Skillmore Privacy Policy

Effective 05/12/2023

This Privacy Policy (“Policy”) describes the information collected by or on behalf of Talent Mobility, LLC a Delaware limited liability company d/b/a Skillmore (“Skillmore,” “we,” “us,” or “our”) through our website(s) Skillmore.com (“Sites”) and our interactions with you both online and offline, and how the information is used, protected, and shared. If you have questions or concerns about this Policy, please contact us as set forth below.

Skillmore’s customers are typically business enterprise customers (“Business Customers”). This Policy does not cover how we process information on behalf of our Business Customers. Information we collect, receive, or process on behalf of our Business Customers is governed by our contractual agreements with them and we only process such information according to our such Business Customer’s instructions. If you have any questions or concerns about how such information is handled or would like to exercise any rights you may have with respect to your Personal Information (as defined below), you should contact the relevant Business Customer who has contracted with us for the use of our products and services. Skillmore cannot respond directly to your request. We will assist our Business Customers in accordance with applicable laws and our contractual obligations.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE THE SECTION BELOW TITLED “CALIFORNIA RESIDENT PRIVACY RIGHTS” FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.

If you use our Sites, you must comply with our Term of Use ("Terms") found at terms & conditions.

WE MAY MODIFY THIS POLICY AT ANY TIME. ALL CHANGES WILL BE EFFECTIVE IMMEDIATELY UPON POSTING TO OUR SITES. MATERIAL CHANGES WILL BE CONSPICUOUSLY POSTED ON OUR SITES OR OTHERWISE COMMUNICATED TO YOU.

1. Information We Collect

We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”) when you use our Sites, and otherwise interact with us (collectively, “Services”). The information we collect falls into three categories: (a) information you provide to us; (b) information we collect through automated methods when you use our Services; and (c) information we collect from other sources (as further detailed below).

You can visit our Sites without submitting Personal Information. However, Personal Information is required to use certain Services, for example, to create an online account, purchase products, contact us via email or phone (where we may retain your message’s content and our response), receive or request data from us (e.g., catalogs and newsletters), and respond to communications from us (e.g., surveys and promotional offers). In such circumstances, we may be unable to provide you with our Services unless you provide your Personal Information.

2. Information You Provide to Us

We collect Personal Information that you provide directly to us. If you elect to provide data that personally identifies you such as your name, personal or business email address, mailing address, and phone number and we will collect, use, and share such Personal Information pursuant to this Policy and applicable law. This may occur in the following ways:

Online Accounts. To create an online account, you must submit your name, business email address, and phone number. This data is used to populate a profile within your account.

Marketing Communications; Email Opt-Out. If you opt-in to receive marketing communications from us, you must submit your name, email address, and phone number. We use this data to send you promotional and other electronic communications. We may use third-parties or service providers to deliver communications to you. You may opt-out of such marketing emails by using the unsubscribe link in the email. Opting out of marketing communications does not opt you out of non-marketing communications, such as emails about your account or transactions

Business Contracts with Us. When a business contracts directly with us for the purchase of our products or services, we may collect the business contact information of those involved. The processing of any information provided in such a business context is governed by the contracts between that business and Skillmore.

Feedback. When you provide comments or feedback about our Sites, the content on our Sites, or our products ("Feedback"), we will not treat that Feedback as confidential, and we may use that Feedback for any purpose in our sole discretion. Feedback will be used without attribution or compensation to you.

3. Data Automatically Collected

We may use automated technology to collect information from your computer system when you use our Services. This may include the following:

Account Activity. We may collect data about how you use (i) your online account, and (ii) our Sites when you are logged into your account. We may combine data automatically collected from you with other Personal Information about you

Cookies and Other Tracking Technologies. We may use cookies, web beacons, pixel tags and other tracking technologies (collectively "Cookies") on our Sites. A cookie is a small text file that our Site saves onto your computer or device when you use our Sites that provides us certain information about your activities. Cookies allow our Sites to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

Most browsers automatically accept Cookies. You can disable this function by changing your browser settings but disabling Cookies may impact your use and enjoyment of our Sites. Not all features or functions of our Sites may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of our Sites.

The Cookies on our Sites may collect information such as:

  • IP addresses assigned to the computers and other devices you use;
  • your internet service provider;
  • device ID number;
  • approximate geographic location;
  • browser type;
  • Site pages visited;
  • websites you access before and after visiting our Sites; and
  • data related to how and when you use our Sites.

Data from Other Sources. We may obtain data about individuals from various third-party companies and public sources and we may combine that data with other Personal Information. This enhances our existing data about our users, improves our ability to contact you, and enhances our marketing capabilities.

4. How We Use Your Information

We may use Personal Information that we collect for the following purposes:

As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.

Administration. We may use Personal Information for administrative purposes, such as managing your accounts, facilitating transactions, to inform our business strategies, and to understand our Sites’ demographics and user preferences.

Site Management. We may use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of our Sites, statistical and other analyses of our Sites, and to customize our Sites to you and our users.

Business Analytics. We may use Personal Information for business analytical purposes, including consumer and operations research, to assess the effectiveness of our sales, online service, marketing, and advertising, and to analyze market trends and (future) customer demand

Advertising and Communications. We may use Personal Information to send you promotions, to notify you of new services, products or programs, to notify you of new features of our Sites, to notify you of changes to our Terms or this Policy, and for other similar communications.

To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Sites, or to other users of our Sites. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.

How We Use Data Collected by Automatic Technologies. We may use Cookies to: (i) make our Sites function properly; (ii) provide personalized experiences; (iii) tailor our interactions with you; (iv) help with our marketing efforts; (v) provide us with valuable data and statistics about the usage and effectiveness of our Sites and to help us improve our Sites; and (vii) help us improve our Services.

Analytics. We may use Google Analytics and other analytic tools to collect and process information about your use of our Sites. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Sites. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

5. Retention of Personal Information

We will keep Personal Information for the period necessary to fulfill the purposes described in this Policy, unless a longer retention period is permitted or required by law.

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law.

6. Disclosure of Personal Information

We do not sell, rent or lease Personal Information to any third party. We may share Personal Information with the following categories of parties, in compliance with applicable laws:

Employees and Affiliates. We may disclose Personal Information with our employees and affiliates (including affiliate employees) who have a need to know the information for our business purposes.

Third-Parties and/or Service Providers. We may disclose Personal Information with third parties and/or service providers that provide services for us. We have contracted with our service providers to protect any such Personal Information. For example, we may disclose Personal Information with vendors to help us host and manage our Sites; and other marketing; improve the content and functionality of our Sites; perform data analysis and statistical analysis; troubleshoot problems with our Sites; provide payment processing services and online storefronts; and support or provide the security of our Sites. For purposes of this section, the term “service provider” may include our affiliates and ”service providers” of our affiliates.

Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of Skillmore or any other party.

Professional Advisors. We may disclose Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Skillmore.

Change in Ownership. In the event Skillmore is the subject of a change of control or in the event our Sites changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).

Other. We may disclose Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

7. Use and Disclosure of Non-Personal Information.

Skillmore may collect, use, disclose, transfer and otherwise process de- identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Skillmore is the sole and exclusive owner of such de-identified and aggregated information, including if Skillmore de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.

8. Children's Information

Our Sites are not directed at children under 18 years of age. We do not knowingly collect, sell, use, or share Personal Information from children under 18. If we obtain actual knowledge that any Personal Information, we collect has been provided by a child under the age of 18, we will promptly delete that information. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.

9. Data Security

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

10. Social Media

We may be active on social media, including on Facebook, YouTube, Twitter, Instagram and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on our Sites and our Social Media pages any comments or content that you post on our Social Media pages

Our Sites may allow you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. Our Sites may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access our Sites.

Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

11. Access from Outside the United States

If you access our Sites from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.

12. Third-Party Websites

Our Sites may link to, or be linked to, websites not controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

Contact Us

If you have questions or concerns regarding this Policy, contact us at:

Skillmore


questions@skillmore.com

4035 S. Riverpoint Parkway #6025, Phoenix AZ 85040


CALIFORNIA RESIDENTS’ PRIVACY RIGHTS

This section provides additional terms that apply to residents of California. In the event of a conflict between this section and the remainder of this Policy, this section shall take precedence for California residents. In this section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018, as amended, and including its implementing regulations (the “CCPA”).

The Collection, Source, Purpose and Sharing of Your Personal Information.

Categories of Personal Information. We may collect the following categories of Personal Information:

  • Ientifiers consisting of: real name, alias, postal address, unique personal identifier, online identifier, phone number, internet protocol address (“IP Address”), email address, or other similar identifiers.

  • Commercial Information consisting of :customer billing information, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Internet Activity consisting of : browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.

  • Inferences drawn from information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

In the twelve (12) months prior to the Effective Date of this Policy, we have not collected any of the preceding categories of Personal Information.

Categories of Sources From Which Personal Information is Collected. The categories of sources from which your Personal Information is collected is described in Section 1 (Information We Collect)

Purposes for Collecting Personal Information. Our purposes for collecting your Personal Information are described in Section 2 (How We Use Your Personal Information)

Categories of Third Parties / Services Providers With Whom Personal Information is Disclosed for a Business Purpose. In the last 12 months preceding the Effective Date of this Policy, we did not disclose Personal Information for a Business Purpose. We have not used or disclosed Sensitive Personal Information for any reason other than the reasons for which it was provided to us

California Residents Data Rights.

Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their personal information:

  • Right to request disclosure of categories. California residents have a right to request access to the following information: (a) the categories of personal information we collected from you in the 12 month period prior to your request, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting your personal information(d) the categories of third parties with whom we disclosed your personal information; and (e) the categories of personal information we disclosed in the 12 month period prior to who your request. California residents also have a right to access a list of categories of personal information we sold or disclosed for a business purpose in the last 12 months, if any

  • Right to request access. California residents have a right to request that we disclose to you the specific pieces of Personal Information that we have collected about you in the 12-month period prior to your request and receive a copy of your electronic personal information in a readily- usable format.

  • Right to correct inaccurate data. California residents have a right to request the correction of personal information we collected about you.

  • Right to deletion. California residents have a right to request that we delete personal information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

  • Right to Opt-out of Sale. You have the right to opt-out of the sale or sharing of your Personal Information. In the 12 months preceding the Effective Date of this Policy, we have not sold or shared Personal Information of any individual for compensation or cross-contextual behavioral advertising and we currently do not sell or share Personal Information. We do not have any actual knowledge that we have sold or shared Personal Information of any individual under the age of 16 for monetary compensation or for cross-context behavioral advertising

How to Exercise Your Rights. To exercise your California rights described in this section, you may submit your request to us by contacting us at questions@skillmore.com.

Verifiable Consumer Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. This information may vary depending on the Personal Information we already have.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

Authorized Agents. You may only make a request to exercise your rights on behalf of yourself, or a parent or legal guardian may make a request on behalf of their child. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to be your agent and to make the specific request submitted, unless the agent is subject to a Power of Attorney under California probate laws. If the agent is a Power of Attorney under California probate laws, we may require evidence of that status.

When We Will Respond. We will confirm receipt of your request within 10 business days. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Sensitive Personal Information. Skillmore does not use or disclose Sensitive Personal Information for purposes that, under applicable law, require us to offer consumers a “Right to Limit” the use or disclosure of Sensitive Personal Information

Right to Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. Should you wish to exercise any of your rights as detailed above, we will not discriminate against you by offering you different Services based solely upon your exercise of the above rights.

CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. WE CURRENTLY DO NOT RESPOND TO “DO NOT TRACK” REQUESTS.

Contact Us

If you have questions or concerns regarding this Policy, contact us at:

Skillmore

questions@skillmore.com

4035 S. Riverpoint Parkway #6025, Phoenix AZ 85040