PRIVACY POLICY

This Privacy Policy has been updated on June 10, 2024

We value Your privacy! Please read this document carefully before using SKILLFUL AI's services! This Privacy Policy describes how We collect and use the Personal Data You provide through the Website and/or the Platform (as defined below), as well as the choices available to You regarding Our use of Your Personal Data and how You can access the information.

SKILLFUL Technologies Inc. (Legal address: Advanced Tower, 1st Floor Panama City, Panama, company number: 155747732) (“SKILLFUL AI”, or “We”) is committed to providing You with the needed level of transparency and control over the data We are processing.

By using Our websites www.app.skillfulai.io and www.skillfulai.io (each alone as well as both together — the “Website”, or the “Platform”), and/or services, tools, offline/online components, and features, provided by SKILLFUL AI at the Website and/or the Platform, on any computer/mobile device or another applicable device, You (or “User”) explicitly confirm to Us that You have read, understand and agree to be bound by this Privacy Policy, as well as Our Terms and Conditions accessible at here, which together form an agreement (the “Agreement”) between You and SKILLFUL AI about the use of the Website and/or the Platform, as well as any other applicable law.

We assume that all Users have carefully read this document and agree to its terms and conditions. If one does not agree with this Privacy Policy, they should not use this Website and/or the Platform.

1. GENERAL TERMS

• 1.1. This Policy applies to the following subjects:
• 1.1.1. people who use the Website and/or the Platform in any applicable way as may be available;
• 1.1.2. people who make complaints to Us by email or other available ways.
• 1.2. We do not sell Your Personal Data to third parties. Under the CCPA (as defined below), a “sale” of Personal Data is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal data of a Consumer to another business or third party “for monetary or other valuable consideration”.
• 1.3. However, We may share or transfer Your Personal Data if We enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of Our business assets. Any party that acquires Our business assets as result of such a transaction may continue to use Your Personal Data in accordance with the terms of this Privacy Policy. If We decide to sell the Website and/or the Platform, We will inform You about such decision, so You can forbid Us from transferring Your Personal Data along with Our business. Upon such, We will delete Your Personal Data from the databases prior to a business transfer.
• 1.4. We adhere to the following principles to protect Your privacy:
• 1.4.1. principle of lawfulness, fairness, and transparency — We process Personal Data lawfully, fairly, and transparently concerning the Data Subject in order to protect its individual rights;
• 1.4.2. principle of data minimization — We collect adequate Personal Data, relevant and limited to what is necessary concerning the purposes for which We process Personal Data;
• 1.4.3. principle of purpose limitation — We collect Personal Data for specified, explicit, and legitimate purposes defined prior to data collection and communicated to the Data Subject and not further process in a manner that is incompatible with those purposes;
• 1.4.4. principle of storage limitation — We keep Personal Data in a form that permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data are processed;
• 1.4.5. principle of integrity and confidentiality — We process Personal Data in a manner that ensures appropriate security of the Personal Data, including protection against unauthorized or unlawful processing, or accidental loss, destruction, or damage, using appropriate technical and organizational measures;
• 1.4.6. principle of data accuracy — We accurate Personal Data and, where necessary, keep it up to date. We take every reasonable step to ensure that inaccurate Personal Data, having regard to the purposes for which they are processed, are erased or rectified without delay.

2. TERMS AND DEFINITIONS

• 2.1. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in Our Terms and Conditions.
• 2.2. In this document, the following terms shall be defined as follows:
• 2.2.1. “CCPA” means California Consumer Privacy Act;
• 2.2.2. “EEA” means European Economic Area;
• 2.2.3. “GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation;
• 2.2.4. “Personal Data” means data that is related to an identified or identifiable natural person;
• 2.2.5. “Usage Data” is data collected automatically either generated by the use of the Website and/or the Platform or from the Website and/or the Platform infrastructure itself (for example, the duration of a page visit);
• 2.2.6. “User” also corresponds to the Data Subject, who is the subject of Personal Data.

3. COMPLIANCE WITH DATA PROTECTION LAWS IN APPLICABLE JURISDICTIONS

• 3.1. If You are located in the EEA, privacy rights are granted, and all processing of Personal Data is performed by regulations and rules following GDPR.
• 3.2. If You are located in California, all processing of Personal Data is performed in accordance with regulations and rules following the CCPA, Cal. Civ. Code § 1798.100 et seq.
• 3.3. The relevant data protection law will apply if you are located in another country or territory.

4. PERSONAL DATA THAT WE COLLECT AND PROCESS

• 4.1. We may collect Personal Data from You in various ways and circumstances, including (but not limited to) access to the Website and/or the Platform, filling out a registration form and other forms, providing feedback, responses to surveys, and collecting Personal Data contained in collected Cookie files. We shall be entitled to combine Personal Data collected during Your interaction with different sections of the Website and/or Platform with any other relevant information.
• 4.2. To fulfill Our obligations on the provision of the Platform for You, as well as other obligations and issues as stipulated in applicable Terms and Conditions, We are entitled to ask You to provide Us with Your Personal Data, including (but not limited to):
• 4.2.1. First and last name;
• 4.2.2. Date of birth;
• 4.2.3. Email;
• 4.2.4. Phone number;
• 4.2.5. Password to be set up to use Our services;
• 4.2.6. Other identifying information in emails or other communications from You.
• 4.3. We may also receive information about You from other sources or systems, such as when You sign up or log in using Your account credentials for a separate third-party service, such as Facebook, X, Google account, Thirdweb, or other ones as available. We will receive information from that third party's service as indicated in their relevant authorization screen or as otherwise may be available.
• 4.3.1. To make Our services easier for You to access, You may be able to use Your account credentials with a third party's service Facebook to sign in to Our Website and/or Platform. By doing so, You confirm that You acknowledge and agree that some Facebook account information may be transmitted into Your account with Our Website and/or Platform, and that such Facebook account information transmitted to Us is covered by this Privacy Policy. Such third-party service may collect information about Your browser, online, and other similar activity through its own tracking technologies and according to its own privacy policy at here.
• 4.3.2. To make Our services easier for You to access, You may be able to use Your account credentials with a third party's service X to sign in to Our Website and/or Platform. By doing so, You confirm that You acknowledge and agree that some X account information may be transmitted into Your account with Our Website and/or Platform, and that such X account information transmitted to Us is covered by this Privacy Policy. Such third-party service may collect information about Your browser, online, and other similar activity through its own tracking technologies and according to its own privacy policy at here.
• 4.3.3. To make Our services easier for You to access, You may be able to use Your account credentials with a third party's service Google to sign in to Our Website and/or Platform. By doing so, You confirm that You acknowledge and agree that some Google account information may be transmitted into Your account with Our Website and/or Platform, and that such Google account information transmitted to Us is covered by this Privacy Policy. Such third-party service may collect information about Your browser, online, and other similar activity through its own tracking technologies and according to its own privacy policy at here.

5. PERSONAL DATA, COLLECTED IN AN AUTOMATIC WAY

• 5.1. We may automatically collect data about the devices You use to interact with the Website and/or the Platform.
• 5.2. Personal Data automatically collected by or transmitted to Us in the course of accessing, interacting, and operating the Website and/or the Platform may include, without limitation, the following Personal Data:
• 5.2.1. session data, which may include (but is not limited to) information about the referral source, including the hardware and software information, operating system and version, identifiers associated with Cookies, and other device or browser identifiers;
• 5.2.2. browser, which may include (but is not limited to) the date and time of visits, the pages viewed, Your IP address, time spent at the Website and/or Platform, features You’ve been using, actions taken, the information shown to You, referring webpages addresses and ads that You interacted with;
• 5.2.3. information collected by Cookies and other similar technologies. We and Our service providers may use various technologies to collect information when You interact with the Website and/or the Platform, including Cookies and similar technologies. Where required and where necessary, possible or otherwise appropriate, We will ask You for consent to Our use of Cookies. To view more information on what Cookies We use and how We use them, please review Our Cookies Section in this Privacy Policy.

6. LAWFUL BASIS OF DATA PROCESSING

• 6.1. Under Article 6 of the GDPR, We only process Personal Data if We have a lawful basis for doing so.
• 6.2. The processing of Personal Data, described in clauses 4.1, 4.2, and 4.3 of this Privacy Policy, is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Privacy Policy — to provide access to Website and/or the Platform, provide a greater and better experience with Us, including (without limitation) creating and managing User accounts or other User profiles, processing User orders or other transactions, and invoicing, providing support and assistance in relation to the Service, sending notifications to Users, contact You concerning, and conduct, surveys or polls You choose to take part in and analyze the data collected for market research purposes, and other related purposes.
• 6.3. The processing of Personal Data, described in clauses 5.2.1 and 5.2.2 of this Privacy Policy, is based on a legitimate interest (Art. 6 (1) lit. (f) GDPR) and is performed only for the purposes specified in this Privacy Policy — to provide a greater and better experience with Us, conduct internal research and development and improve, test, and enhance the features and functions of the Website and/or the Platform, analyze the data collected for market research purposes, and other related purposes.
• 6.4. The processing of Personal Data, described in clause 5.2.3 of this Privacy Policy is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Privacy Policy — to provide a greater and better experience with Us and other related purposes.

7. PURPOSES OF DATA PROCESSING

• 7.1. We may use the Personal Data collected from You for various purposes, primarily relating to providing the Website and the Platform and Our services, and information about the Website and the Platform and Our services.
• 7.2. We may also use the information for other purposes as otherwise allowed by law.
• 7.3. We may use and otherwise process Your Personal Data for such purposes, including, but not limited to:
• 7.3.1. provide access to the Website and/or the Platform;
• 7.3.2. meet Your request concerning the Website and/or the Platform to formalize the development of the contractual relationship;
• 7.3.3. handle Your requests, including requests for technical support and assistance;
• 7.3.4. provide You with the products, services, and/or information You requested;
• 7.3.5. provide a greater and better experience with the Website and/or the Platform;
• 7.3.6. personalize Your experience with the Website and/or the Platform;
• 7.3.7. conduct internal research and development and improve, test, and enhance the features and functions of the Website and/or the Platform;
• 7.3.8. for fraud protection activities, providing security, and fixing bugs;
• 7.3.9. meet Our internal and external audit requirements, including Our information security obligations;
• 7.3.10. create and manage User Accounts;
• 7.3.11. process orders or other transactions; invoicing;
• 7.3.12. contact You concerning, and conduct, surveys or polls You choose to take part in and analyze the data collected for market research purposes;
• 7.3.13. respond to Users' correspondence, contact Users when necessary and/or upon their request, and send Users information about SKILLFUL AI, Our Website and/or Platform;
• 7.3.14. send emails and other communications according to Your preferences or display content that We think will interest You;
• 7.3.15. fulfill Our legal obligations under applicable laws, regulations, court orders, or other legal proceedings, for example, preventing, detecting, and investigating security incidents, potentially illegal or prohibited activities, illegal activities or conduct that may violate the Terms and Conditions of SKILLFUL AI and this Privacy Policy;
• 7.3.16. protect property rights of You, SKILLFUL AI, or another party;
• 7.3.17. enforce any agreements with the Users;
• 7.3.18. reply to claims for any publication or other content that infringes the rights of third parties;
• 7.3.19. dealing with disputes;
• 7.3.20. any other purpose as We determine, at Our sole discretion, to be necessary or required to ensure the safety and/or integrity of Our Users, employees, third parties, public, and/or Our services, or to comply with requirements of any applicable law.

8. CONSENT TO PERSONAL DATA PROCESSING

• 8.1. Consent To Processing Of Personal Data.
• 8.1.1. By accepting this Privacy Policy as described herein, You confirm that You are solely responsible for all Your actions/omissions and fully understand the statements, terms, and conditions outlined in this Privacy Policy.
• 8.2. Consent To Processing Of Personal Data By EU Persons.
• 8.2.1. If You are an EU Person and to process Your Personal Data, We need to receive Your consent (as it is prescribed by the GDPR), We will process Your Personal Data only if We have received from You a freely given, specific, informed, and unambiguous indication of Your wishes by which You signify agreement to the processing of Your Personal Data (“Consent”).
• 8.2.2. Ways To Consent. You may give Your Consent by ticking the respective box when You register for a Personal Account with Our Website/Platform and in other cases as may be accessible on the Website and/or the Platform. In the case You tick the respective box, You irrevocably and unconditionally consent and agree that We shall be entitled to process Your Personal Data as indicated by Your Consent.
• 8.2.3. Also, You give Your Consent to receive marketing emails when You tick the respective box for receiving marketing emails when You register a Personal Account or as otherwise available on the Website and/or the Platform. In each letter, You shall be provided with the opportunity to “Opt out of the electronic mailing list”.
• 8.2.4. Your Consent covers all processing activities with Your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, Your Consent should be deemed given for all of them.
• 8.2.5. We only collect the location information where Users have granted Us permission to do so through the obtaining permission system used by their mobile or computer device platforms, including, but not limited to, IOS, Android, etc.
• 8.3. Consent To Processing Of Personal Data by Non-EU Persons.
• 8.3.1. If You are not an EU Person, by transferring to Us Your Personal Data via the Website and/or the Platform or otherwise, You irrevocably and unconditionally consent and agree that We shall be entitled, in accordance with this Privacy Policy, to:
• 8.3.1.1. process in any manner, including collecting, using, storing, disclosing, sharing, and transferring (including cross-border), Your Personal Data so provided to Us, as well as Your Personal Data collected from Your use of the Website and/or the Platform (i.e., Your Personal Data which We collect automatically and/or from other sources); and
• 8.3.1.2. use the Cookies and web beacons (pixel tags) to collect Your Personal Data.

9. THE RIGHTS OF USERS

• 9.1. Subject to possible restrictions under national law, as a Data Subject under the GDPR and other applicable data protection laws, You may have certain rights regarding the Personal Data We collect on You.
• 9.2. Under Chapter 3 of the GDPR, You as a Data Subject may have the rights as follows:
• 9.2.1. Right To Withdraw Your Consent. If Our processing is based on the consent You granted, You may withdraw such consent at any time by contacting Us or by using the functionalities of the Website and/or the Platform, or by replying to the email with Your withdrawal, and Your Personal Data will be deleted immediately. If You withdraw Your consent, it may lead to fewer possibilities to use the Website and/or the Platform;
• 9.2.2. Right To Object. In case Our processing is based on a legitimate interest to run, maintain, and develop Our business, You may object at any time to such Our processing. Then, We shall no longer process Your Personal Data unless for the provision of Our services or if We demonstrate other compelling legitimate grounds for Our processing that override Your interests, rights, and freedoms or for legal claims/proceedings. Notwithstanding any consent granted beforehand for direct marketing purposes, You may prohibit Us from using Your Personal Data for direct marketing purposes, by contacting Us, or by using the functionalities of the Website and/or the Service or unsubscribing possibilities in connection with Our direct marketing messages;
• 9.2.3. Right To Restrict Our Processing. You may obtain from Us restriction of processing of Your Personal Data, as foreseen by applicable data protection law, e.g. to allow Our verification of the accuracy of Personal Data after You contest the accuracy, or to prevent Us from erasing Personal Data when Personal Data is no longer necessary for the initial purposes but still required for Your legal claims/proceedings, or in case Our processing is unlawful. If You restrict processing, it may lead to fewer possibilities to use the Website and/or the Platform;
• 9.2.4. The Right To Access The Data. You have the right to contact Us to get confirmation as to whether or not We are processing any of Your Personal Data. If We process Your Personal Data, We will inform You of what categories of Your Personal Data We process regarding You, the processing purposes, the categories of recipients to whom such Personal Data have been or will be disclosed, and the envisaged storage period or criteria to determine that period;
• 9.2.5. Right Of Data Portability. You may receive Your Personal Data from Us in a structured, commonly used, and machine-readable format and independently transmit those data to a third party if Our processing is based on Your consent and carried out by automated means;
• 9.2.6. Right To Complain. You may complain to any relevant Data protection authority, in particular in the Member State of Your residence, place of work, or the place of processing of Your Personal Data.

9.3. How To Use These Rights?

• 9.3.1. To exercise any of the mentioned rights, You should primarily use the functionalities offered by the Website and/or the Platform. If such functions are not sufficient for exercising such rights, You shall send Us a letter or email to the address set out in this Privacy Policy, where You must include the following: name, address, phone number, email address, and a copy of a valid proof of identity. We may further request any additional information We deem necessary to confirm Your identity. However, We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.
• 9.3.2. If You wish to exercise any of the mentioned rights, please contact Us via Our customer support at support@skillfulai.io.
• 9.4. You may have other rights under the data protection laws applicable in Your jurisdiction.

10. DATA SECURITY

• 10.1. We are committed to ensuring the security of the Personal Data of Our Users!
• 10.2. We follow generally accepted industry standards and maintain technical, physical, and administrative security measures to provide reasonable protection for information provided to Us, both during transmission and once We receive it. When We or Our contractors process Your information, We are committed to making sure that Your information is reasonably protected from unauthorized access, misuse, loss, manipulation, destruction, or unauthorized disclosure through the relevant measures.
• 10.3. Please note that due to the evolving nature of Internet communications and technologies, there is no 100% secure method of transmission over the Internet or method of electronic storage. We do Our best to protect Your information, but We cannot guarantee its absolute security. We cannot provide, and we hereby disclaim any, assurance that the data You provide to Us will remain absolutely secure.
• 10.4. We never process any kind of sensitive data or criminal offense data. Also, We never undertake to profile Personal Data.

11. DATA STORING AND DELETION

• 11.1. We store Your Personal Data for as long as needed to provide You with Our Website and/or Platform, or as long as You use Our Website and/or Platform, or continue communicating with Our customer support at support@skillfulai.io.
• 11.2. We may store Personal Data longer, but only so that it cannot be tracked back to You. When Personal Data is no longer needed, We delete it using reasonable measures to protect the Personal Data from unauthorized access or use.
• 11.3. EU Territory.
• 11.3.1. We store Personal Data as long as needed to provide Our Website and/or Platform.
• 11.3.2. Traffic information is erased or made anonymous when it is no longer needed for the transmission, or in the case of payable service, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added service information (including traffic information used for these purposes) are stored as long as the same is necessary for the provision of these activities or up to the time when a User opts out from such use under this Privacy Policy. Other information is stored for as long as We consider it to be necessary for the provision of Our Website and/or Platform.
• 11.3.3. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary for Us to provide the Website and/or the Platform, or the services You requested.
• 11.3.4. As explained in the GDPR, We strive to anonymize Personal Data when possible. If You decide to exercise Your right to erasure, We will also inform Our providers to delete all Your Personal Data.
• 11.4. US Territory.
• 11.4.1. We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable laws or regulations.
• 11.5. Storing might differ depending on the territory of collecting the information and the applicable laws or regulations, but We always strive to store the information only as long as it is needed to provide, improve, or personalize Our Website and/or Platform.
• 11.6. In some circumstances, We may anonymize and aggregate Personal Data for research or statistical purposes, in which case We may use, disclose, share, and transfer this information, as well as any information that does not identify an individual, indefinitely without further notice to Our Users.

12. THIRD-PARTY CONTRACTORS, OTHER PERMITTED DISCLOSURE

• 12.1. We cooperate with third-party service providers to obtain website hosting, maintenance, and other services for Us. They may be located outside of the EEA. These service providers may have access to or process Personal Data on Our behalf as part of providing those services for Us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions.
• 12.2. We host Our Website and Platform on Amazon Web Services (AWS).
• 12.2.1. AWS provides a cloud platform with a variety of hosting services, including storage, computing, and networking. AWS is a global platform, so Your Personal Data may be transferred to and stored in the US where AWS has servers.
• 12.2.2. We have chosen to host Our Website and Platform on AWS because We believe that it offers a sufficiently high level of security and reliability.
• 12.2.3. As AWS states for the US notice, they must not sell Personal Data of consumers to third parties, as those terms are defined under the CCPA.
• 12.2.4. You can find more information about AWS's privacy practices at its official website via the following links:AWS Privacy;AWS Data Protection.
• 12.3. All data processed by Us is stored exclusively in secure hosting facilities provided by AWS (Oregon, the US).
• 12.4. For The Users In The EEA.
• 12.4.1. All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the EEA may be possible only in the case when We have obtained Your consent for it. When You agree to this Privacy Policy, or when We receive Your consent to Personal Data processing otherwise as described hereunder, it includes that You give Us Your consent for the said transfer to countries outside of the EEA.
• 12.5. For The Users In The US.
• 12.5.1. All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the US may be possible only in the case when We have obtained Your consent for it. When You agree to this Privacy Policy, or when We receive Your consent to Personal Data processing otherwise as described hereunder, it includes that You give Us Your consent for the said transfer to countries outside of the US.
• 12.6. Other Permitted Disclosure.
• 12.6.1. We may share Your Personal Data with Our technical specialists and other of Our employees, contractors, and personnel in connection with the maintenance and support of the Website and/or Platform (and any related system or database) they provide for us. We may also share Your Personal Data with Our professional advisors (lawyers, bankers, auditors, corporate financiers, barristers, insurers, and brokers), in connection with the services they provide for Us. Only those of the foregoing whose duties require access to Personal Data are granted such access, and only to the extent necessary. If We share Your Personal Data with these processors, We will require the recipient to keep it confidential and secure.
• 12.6.2. We may share Your Personal Data with Our business partners such as payment processors and analytics providers who help Us provide You with Our Website and/or Platform. These parties may have access to Your Personal Data so that they may perform these functions on Our behalf, but they may not use Your Personal Data for any other purpose, the ways they collect, use, and process personal information must be in compliance with their privacy notices, policies, and statements as available on their websites or otherwise.
• 12.6.3. We may have to share Your Personal Data to comply with laws and requests of law enforcement entities. We may disclose an individual’s Personal Data to law enforcement officials as We, at Our sole discretion, believe necessary or appropriate to respond to claims and legal processes, to protect Our and/or a third party’s rights and/or property, to protect the safety of the public and/or any person, and/or to prevent and/or stop any activity We may consider to be illegal, unethical, inappropriate, or legally actionable, or that to pose a risk of being such. We also may disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

13. COOKIES POLICY

• 13.1. We use Cookies and similar tracking technologies to track the activity on Our Website and/or Service.
• 13.2. Definitions.
• 13.2.1. Cookies are small data files that are sent from a website to, and stored on, Your device when You visit a website. It may enable Us to collect information about Your device identifiers, IP address, browsers You use to visit the Website/Platform, what web pages, functions, or features You interact with, and what time You spend on each or at all at the Website/Platform, what actions You choose or links click.
• 13.2.2. Other tracking technologies, such as beacons, tags, and scripts, are also used to collect and track information and improve and analyze Our Website and/or Platform. They are typically stored in emails to help Us confirm Your receipt of, and response to, Our emails and to provide You with a more personalized experience when using Our Website and/or Platform.
• 13.3. Purposes. We use Cookies for the purposes specified in this Privacy Policy — to provide access to the Website and/or the Platform, provide a greater and better experience with Our Website and/or the Platform, and for other related purposes.
• 13.3.1. We may use information collected from Cookies to evaluate the effectiveness of Our Website and/or Platform, enhance the features and functions of the Website and/or the Platform, maintain the Website and/or the Platform, determine which parts, features, and functions of Our Website and/or the Platform are most used and the difficulties Our Users may experience within interacting with Our Website and/or the Platform. With this knowledge, We can improve the quality of Your experience with the Website and/or the Platform after determining and providing more of the most desired features and functions, as well as by resolving access difficulties.
• 13.4. Types Of Cookies We Use.
• 13.4.1. Strictly Necessary Cookies are required to navigate Our Website and/or Platform, to operate the basic features and functions of the Website and/or the Platform, and to provide access to such (such as to remember Your Cookies preferences, to access the basic information or secure areas of the Website and/or the Platform). If these Cookies are not used, certain or all basic features or functions may not be offered. Strictly Necessary Cookies cannot be disabled, they are always active and will be placed without Your consent.
• 13.4.2. Functional Cookies help Us to enhance Our Website’s and/or Platform's performance and functionality, and personalize Your experience on Our Website and/or Platform (such as to ensure and enhance the functioning of the connected payment processor(s) or integration with external systems, to recognize You when You return to Our Website and/or Platform, to remember Your choices, e.g. Your region).
• 13.4.3. Session Cookies allow Us to synchronize the interactions of the User during the browser session (to record the information viewed on the Website and/or the Platform, etc.). Session Cookies expire after the browser session, so they will not be stored after it is closed.
• 13.4.4. Please note We do not use Marketing (Targeting) Cookies.
• 13.5. Opt-in or Opt-out of Cookies.
• 13.5.1. We may provide You with the option to allow or deny certain all or all types of Cookies by choosing the preferred or undesired ones in the Website’s and/or the Platform's Cookies Settings. You may be provided with the option to decline all, except strictly necessary Cookies, by choosing “Decline All”, or as another similar naming may be available, on the Website and/or the Platform.
• 13.5.2. If You choose to opt out of the use of all or certain Cookies, You may still receive an opt-out Cookie so that Your decision is saved. If You regularly delete Your Cookies in Your browser, such opt-out Cookie may be deleted as well, so You will have to decide again whether to opt out of the use of Cookies or to accept them for use on Our Website and/or Platform.
• 13.6. You can instruct Your browser to refuse all Cookies. You can also set it to indicate when Cookies are being sent. However, if You do not accept Cookies or do disable the use of Cookies, You may be unable to use or experience Our Website and/or Platform or some of the parts, features, or functions of Our Website and/or Platform. See the links below for more information on most popular browsers: Google; Mozilla Firefox; Safari (desktop); Safari (mobile); Opera; Opera Mobile.
• 13.7. We acknowledge the objective difficulty associated with the identification of Cookies-based technologies. Please contact Us via Our customer support at support@skillfulai.io if You wish to receive additional information about Our use of Cookies on Our Website and/or Platform.

14. THIRD-PARTY WEBSITES

• 14.1. The Website and/or the Platform may contain hyperlinks to third-party websites (including, but not limited to, links to SKILLFUL AI communities on different services or systems).
• 14.2. This Privacy Policy applies to the Website and the Platform. Once redirected to another website, this Privacy Policy is no longer applicable. We are not responsible for the content of such websites, or for how those websites collect, hold, use, and distribute any personal information You provide, including within their Cookies practices. If and when visiting such third-party websites from hyperlinks displayed on the Website and/or the Platform, You should review the privacy notices, policies, or statements of those websites so that You can understand how the personal information You provide will be collected, held, used, and distributed.

15. INFORMATION RELATING TO USER’S AGE; CHILDREN’S PRIVACY

• 15.1. As noted in Our Terms and Conditions, the Platform is not designed for or directed at persons under 13 (thirteen) years of age.
• 15.2. By agreeing to this Privacy Policy, You represent and warrant that You are at least 13 (thirteen) years of age. We do not knowingly collect, solicit, or maintain Personal Data from anyone under the age of 13 (thirteen) or knowingly allow such persons to register for Our Platform. If You are under the age of 13 (thirteen), please do not send any Personal Data about yourself (such as Your name, phone number, email address, or other) to Us. No one under the age of 13 (thirteen) should provide any Personal Data to or on the Platform and/or the Website.
• 15.3. If you are 13 (thirteen) or older, but under 18 (eighteen) years of age, You must have consent from Your parent or guardian to use Our services. In the event that We learn that We have unknowingly collected Personal Data from a person under the age of 13 (thirteen) years, or under the age of 18 (eighteen) without verification of parental/guardian consent, We will not use or maintain that information and will use commercially reasonable efforts to delete that information from Our database as quickly as may be reasonably possible.
• 15.4. We recommend parents to monitor their children’s Internet activities and learn and employ software and other applicable tools that can help their children enjoy their online experience without compromising their personal safety.
• 15.5. Please note that according to each country’s applicable laws, the processing of the Personal Data of a child will be lawful where the child is at another age.
• 15.6. If You have any concerns about Us collecting or processing information in relation to a person under the age of 13 (thirteen) years, please contact Us via email to Our customer support at support@skillfulai.io.

16. CHANGES AND UPDATES TO OUR PRIVACY POLICY

• 16.1. From time to time, We may update this Privacy Policy. We encourage You to periodically check back and review this Privacy Policy so that You always know what data We collect, how We use it, and with whom We share it.
• 16.2. Our updated Privacy Policy will be effective upon posting to the Website and/or the Platform. Your continued access to or use of the Website and/or the Platform shall be considered Your acceptance of the revised Privacy Policy, and its application to all information gathered before and after its effective date.
• 16.3. We may notify You about the updates to this Privacy Policy but We assume no obligation for such notification.

17. DATA CONTROLLER AND RELATED ISSUES

• 17.1. SKILLFUL Technologies Inc., a company (Legal address: Advanced Tower, 1st Floor Panama City, Panama, company number: 155747732), acts as a Data Controller of the Personal Data collected and processed within the scope of this Privacy Policy, and determine the purposes and ways for Personal Data to be processed, under the license granted to Us.
• 17.2. If You have any concerns or questions in this regard, please contact Us via Our customer support at support@skillfulai.io.

18. CONTACT US

18.1. Notices relating to this Privacy Policy may be sent to You via email to the email address You used for registration or provided to Us otherwise. You expressly authorize Us to contact You via such email in the event We (or Our affiliate) are required by law to notify You of a data security incident or data breach.

18.2. If You have any questions, suggestions, or comments, please contact Us via Our customer support at support@skillfulai.io.