Legal
Privacy Policy
Last updated: Dec 13, 2024 10:33 AM
We value your privacy very highly. Please read this Privacy Policy carefully before using the SkillCycle Website - Website (the "Website") - or SkillCycle Application (the “Application) - - operated by SkillCycle, a Corporation formed in Delaware, United States ("us," "we," "our"), as this Privacy Policy contains important information regarding your privacy and how we may use the information we collect about you.
Your access to and use of SkillCycle is conditional upon your acceptance of and compliance with this Privacy Policy. This Privacy Policy applies to everyone, including, but not limited to: visitors, users, and others, who wish to access or use the Website or Application.
By accessing or using the Website and SkillCycle Application, you agree to be bound by this Privacy Policy. If you disagree with any part of the Privacy Policy, then you do not have our permission to access or use the Website.
Some of the data cataloged below in this Policy is collected only from paying customers of the SkillCycle platform.
SkillCycle uses data processors to provide technology infrastructure as part of the SkillCycle application. A complete list of data processors is available by contacting us.
What information we collect, where we get this information, how we use this information, what happens if we don't have it, and the legal basis for processing this information
We collect and store any and all information that you enter on this Website. We collect and store the following information about you:
Identifying information
Name
Legal basis for processing
- The user has provided consent to the processing of their information;
- Processing is necessary to perform a contract with the user;
- Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation.
Where we get it
- Information submitted by the consumer.
How we use it
- Performing services;
- Processing or fulfilling orders or transactions;
- Providing customer service.
If we don't have it
- Our use of your data for performing services will not be possible;
- Our use of your data for processing or fulfilling orders or transactions will not be possible;
- Our use of your data for providing customer service will not be possible.
Identifying information
Postal / Shipping address
Legal basis for processing
- The user has provided consent to the processing of their information;
- Processing is necessary to perform a contract with the user;
- Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation.
Where we get it
- Information submitted by the consumer.
How we use it
- Performing services;
- Processing or fulfilling orders or transactions;
- Providing customer service.
If we don't have it
- Our use of your data for performing services will not be possible;
- Our use of your data for processing or fulfilling orders or transactions will not be possible;
- Our use of your data for providing customer service will not be possible.
Identifying information
Billing address
Legal basis for processing
- The user has provided consent to the processing of their information;
- Processing is necessary to perform a contract with the user;
- Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation.
Where we get it
- Information submitted by the consumer.
How we use it
- Performing services;
- Processing or fulfilling orders or transactions;
- Providing customer service.
If we don't have it
- Our use of your data for performing services will not be possible;
- Our use of your data for processing or fulfilling orders or transactions will not be possible;
- Our use of your data for providing customer service will not be possible.
Identifying information
Phone number
Legal basis for processing
- The user has provided consent to the processing of their information;
- Processing is necessary to perform a contract with the user;
- Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation.
Where we get it
- Information submitted by the consumer.
How we use it
- Performing services;
- Processing or fulfilling orders or transactions;
- Providing customer service.
If we don't have it
- Our use of your data for performing services will not be possible;
- Our use of your data for processing or fulfilling orders or transactions will not be possible;
- Our use of your data for providing customer service will not be possible.
Identifying information
Email address
Legal basis for processing
- The user has provided consent to the processing of their information;
- Processing is necessary to perform a contract with the user;
- Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation.
Where we get it
- Information submitted by the consumer.
How we use it
- Marketing and advertising;
- Performing services;
- Processing or fulfilling orders or transactions;
- Providing customer service.
If we don't have it
- Our use of your data for marketing and advertising will not be possible;
- Our use of your data for performing services will not be possible;
- Our use of your data for processing or fulfilling orders or transactions will not be possible;
- Our use of your data for providing customer service will not be possible.
Identifying information
Company
Legal basis for processing
- The user has provided consent to the processing of their information;
- Processing is necessary to perform a contract with the user;
- Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation.
Where we get it
- Information submitted by the consumer.
How we use it
- Analytics;
- Marketing and advertising;
- Performing services;
- Processing or fulfilling orders or transactions;
- Providing customer service;
- Undertaking internal research for technological development and demonstration.
If we don't have it
- Our use of your data for analytics will not be possible;
- Our use of your data for marketing and advertising will not be possible;
- Our use of your data for performing services will not be possible;
- Our use of your data for processing or fulfilling orders or transactions will not be possible;
- Our use of your data for providing customer service will not be possible;
- Our use of your data for undertaking internal research for technological development and demonstration will not be possible.
Employment information
Individual and organization goals, feedback and sentiment about job satisfaction and performance
Legal basis for processing
- The user has provided consent to the processing of their information;
- Processing is necessary to perform a contract with the user;
- Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation.
Where we get it
- Information submitted by the consumer.
How we use it
- Analytics;
- Performing services;
- Processing or fulfilling orders or transactions;
- Providing customer service;
- Undertaking internal research for technological development and demonstration;
- This information is collected to provide organizations with qualitative and quantitative data about employee sentiment and satisfaction and to provide end individual users with feedback and guidance for their career development..
If we don't have it
- Our use of your data for analytics will not be possible;
- Our use of your data for performing services will not be possible;
- Our use of your data for processing or fulfilling orders or transactions will not be possible;
- Our use of your data for providing customer service will not be possible;
- Our use of your data for undertaking internal research for technological development and demonstration will not be possible;
- Our use of your data for this information is collected to provide organizations with qualitative and quantitative data about employee sentiment and satisfaction and to provide end individual users with feedback and guidance for their career development. will not be possible.
Commercial information
Industry
Legal basis for processing
- The user has provided consent to the processing of their information;
- Processing is necessary to perform a contract with the user;
- Processing is necessary in order to take steps that the user has requested prior to entering into a contract.
Where we get it
- Information submitted by the consumer.
How we use it
- Marketing and advertising;
- Performing services;
- Processing or fulfilling orders or transactions;
- Providing customer service.
If we don't have it
- Our use of your data for marketing and advertising will not be possible;
- Our use of your data for performing services will not be possible;
- Our use of your data for processing or fulfilling orders or transactions will not be possible;
- Our use of your data for providing customer service will not be possible.
Internet or other electronic activity
Information regarding your interaction with our website or application
Legal basis for processing
- The user has provided consent to the processing of their information.
Where we get it
- Information submitted by the consumer;
- Tracking pixels.
How we use it
- Analytics;
- Performing services;
- Providing customer service.
If we don't have it
- Our use of your data for analytics will not be possible;
- Our use of your data for performing services will not be possible;
- Our use of your data for providing customer service will not be possible.
How we share your information:
With the relevant Customer and people it authorizes. If you use the Service through an organization, information available in the workspace - including account details, usage or participation data, reports, and content or metadata made available by the Service -may be accessible to administrators, managers, coaches, or other people designated by that Customer, depending on the features used and the Customer's configuration.
With coaches and collaborators. We may share information with human coaches or other participants as needed to provide coaching, scheduling, collaboration, or related Service functionality.
With service providers and subprocessors. We may share information with vendors that help us operate the Service, such as hosting, infrastructure, AI, analytics, communications, support, payment, and security providers. These providers act on our behalf and are subject to contractual restrictions.
For legal, safety, and business reasons. We may disclose information to comply with law, legal process, or governmental requests; to protect rights, safety, and security; to investigate fraud or violations of our terms; or in connection with a merger, financing, acquisition, reorganization, bankruptcy, or sale of assets.
Customers that have contractual rights relating to subprocessors, incident notices, deletion timelines, or similar operational commitments will receive those rights under the applicable Customer agreement, order form, or data processing addendum.
How we protect your personal information
We have implemented the following measures to protect and safeguard your personal information:
- Limiting the amount of personal information that we collect to strictly necessary only
- Using SSL encryption or other secure technologies when receiving or sending personal information beyond internal networks
- Destroying and/or deleting personal information once we no longer need it
- Performing regular risk assessments
- Mitigating risks by following a risk treatment plan
- Having comprehensive written security policies and procedures
- Screening (e.g. performing background checks) all employees with access to personal information
- Training our employees on best security practices
- Requiring our employees to sign confidentiality agreements
- Encrypting laptops, USBs and other portable media
- Implementing and monitoring intrusion prevention and detection systems (e.g. anti-virus software)
- Maintaining up-to-date software and safeguards
- Performing regular due diligence of vendors who have access to personal information
No method of transmission or storage is completely secure. If you believe your account or information has been compromised, please contact us promptly at support@skillcycle.com.
Sale of your information
We do not sell your personal information.
Cookies and Similar Technologies
We use cookies, pixels, and similar technologies to operate our website and the Service, remember preferences, analyze usage, support security, and improve performance. Where required by law, we obtain consent for non-essential cookies. You can control cookies through browser settings or our cookie preference tools, but disabling cookies may affect functionality.
Children's privacy
This Website is intended for use by a general audience and does not offer services to children. Should a child whom we know to be under 18 send personal information to us, we will use that information only to respond to that child to inform him or her that they cannot use this Website.
Data Retention
We retain information for as long as reasonably necessary to provide the Service, maintain our business relationship, support legitimate business operations, comply with law, resolve disputes, and enforce agreements. Retention periods vary depending on the type of information, the purpose for which it was collected, account status, Customer instructions, and any applicable contractual commitments.
If you use the Service through a Customer, retention and deletion of Customer Data are generally governed by that Customer's instructions and our agreement with the Customer. We may retain copies in backups or archival systems for a limited period consistent with business continuity, security and legal requirements. We may also retain de-identified or aggregated information for longer.
AI Features and Automated Processing
Optional AI features
Certain features of the Service use artificial intelligence, including SkillCycle's AI coaching and content-generation capabilities ("AI Features"). AI Features are optional and may be enabled or disabled by the relevant Customer. If a Customer disables AI Features, the AI-specific processing described in this section will not apply while those features remain disabled.
How we use data in AI Features
AI Features may process prompts, files, conversation history, profile information, goals, feedback, and other context necessary to generate summaries, recommendations, coaching content, and other outputs. We may use third-party AI, cloud, and infrastructure providers to operate these features.
We may use inputs, outputs, feedback, usage signals, and related logs to operate AI Features, respond to support requests, investigate incidents, enforce policies, evaluate quality and safety, and improve the Service. Where feasible and appropriate, we use de-identified or aggregated information for product improvement. In some cases, limited review of identifiable information may be necessary for support, troubleshooting, safety, abuse prevention, quality assurance, or to investigate product issues, subject to access controls, customer agreements, and applicable law.
We do not use Customer Data to train generalized or shared AI models, or permit third-party AI providers to do so, unless we clearly disclose that use and obtain any required authorization. This restriction does not prevent us from using Customer Data within the Service to provide requested functionality, personalize results, support quality assurance, maintain safety and reliability, or operate customer-specific configurations and workflows.
Third-party AI providers may retain data for limited periods as needed to provide the requested service, maintain security, prevent abuse, investigate incidents, or comply with law, subject to our contracts and controls.
Human review and important decisions
AI outputs are probabilistic and may be incomplete, inaccurate, or unsuitable for a particular purpose. SkillCycle is designed to support human judgment, not replace it. SkillCycle does not intend for AI Features to make solely automated decisions that produce legal effects or similarly significant effects without meaningful human involvement. Customers and users are responsible for how they use AI outputs.
Responsible AI use
We are committed to using AI in ways that benefit our users and society. We strive to:
develop AI systems that augment human capabilities rather than replace human judgment;
avoid using AI for purposes that could cause harm or violate human rights;
consider the environmental impacts of our AI systems and minimize their carbon footprint;
ensure our AI systems are accessible to users with diverse needs and abilities;
continuously evaluate and improve our AI practices based on evolving standards and feedback.
Your Rights and Choices
Depending on your location and the context in which we process your information, you may have rights to access, correct, delete, or port personal information; object to or restrict certain processing; withdraw consent where processing is based on consent; opt out of marketing communications; and, where provided by law, exercise rights relating to automated decision-making or profiling.
If you use the Service through a Customer, that Customer controls most workspace data and is often best positioned to respond to your request. We may forward or direct your request to the relevant Customer where appropriate.
For individuals in the European Economic Area or the United Kingdom, our legal bases for processing personal information generally include performance of a contract, legitimate interests, consent, and compliance with legal obligations, depending on the context. Residents of certain U.S. states may also have additional rights under applicable privacy laws.
To exercise your rights or ask a privacy question, contact us at support@skillcycle.com. We may need to verify your identity and will respond as required by applicable law.
Exercising your rights and Complaints/Questions
Contact Us
SkillCycle, Inc.
Email: support@skillcycle.com
Website: www.skillcycle.com
Mailing Address: 26 Broadway, 3rd Floor, New York, NY 10004
Any such complaints must first be addressed to us in writing as required by Australia Privacy Act 1988 S 40(1A). We will respond to all complaints within a reasonable time (usually 30 days). If you are not satisfied with our response to your complaint, you may then lodge a complaint with the Office of the Australian Information Commissioner by following the steps on the Lodge a Privacy Complaint (Australia) page.
Residents of the United Kingdom may lodge a complaint with the United Kingdom Information Commissioner's Office by following the steps on the Lodge a Privacy Complaint (United Kingdom) page.
Third-party websites
This Website may contain hyperlinks to websites operated by parties other than us. We provide such hyperlinks for your reference only. We do not control such websites and are not responsible for their contents or the privacy or other practices of such websites. It is up to you to read and fully understand their Privacy Policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators.
Transferring data -International transfers
SkillCycle is headquartered in the United States, and we and our service providers may process personal information in the United States and other countries. Where required by law, we use appropriate safeguards for international transfers, such as Standard Contractual Clauses or other approved mechanisms.
Changes to Privacy Policy
We reserve the right to amend this Privacy Policy at any time. We will notify you of any changes to this Privacy Policy by posting the updated Privacy Policy to this website or application.