This Policy describes how companies in the skills® group with including skills® 2004 UG, Im Technologiepark 1, 15234 Frankfurt, Germany and skills® sp. z o. o. Puławska 145 02-715 Warszawa, Poland (together “ skills® ” or “we”) collect and process data which identify individuals (“Personal Data”) who are customers and other users of our services (“Users”, “you”), and your associated rights. This Policy applies to skills® products and services, including websites operated by skills®. Your privacy is extremely important to us and we are committed to offering you a safe and hassle-free experience while visiting our websites and using our services.
- How We Collect and Use Personal Data
We may collect and/or process your Personal Data only as stated in this Policy, for the purposes described below. We process Personal Data as necessary for our legitimate interests in providing training and related services, to fulfil our contracts with you, and in certain cases based upon your explicit consent.
a. Training Services
skills® provides training services (“Training Services”) as an Accredited Training Organization (ATO). We may collect your Personal Data (including name, address, email address, phone number, video and audio recordings of training sessions, and other information) to confirm your identity, deliver trainings, and ensure the validity of the training process. Certain Personal Data is required to be collected under our procedures to provide you Training Services and other Personal Data is collected to provide you with a good experience.
skills® uses your Personal Data to provide Training Services. We may also use your Personal Data for internal research and development or quality control purposes, and extracts from training work in anonymised form may be reproduced in published training preparation material. In the process of providing Training Services, we create additional Personal Data, including training results. Recordings of training sessions are retained for one (1) year to provide a record of training quality.
Some of our Training Services are offered in cooperation with (i) organisations (including public authorities) that provide training content or otherwise authorise trainings (“Accredited Examination Institutes”) and/or (ii) organisations who are authorised and approved by skills® for delivery of Training Services (“Partners”). Some authorised Partners may also provide training services related to skills® trainings. We may share your Personal Data with those Accredited Examination Institutes, and Partners to the extent necessary to provide you Training Services. We require Accredited Examination Institutes and Partners to comply with data protection law, but we are not directly responsible for their privacy practices. For information on those practices, please refer to the privacy policies of the Accredited Examination Institute associated with your training (our websites contain information about Accredited Examination Institutes) and Partner(s) whose services you use.
skills® maintains a registry containing details of all trained persons.
b. Trainings Services – Support
skills® delivers Training Services in cooperation with an network of Partners, other supporting organisations and individuals, including trainer, training invigilators, assessors, auditors and others. We collect Personal Data of individuals providing such supporting services (“Training Personnel”) in order to ensure training quality and security, including name, address, email address, phone number, employment information (e.g. skills® role and experience), nationality, native language, video and audio recordings of training sessions, and other information. Records are retained for five (5) years from the end of our relationship with Training Personnel (or an unsuccessful application of Training Personnel).
We use Personal Data of Training Personnel to provide Training Services and to manage our relationships with Training Personnel and the entities that employ them. We may disclose Personal Data of Training Personnel to Accredited Examination Institutes whose trainings the Training Personnel are involved in delivering.
c. Online Proctoring
skills® optionally offers trainings with the online proctoring, for Users who wish to take an online exam at their location (i.e. almost anywhere they have internet access). skills® online proctoring connects Users via webcam directly to an authorised skills® proctor (invigilator), who guides them throughout the exam and monitors the exam session.
The online proctoring includes the following photographic records of examination sessions and examination candidates (“Candidates”):
- We record the examination session (video and sound) ensuring its security and integrity. Recordings are retained for one (1) year to provide a record of training integrity.
- For certain proctored exams, we may with notice to the Candidate also take a photograph of the Candidate for ongoing identification purposes and inclusion in the training statement of results (which may be shared with third parties as explained in paragraph 3 below). The photographs are retained according to our retention policy as part of the skills® ’s records of the training results.
d. Online Account
All skills® training Candidates (and in certain circumstances other Users) must have an online account (“skills® Account”), which is created and accessible via the skills® website. Users also may voluntarily create an Account. Your Account contains some or all of the Personal Data that we hold about you, and makes it easier for you to use our services. You may request deletion of your Account at any time by emailing firstname.lastname@example.org although this may reduce our ability to provide you services. We may be required to retain certain Personal Data after account deletion to ensure the functioning of Training Services.
e. Customer Support Services
skills® offers customer support to Users (both organisations and individual Candidates), through email and telephone. Telephone calls may be recorded for monitoring and training purposes, and to improve our services. Telephone recordings are retained for up to fifteen (15) days and emails are retained for up to one (1) year.
We collect data on suppliers of good and services in order to manage our relationships with the suppliers. The information may include personal details of supplier representatives.
g. Marketing Communications
If you have opted in to receiving marketing communications from skills®, we may contact you via various means (e.g. email, telephone) to inform you of new skills® products and services, and other skills® developments. Partners and Accredited Examination Institutes are not permitted to use your Personal Data for marketing or similar purposes, unless specific consent has been given by you. You have the option of opting out of such communications at any time, by using the “unsubscribe” links in the communications or by contacting us at email@example.com.
From time to time skills® may run surveys, polls and similar initiatives (“Surveys”), to request information from Users to assist us to improve our products, services and operating practices. Participation in Surveys is always voluntary, and Personal Data provided in Survey responses will always remain strictly confidential. The results of Surveys may be aggregated and anonymised, and such anonymised information may be shared with third parties.
i. Cookies, Analytics and Customised Advertising
We also use Google Analytics to improve the content and functions of our websites and online proctoring services (by collecting information about how visitors use these services), and the Google AdWords service to provide you with customised advertisements that suit your interests and preferences. Google anonymously collects information such as age, gender, geographical location, webpage views and visits to other websites, including using cookies. You can manage cookie preferences through your Google account, by going to Google Account Settings and editing your preferences. To opt out of being tracked by Google Analytics, you can install the relevant browser add-on available at https://tools.google.com/dlpage/gaoptout.
- Services to Children
Where the User of our services is a child below the age of 16 years, we will request consent for the collection and processing of Personal Data from a holder of parental responsibility over the child.
- Disclosure of Personal Data to Third Parties
We never sell your Personal Data or disclose it to third parties for marketing purposes (if Accredited Examination Institutes whose trainings you take market other services to you, it is their responsibility to comply with applicable data protection law – see paragraph 9 below).
We may disclose Personal Data to third parties in the following circumstances:
- if we have obtained your consent to do so as part of the Training Services, including:
- sharing with Accredited Examination Institutes as described in paragraphs 1.a and 1.b
- during training sessions, through contact among Training Personnel and candidates
- by disclosing your training results:
- to the Partner where you took your training, for sharing with you
- as requested by your employer or other person or entity who booked an training on your behalf (directly or via a Partner)
- when we are required by law or court order, or requested by a regulatory or governmental authority legally authorised to request such disclosure
- if you are suspected and/or investigated for training malpractice
- if required to protect the rights, property or safety of skills® , its business partners or Accredited Examination Institutes.
- Retention of Personal Data
Where retention of Personal Data is required by law, skills® complies with required retention periods. In other circumstances, skills® retains Personal Data for as long as necessary for the business purposes set out above. For certain specific circumstances, shorter retention periods are specified in this Policy.
- Cross-Border Transfer
We aim to comply with the data protection law in all countries where we do business, including the laws of the European Union. We may transfer Personal Data across borders in accordance with applicable law. When we transfer or store Personal Data of EU residents outside the European Economic Area, we do so in compliance with the applicable laws on data protection of the EU and its member states.
- Rights Regarding Your Personal Data
You have the right to access, correct or delete your Personal Data. However, you acknowledge and accept that upon deletion of specific Personal Data, certificate validation and other services provided by skills® may not be available. Under EU law, you have certain rights to restrict of processing of your Personal Data, to withdraw consent to processing that is based upon consent, and of portability of your Personal Data to other service providers. To exercise these rights, please email firstname.lastname@example.org.
- Data Security and Integrity
We use appropriate technical and organisational measures to protect Personal Data from unauthorised use, access, disclosure, alteration or destruction.
- Online Purchases
skills® offers products, trainings and services for purchase remotely and electronically. Payments are processed securely by our selected payment processors. skills® does not store any credit or debit card information. This information is securely provided by Users directly to our payment processors at the time of purchase.
- Third-Party Services and Sites
skills® provides Training Services in cooperation with Accredited Examination Institutes and Partners (see section 1.a above), and skills® websites contain links to third party websites. skills® is not responsible for the privacy practices or the content of any third-party services and websites. For information on other organisations’ privacy practices, you should refer to the privacy policies of those organisations.
- Amendments to Policy
We may revise this Policy to reflect changes in skills® products or the law, or for other reasons. If we make any material change to this Policy, we will notify you by email. You will be bound by any changes to this Policy when you use skills® services after we have provided notice of such changes.
- Questions and Complaints
If you have any questions or complaints relating to this Policy, or your Personal Data that skills® holds, please email email@example.com. You also have the right to complain to the data protection authorities in your country regarding the processing of your Personal Data, to the extent provided by applicable law (e.g. the EU General Data Protection Regulation or relevant privacy laws of other countries).