Privacy Policy

Updated: November 1, 2021

Skillable values your privacy. This Privacy Policy (the “Policy”) explains the privacy practices of Hands-On Learning Solutions, LLC d/b/a Skillable (“we,” “us” or “our”) and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website (the “Site”), as well as through social media and marketing activities. Please read this Policy carefully. European residents, please see our Notice to European Users to learn more.

When we refer to “you,” “your” or “User,” we are referencing the individual user of our website. References in this policy to “Customers,” means an entity or organization that contracts with us to provide a product or service to an end user of a product or service.

OUR COLLECTION OF PERSONAL INFORMATION

The information we collect depends upon your interactions with us and your internet browser settings. Personal information we collect includes:

• Contact data, such as your first and last name, email address, mailing address, home and work telephone number, company name, job title, work mailing address, facsimile number, and other similar contact information.
• Demographic information, such as your age, gender, country and preferred speaking language.
• Profile data, such as login credentials, including your user ID, password and any other pertinent security details, which are necessary to authenticate and provide you with access to our Site.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them, information you share when you sign up for special offers, or information you share when you complete a survey.
• User-generated content
• Communications that we exchange with you, including when you contact us with questions or feedback.
• Data about others. Users of the Site may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
• Device data, such as your device type, the name of the internet browser you use to browse our website, Internet Protocol (“IP”) address, geolocation data including global positioning system data, network name, and internet or telecommunication services provider name.

Cookies 

Our Site utilizes cookies. When you use our Site we will collect information from and store cookies on your computer in order to optimize your user experience by showing you new and relevant content based upon your prior browsing history on our website. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your internet browser permits) that can later be retrieved to identify you to us. Our cookies store a randomly assigned user identification number necessary to keep you logged into our Site. You are free to decline our cookies if your browser permits, but some parts of our Site will not work properly.

When Skillable collects personal data on Microsoft’s behalf in support of Microsoft offered content, Skillable uses the Microsoft Privacy Statement to use and protect your data, available for review at https://privacy.microsoft.com/en-us/privacystatement. 

How We Use Your Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Site delivery. We may use your personal information to:

• provide, operate and improve the Site and our business;
• establish and maintain your user profile on the Site;
• facilitate your invitations to friends who you want to invite to join the Site;
• enable security features of the Site, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Site, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Site and our communications; and
• provide support for the Site, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Site and our business.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as responding to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Site; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

• Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
• Service providers. Third parties that provide services on our behalf or help us operate the Site or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics). Your personal information is only used by our Service Providers to the extent necessary to carry out their contractual obligations to us for providing services.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Skillable or our affiliates (including, in connection with a bankruptcy or similar proceedings).
• Other users and the public. Your profile and other user-generated content (except for messages) may be visible to other users of the Site and the public.

Your Choices on Our Collection and Use of Your Personal Information

Users that opt in to receiving email communications regarding our products and services have the option to unsubscribe to such email communications at any time by clicking the unsubscribe link at the bottom of promotional emails or by emailing [email protected].

You have choices with respect to cookies. Depending upon your chosen internet web browser, you may have the option to reject all cookies by modifying your browser preferences. Rejecting cookies will limit the functionality of some portions of our website. Learn more about your options in our Cookie Policy.

Please be aware that when you voluntarily disclose personal information (i.e. your name, email address, etc.) in any discussion forums or other public areas on this website, that such information becomes available to be collected and used by third parties, which may result in your receiving unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information or solicitations that you choose to make public. You hereby expressly acknowledge and agree that by providing any submission of information in a chat rooms or in other public areas on this website are publicly accessible to all third parties and that you assume any and all risk, harm and damages arising from or in any way connected to your submission and the information in such public forums. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. You are solely and exclusively responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you’re online.

Security of Your Information

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

Privacy Policies of Third-Party Sites

This Policy only addresses our use and disclosure of the information we collect from you. Other sites accessible through our Site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy.

Do Not Track

Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

International Data Transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

If we transfer your personal information from Europe to another country such that we are required to apply appropriate safeguards to your personal information under European data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Changes to This Privacy Policy

We will occasionally update this privacy policy to reflect changes in our business. When we post changes to this Policy, we will revise the “last updated” date at the top of this policy. If there are material changes to this policy or in how Skillable will use your personal information, we will notify you as appropriate, such as by prominently posting a notice of such changes on the Site or by emailing you a notification of the change to the extent you have registered for a newsletter or have an account. We encourage you to periodically review this policy to be informed of how Skillable is using your information.

Contact Us

If you have any questions regarding this Policy or our privacy practices, you may contact us at [email protected] or:

Hands on Learning Solutions, LLC d/b/a Skillable
PO Box 1499
New Port Richey
Florida, 34656-1499

Notice to European Users

The information provided in this “Notice to European Users” section applies only to individuals in the United Kingdom, Switzerland, and the European Economic Area (hereafter collectively referred to as “Europe”). References to “personal information” are equivalent to “personal data” governed by European data protection legislation.

Hands on Learning Solutions, LLC d/b/a Skillable is the controller of personal information collected via the Site. You can contact us as described here. When we are acting on behalf of a Customer, the Customer is the controller.

Legal Basis for Processing

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing purpose Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.	Legal basis
Site delivery	Processing is necessary to perform the contract governing our provision of our Site or to take steps that you request prior to signing up for the services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request.
Research and development, marketing and advertising, compliance and protection and/or sharing your personal information as described in this Privacy Policy	These activities may constitute our legitimate interests, may be necessary to perform the contract governing our provision of our services or to take steps that you request prior to signing up for the services, or may be based on your consent. To the extent that these activities constitute our legitimate interests, we do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
With your consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the services.

Retention Schedule for Your Personal Data

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.

Your Rights

European data protection laws give you certain rights regarding your personal information. If you are a European resident, you may ask us to take the following actions in relation to the personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
• Withdraw consent. Where our processing of your personal data is based upon your consent, you have the right to withdraw your consent at any time.

You may exercise any of the aforementioned data rights by contacting us, in writing, via mail or at [email protected].

Notwithstanding any of the aforementioned rights, you also have the right to lodge a complaint against us with the applicable Supervisory Authority.