SkillThru LTD (SkillThru, Website or Controller) processes data in accordance with the provisions of European Regulation 2016/679 and current English legislation on the protection of personal data.
1. PROCESSING METHODS AND DATA RETENTION
Anyone can access our Website without the necessity to register an account. Therefore, limited use of the Services is always possible without the provision of your personal details (for example, browse the Website, look through the list of tutors, review the variety of services, etc.). However, whenever a user accesses the Website SkillThru collects log information and puts cookies on the user’s device, by which it tracks the activity on the Website. After registration SkillThru may collect and process Cookie identifiers and those data specifically provided by users.
The data are processed:
• in full compliance with applicable legislation, based on the information provided and in a fair and transparent manner;
• collecting a minimum number of data and in any case collecting only the data strictly necessary for the functioning of the website;
• in a precise and updated way;
• retaining the data only for the time necessary to guarantee the functioning of the site and to comply with any regulatory obligations. The data will then be deleted or anonymized.
Specific security measures are observed to prevent data loss, illicit or incorrect use, and unauthorized access.
2. PERSONAL DATA COLLECTED
• Browsing data: the software systems and procedures on which this website runs might process some personal data whose transmission is inherent to the Internet’s communication protocols. The aforementioned data category (which includes, for example, but not exhaustively, IP and DNS addresses) is processed by the controller for statistical reasons and in an anonymous form but can be cross-correlated through a series of operations in order to render the user identifiable, for instance, to ascertain its liability in case of damages to the website’s infrastructure
• Students Personal Data: login credentials (username and passwords), first name, last name, email, photo
• Mentors Personal Data: login credentials (username and passwords), first name, last name, email, age, timezone, language spoken, photo, a personal description/introductory video, education history, job history
• Billing information: details of transactions carried out through the Website (as ID, date, and time of transaction).
• Posting of Information: SkillThru may also process information provided by users (including content and messages) posted on/through the Website, including personally identifiable information. By doing so, the user acknowledges that any information shared through the Services will be available to SkillThru and to other users of the Services (students/tutors).
• Minor’s data: SkillThru services are not intended for use by children under the age of 16 without the express permission of their parents or legal guardians. The Website may process the personal data of children under the age of 16, provided that the data has been provided by consent of the parents / legal guardians for the express purpose of using the SkillThru Services.
• Sensitive data: no particular categories of data will be processed (articles 9 and 10 European Regulation 2016/679)
3. LAWFUL BASES FOR PROCESSING
SkillThru processes personal data only when:
• processing is based on the consent the users have given. As such the newsletters, collection, analysis, and publication of user feedback and reviews, marketing;
• processing is necessary to provide the Controller services according to Website Terms and Conditions;
• In exceptional cases, the processing is necessary for the purposes of the Controller's legitimate interests.
• where necessary, compliance with applicable legislation (e.g., data subject request processing);
• in exceptional cases, to protect users' vital interests or vital interests of another natural person, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
4. PURPOSE OF DATA PROCESSING
SkillThru may process users' personal data provided voluntarily for the purposes defined below.
Provision of Services
Primarily, the Controller processes personal data to fulfill the obligations under the Terms and Conditions for services provision. Specifically, personal data upon registration are processed to help students and mentors to find the account or profile, schedule, give and/or take lessons. In order to use the Services users will need to provide payment (e.g. credit card details) and billing information through SkillThru partners –third-party payment providers, which process personal data encrypted and securely. The processing of this personal data is necessary in order to provide the service.
The Controller could contact students and mentors via email and other ways, including through publicly available notices, for Services-related purposes (welcoming letter, security and legal notices, announcements, SkillThru updates, reminders, suggestions, etc.).
• to communicate with other users through the Website, including exchanging messages, conducting video calls, and/or leaving feedback about other users.
• to participate in research to improve the user experience of SkillThrus products. The research will be used for internal purposes only.
Furthermore, on the basis of the user's consent, on the pages dedicated to the collection of personal data, personal data will be processed for the following purposes:
• receive commercial or promotional information about SkillThru Services This data processing includes traditional and unconventional marketing activities, telemarketing, commercial information, sending advertising material or carrying out market research, interactive commercial communications on services, and other activities of the Data Controller. The provision of data is optional and the lack of consent for such processing affects the performance of the activities described above. The user has the right to revoke the consent previously given at any time with reference to the purposes referred to in this paragraph using the methods indicated in point 7).
• Receive only the promotions most similar to the user's preferences and habits. This processing includes the analysis of personal data collected in order to evaluate and predict certain personal aspects including the preferences and choices made on the site and the interests shown to limit promotional activities only to similar products or promotions based on the analyzes previously carried out. The provision of data is optional and the lack of consent for such processing affects the performance of the activities described above. The user has the right to revoke the consent previously given at any time with reference to the purposes referred to in this paragraph using the methods indicated in point 7).
Analytics and Development
The Controller monitors and analyzes web traffic and user behaviour within its Services to verify their functionality, quality, and interest. The data involved in this activity are cookies and usage data, such as the parts of our services that users visit, the date and duration of the visit, and the type of device that is used during the visit. All the data indicated in this paragraph are collected and further processed in a way that does not allow the identification of the user.
Support and Platform Supervision
In case of any disputes on the Website and other Services-connected issues, the Controler may use data (including communications) to resolve such matters, supervise user behaviour on the platform, and respond to any complaints or requests.
Compliance with legal requirements
SkillThru processes certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. SkillThru also may process the data collected on the platform in connection with legal requests it receives from users or any other competent person and/or body and may use this information to exercise, defend and/or establish its legal rights.
Certain information, such as log information, payment information, and the behavior on the platform is subject to the Controller's supervision to prevent fraudulent activities on the platform and assist users.
5. DATA DISCLOSURE TOWARDS THIRD PARTIES
All those who will process the data will be appointed and instructed. In order to provide high-quality services, SkillThru hires people, enters into an agreement with independent contractors as well as cooperates with other services providers, companies, and organizations strictly under data processing agreement (DPA).
For those reasons, some users' personal data can be passed to the persons mentioned. SkillThru uses only secure places of storage, such as those provided by AWS (Amazon, the USA) with servers located in Ireland and the United States, and other services and applications listed. Amazon uses a Data Processing Agreement and the official Standard Contractual Clauses provided by the European Union.
More information can be found here https://aws.amazon.com/fr/blogs/security/new-standard-contractual-clauses-now-part-of-the-awsgdpr-data-processing-addendum-for-customers/
According to Facebook policy, we have to provide a User Data Deletion Callback URL or Data Deletion Instructions URL.
If you want to delete your activities for the Skillthru Login App, you can remove your information by following these steps:
1. Go to your Facebook Account’s Setting & Privacy. Click "Settings”.
2. Look for "Apps and Websites” and you will see all of the apps and websites you linked with your Facebook. Click "Settings”.
3. Search and Click "Skillthru Login” in the search bar.
For any direct contact - formal and urgent, other than the exercise of the rights provided for in paragraph 7) - you can contact the Data Protection Officer using the following contact details:
7. DATA SUBJECT’S RIGHTS
The GDPR has defined some rights for individuals to ensure privacy and better control over personal data.
• Right to Access Personal Data: Under GDPR, data subjects have the right to access the data collected on them by a data controller. The data controller must respond to that request within 30 days (Article 15).
• Right to Rectification: Data subjects have the right to request modification of their data, including the correction or errors and the updating of incomplete information (Article 16).
• Right to Erasure: The right to erasure – also referred to as the right to deletion or the right to be forgotten – allows a data subject to stop all processing of their data and request their personal data be erased (Article 17).
• Right to Restrict Data Processing: Data subjects, under certain circumstances, can request that all processing of their personal data be stopped (Article 18).
•Right to be Notified: Data subjects must be informed about the uses of their personal data in a clear manner and be told the actions that can be taken if they feel their rights are being impeded. Data subjects must also be informed of any rectification or erasure of their personal data under articles 16, 17, and 18 (Article 19).
• Right to Data Portability:A data subject can request that their personal data file be sent electronically to a third party. Data must be provided in a commonly used, machine readable format, if doing so is technically feasible (Article 20).
• Right to Object: If a request to stop data processing is rejected by a data controller, the data subject has the right to object to their Article 18 right being denied (Article 21).
• Right to Reject Automated Individual Decision-Making: Data subjects have the right to refuse the automated processing of their personal data to make decisions about them if that significantly affects the data subject or produces legal effects – profiling for example (Article 22).
• Right to lodge a complaint with your national (DPA): Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation. (Article 77).
The Data Controller provides feedback to requests within 30 (thirty) days of their receipt unless extended by 60 (sixty) days, taking into account their complexity and number; after the expiration of the terms indicated above. The data subject has the right to lodge a complaint with the Data Protection Authority (for England the ICO) in the forms and methods provided for by currentlegislation.
Here you can find the list of every Data Protection Authority in the world https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
For any request regarding personal data, including the exercise of their rights, any data subject can contact the Controller at the following address:
Address: 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX
Data Protection Officer
What are cookies?
A cookie is a small computer file, a tracer, deposited and read, for example when consulting a website, reading an e-mail, installing or using software or a mobile application, regardless of the type of terminal used, (computer, smartphone, e-reader, video game console connected to the internet, etc …)
In accordance with GDPR article 6.1a as well as the E-privacy directive, skillthru collects your consent before depositing any tracers or cookies not necessarily necessary for the proper functioning of the website To collect your consent, skillthru has set up what is called a «cookie consent banner», that allows you at any time to change your choice about a given consent according to GDPR article 7. Changing your choice should be as easy as giving it.
Category: Necessary (3) Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Category: Preferences (1) Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
Category: Marketing (12) Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
Category: Unclassified (2) Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
Thank you for reading this. We welcome feedback at Skillthru. If you have any queries or would like to get in contact, please email email@example.com