
Operate our services
We use the information we collect about you to provide, operate, maintain, and improve our services. We also use this information to help you use our services, including uploading, downloading, collaborating on, and sharing content, delivering e-learning content to learners, as well as delivering emails on your behalf such as sending emails to your collaborators when you comment on a skillXchange Community.
We also use information about you to provide and deliver the services and features you request, to process and complete transactions, and to send you related information, including purchase confirmations and invoices.
Communicate with you
We also use the information we collect about you to send you technical notices, updates, security alerts, and support and administrative messages. We’ll also use that information to communicate with you about services, features, surveys, newsletters, offers, promotions, contests, and events, as well as provide other news or information about us and our select partners.
Of course, we’ll also use your information to respond to your comments, questions, and requests, provide customer service and support and deliver contest entries and rewards.
Protect our services
We also use information about our users to investigate and prevent fraudulent transactions, unauthorized access to our services, and other illegal activities.
Improve our apps and services
If you’re a skillXchange, perpetual product customer, or trial subscription user, we track what apps you use and some of the features that you use when you’re using those apps. We may also track information about the websites you visit, the sizes and names of the files or folders you upload, download, share, or access while using our services, the content you access, and any actions taken in connection with the access and use of your content in our services.
This app usage information helps inform our product development. We also use this information to send you targeted content to support you in using our apps.
Personalize our website and communication with you
Help you use our services
If you’re a skillXchange customer, we analyze your product usage information to see how you’re doing with our apps and resources. We use customer profiles to prioritize outreach from our team, send you helpful information, and guide us in creating content to help customers make the most of their subscriptions.
Advertise to you
When you’ve visited our sites, we place cookies and a tracking pixel in your browser that helps us show you targeted ads on other sites you visit. We do not do this with visitors based in the European Economic Area (EEA).
Process your job application
We will use the information you have provided us to manage job applications and comply with legal reporting requirements such as affirmative action.
Sharing Personal Data
General Disclosure Policy – We may share and disclose your personal data as described below. We may share and disclose Usage Data without restriction, including without limitation, as described below. Please contact us at email@example.com to opt-out of all information sharing with a third party.
We may share and disclose your personal data to the following types of third parties.
Service Providers. We may share your personal data and Usage Data with our third-party service providers, vendors, and consultants working on our behalf to provide services to you and to operate and maintain our sites. For example, we may contract with service providers to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, reporting, and software maintenance and development services. In addition, our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.
For a list of service providers we use to deliver skillXchange services to you, please click to see our trusted sub-processors. To view the sub-processors we use to provide skillXchange services visit https://www.skillxchanges.com/contact-us/
Marketing Partners for Purposes of Re-Marketing – We may share your personal data with service providers, vendors, and consultants for purposes of re-marketing. For a description of re-marketing and your opt-out rights, see the Remarketing within the Cookies and Similar Technologies section below.
Affiliated Entities – We may provide your personal data and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.
Successors – If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy, or liquidation, we may transfer your personal data.
Authorized Resellers – If you acquire our services through an authorized reseller or partner, we may share your personal data and Usage Data with those authorized resellers and partners so that they can provide customers with timely, helpful information about our products and services. Our resellers are contractually obligated to abide by this privacy notice, preventing them from sharing your personal data with any other third parties. Several of our resellers are located in the European Union (EU); however, we have determined that our authorized resellers all have suitable safeguards to protect your information. For more information regarding our authorized resellers and their safeguards, request descriptions via our Contact Us section below.
We may also share aggregated or anonymized information that does not directly identify you with third parties.
How Long Do We Keep Personal Data
We will not retain your personal data for longer than required. This means that we will keep your personal data for any or a combination of time periods described as follows: (i) for as long as required by law, (ii) until we no longer have a valid reason for keeping it, (iii) until you request us to stop using it, or (iv) for so long as our customer for which you are an authorized user remains a customer. In addition, we retain your personal data to preserve history in the skillXchange Communities and to provide the ongoing ability to participate. When we delete your personal data from our databases, it will remain in our backup system until it cycles out.
Opt-Out of Marketing
If you reside in the EU or EEA, you have the option to grant your consent for receiving marketing emails from us to promote our own services. Regardless of your location, you may unsubscribe to those emails at any time by using an opt-out link contained in every non-transactional email, by updating your marketing preferences on your account page, or visiting our email subscription preferences pages here for skillXchange services.
Cookies and Similar Technologies
If you would like to modify your cookie preferences or opt-out, click here.
We use third-party vendors’ remarketing tracking cookies and pixels, including the Google Adwords tracking cookie and the tracking pixel. This means we will continue to show ads to you across the internet, specifically on the Google Content Network (GCN) and through NextRoll’s network for remarketing. The third-party vendors, including Google, will place cookies on web browsers in order to serve ads based on past visits to our websites. This allows us to make special offers and continue to market our products to those who have shown interest in them. We do not remarket to users in the European Union.
We engage third-party analytics partners to monitor and analyze our web traffic and to keep track of user behavior on our sites.
Google Analytics (Google) – Google Analytics is a web analysis service provided by Google Inc. (‘Google’). Google utilizes the data collected to track and examine the use of our sites, prepare reports on its activities, and share them with other Google services. You may opt out of the Google Analytics service with the Google’s Browser Add-on that’s available at https://tools.google.com/dlpage/gaoptout.
Children’s Online Policy
Our websites are general audience sites and are not intended for children. Consistent with the U.S. Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect any personal data from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personal data without your permission or consent, we will remove the personal data from our active list, at your request. To request the removal of your child’s information, please contact us as provided below under the Contact Us section, and be sure to include in your message the login information that your child submitted.
Do Not Track Requests
Some web browsers incorporate a ‘Do Not Track’ feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates ‘Do Not Track’ signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to ‘Do Not Track’ signals at this time. As the technology and communication between browser and website improve, we will reevaluate the ability to honor ‘Do Not Track’ signals and may make changes to our policy.
Legal Basis of Processing
We collect and use your personal data based on the following legal grounds.
Consent – In these situations, you have given us consent to process your personal data. For example, when you register for one of our webinars by filling out a webform containing your name and email address.
Legitimate Interest – We process personal data when we have a legitimate interest to do so. Some examples are to maintain and improve our services, inform you of changes to our services, secure our services, and analyze your use of our services and potential sales leads.
Performance of a Contract – This is where we process your personal data to fulfill our contractual obligations to you. For example, we use your personal data to deliver e-learning services you have requested.
Other Legal Bases – There may be times when we are legally obligated to process or share your personal data, such as in response to a subpoena or court order, to protect the vital interests of others, or to defend against legal claims asserted against us.
If you are from outside the U.S., understand that you are sending personal data and Usage Data to the United States where our servers are located. That personal data may be then transferred within the U.S. or back out of the U.S. to other countries outside of your country of residence. Our collection, storage, and use of your personal data and Usage Data will at all times be governed by this Privacy Notice, and in compliance with the General Data Protection Regulation, including the use of Standard Contractual Clauses. Please see our GDPR page for more information on international data transfers.
By accessing or using our services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence.
Privacy Shield Notice
This section applies to individuals located in the European Economic Area (EEA), United Kingdom (UK), and Switzerland.
We have certified our adherence to the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (together as “Frameworks”) and Privacy Shield Principles (“Principles”) as set forth by the U.S. Department of Commerce regarding the transfer of personal data from the EEA, UK, and Switzerland to the United States. To learn more about the Privacy Shield program and to view our certification, please visit https://www.privacyshield.gov/list. We are responsible for processing personal data we receive under the Frameworks and subsequent transfers to a third party acting as an agent on our behalf. We comply with the Principles for all onward transfers of personal data from the EEA, UK, and Switzerland. Please note we no longer rely on the Frameworks as a lawful transfer mechanism with respect to personal data received or transferred pursuant to the Frameworks.
Complaints and Dispute Resolution
In compliance with the EU-US and Swiss-U.S. Privacy Shield Principles, we commit to resolving complaints about our collection or use of your personal information. EEA, United Kingdom, and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at firstname.lastname@example.org regarding skillXchange services.
If we did not resolve your complaints, you may contact your local data protection authority. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Contact details for the EU data protection authorities can be found at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Contact details for the United Kingdom Information Commissioner (ICO) can be found at https://ico.org.uk/. Contact details for the Swiss Federal Data Protection and Information Commissioner (FDPIC) can be found at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html. You may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
You may refer to the Contact Us section below on how to inquire about your rights.
Depending on your location and whether the privacy law of a geographic region applies to you, you may have certain privacy rights such as the right to 1) access – inquire what personal data we have about you, 2) correction – update your personal data, 3) restrict processing – limit how we process your personal data, 4) withdraw consent – a request we stop processing your personal data when permission was originally granted by you permission to do so, 5) deletion – delete your personal data in our system, 6) portability – providing you with a copy of the personal data for transfer to your chosen third party. If we decline your request, we will generally provide you with the reasons.
skillXchange Acting as a Processor – If you are authorized by one of our customers to access our services, our customer is the data controller of your personal data. In those situations, please contact our customer directly with your request. As our customer’s data processor, we will gladly assist our customers and do not have permission to directly honor your request.
This section provides information about the personal data we collect about California consumers and their rights under California Consumer Privacy Act (CCPA).
Under CCPA, California consumers have the following rights:
- Right to receive, once every twelve months, information about third parties with whom we may have shared information about you for our marketing purposes during the previous calendar year along with a description of the categories of personal data shared
- Subject to certain limitations, right to request details about the categories or specific pieces of personal data we collect about you (including how we use and disclose this information)
- Subject to certain limitations, right to delete your personal information (subject to certain limitations)
- Right to opt out of any “sales” that may be occurring
- Right to not be discriminated against for exercising your rights
For more details about the personal data we may have collected about you over the last 12 months, including the categories of sources, please see the How We Collect Personal Data section above. We share this information with the categories of third parties described in the Sharing Personal Data section.
We do not sell your personal data to data brokers, aggregators, and similar third parties for monetary compensation. Thus, you do not need to contact us to request an opt-out. Please note we use third-party cookies for our own advertising purposes as described in our Cookies and Similar Technologies section.
You may exercise your rights under CCPA by sending an email to the address in the ‘Contact Us section below please include “California Privacy Request” in the subject line, the domain name of the website you are inquiring about, along with your name and email address. We will respond to you within thirty days of receiving such a request and will verify your identity using the information associated with your account. You can also designate an authorized agent to exercise your rights on your behalf.
Nevada consumers may submit a do-not-sell request for their personal information.SkillXchange does not sell the personal data of our customers so no-opt out is required. If you have questions, please email us by referring to the ‘Contact Us’ section and note in the subject line “Nevada Privacy Request.”
If you have any questions or complaints about our use of your personal data as related to skillXchange services, please email us at email@example.com. For questions or concerns about skillXchange services, please email us at privacy@skillXchanges.com.
Alternatively, you may write to us at the following address. Please be advised you may receive a delayed response.
16192 Coastal Highway
Lewes, Delaware 19958
If you’re located in the European Economic Area, United Kingdom, or Switzerland, you can also contact your local data protection supervisory authority to lodge a complaint. Contact information can be found in the Privacy Shield Notice section above.