At SkillUp Online, we care about the confidentiality and security of your personal information. We will use commercially reasonable efforts to keep your Personal Information secure in compliance with this Privacy Policy. "Personal Information" is defined below. As used in this Privacy Policy, "we," "us," and "our" refer to SkillUp Online.

This Privacy Policy only applies to information that we collect through the SkillUp Online Website (the "Site," which consists of all content and pages located within the skillup.online web domain) and does not apply to information that we may collect from you in other ways (for example, this policy does not apply to information that you may provide to us over the phone, by fax, or through conventional mail). In addition, please note that your education records are protected by the Family Educational Rights and Privacy Act ("FERPA") to the extent FERPA applies.

USERNAMES AND POSTINGS

Comments or other information posted by you to our forums, wikis or other areas of the Site designed for public communications or communications among registered class members may be viewed and downloaded by others who visit the Site. For this reason, we encourage you to use discretion when deciding whether to post any information that can be used to identify you to those forums (or other public or classwide areas).

CONSENT TO PROCESSING OUTSIDE HOME COUNTRY

By using our Site, or providing information to SkillUp Online, you understand and unambiguously consent to the collection, use, disclosure and retention of information in the United States and other countries and territories, for the purposes set forth in this Privacy Policy and the SkillUp Online Terms of Service . You hereby consent to the collection, use, disclosure, and retention by SkillUp Online of your Personal Information as described under this Privacy Policy, including but not limited to the transfer of your personal data between SkillUp Online and the third parties, affiliates, and subsidiaries described in this Privacy Policy. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable Personal Information to a jurisdiction which may provide a different level of privacy protection than that available in your own country.

If you do not agree with these terms, then please do not access, browse, or register for the Site. If you choose not to provide us with certain information required to provide you with various services offered on our Site, you may not be able to establish a user account and we may not be able to provide you with those services

PERSONAL INFORMATION

As used in this Privacy Policy, "Personal Information" means any information about yourself that you may provide to us when using the Site, such as when you sign up for a user account or enter into a transaction through the Site, which may include (but is not limited to) your name, contact information, gender, date of birth, occupation.

We endeavor to limit the collection of Personal Information to what we need with respect to specific Site activities in order to satisfy business, legal, or regulatory requirements. For purchasing SkillUp Online courses you will be directed to our third party payment processor; and the submission of your payment information will be subject to the terms found at the payment landing page accessible via SkillUp Online Terms of Service

INFORMATION WE COLLECT AND HOW WE USE IT

We collect information, including Personal Information (described above), when you sign up for a user account, purchase online courses, send us email messages and/or participate in our public forums. We also collect certain usage information about student performance and patterns of learning. In addition, we track information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited and which hyperlinks and other user interface controls were used

We may log the IP address, operating system, and browser software used by each user of the Site, and we may be able to determine from an IP address a user's Internet Service Provider and the geographic location of his or her point of connectivity. Various web analytics tools are used to collect this information. Some of the information is collected through cookies (small text files placed on your computer that store information about you, which can be accessed by the Site). You should be able to control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies in the "Help" section of the toolbar. If you reject our cookies, many functions and conveniences of this Site may not work properly.

USE AND DISCLOSURE TO THIRD PARTIES

Among other things, we and our partners & members that provide courses through SkillUp Online (the "Members") may use the information about you collected through the Site (including your Personal Information) in connection with the following. In cases where we share or disclose your Personal Information: (1) the third party recipients are required to handle the Personal Information in a confidential manner and to maintain adequate security to protect the information from loss, misuse, unauthorized access or disclosure, alteration, and destruction; and (2) we will only disclose and share the Personal Information that is required by the third party to fulfill the purpose stated at the time of collection.

• To enable the Members to provide, administer, and improve the courses
• To help us and the Members improve SkillUp Online offerings, both individually (e.g., by course staff when working with a student) and in aggregate, and to individualize the experience and to evaluate the access and use of the Site and the impact of SkillUp Online on the worldwide educational community.
• For purposes of scientific research, particularly, for example, in the areas of cognitive science and education.
• For the purpose for which you specifically provided the information, for example, to respond to a specific inquiry or provide you with access to the specific course content and/or services you select.
• To track both individual and aggregate attendance, progress and completion of an online course, and to analyze statistics on student performance and how students learn
• To monitor and detect violations of the Honor Code, the Terms of Service, as well as other misuses and potential misuses of the Site.
• To publish information, but not Personal Information, gathered about SkillUp Online access, use, impact, and student performance.
• To send you updates about online courses offered by SkillUp Online or other events, to send you communications about products or services of SkillUp Online, SkillUp Online affiliates, or selected business partners that may be of interest to you, or to send you email messages about Site maintenance or updates.
• To archive this information and/or use it for future communications with you.
• To maintain and improve the functioning and security of the Site and our software, systems, and network.
• For purposes described elsewhere in this Privacy Policy (including, e.g., Sharing with Third Parties).
• As otherwise described to you at the point of collection or pursuant to your consent.
• To authenticate your identity when you register for a paid certificate.
• To process refunds, as applicable
• We will share information we collect with the Members, and we and the Members may share this information (including Personal Information) with third parties as follows:
• With service providers or contractors that perform certain functions on our or the Members' behalf, including processing information that you provide to us on the Site, processing purchases via third party providers, and other transactions through the Site, operating the Site or portions of it, providing or administering courses, or in connection with other aspects of SkillUp Online or Member services.
• With other visitors to the Site, to the extent that you submit comments, course work, or other information or content (collectively, "Postings") to a portion of the Site designed for public communications; and with other members of an SkillUp Online class of which you are a member, to the extent you submit Postings to a portion of the Site designed for viewing by those class members. We may provide your Postings to students who later enroll in the same classes as you, within the context of the forums, the courseware, or otherwise. If we do re-post your Postings originally made to non-public portions of the Site, we will post them without your real name and e-mail (except with your express permission), but we may use your username without your consent.
• For purposes of scientific research, particularly, for example, in the areas of cognitive science and education. However, we will only share Personal Information about you for this purpose to the extent doing so complies with applicable law and is limited to the Personal Information required to fulfill the purposes stated at the time of collection.
• To provide opportunities for you to communicate with other users who may have similar interests or educational goals. For instance, we may recommend specific study partners or connect potential student mentees and mentors. In such cases, we may use all information collected about you to determine who might be interested in communicating with you, but we will only provide other users your username, and not disclose your real name or e-mail address to your contact.
• To respond to subpoenas, court orders, or other legal process; to investigate, or prevent, or take action regarding illegal activities, suspected fraud, or security or technical issues, or to enforce our Terms of Service, our Honor Code, or this Privacy Policy; as otherwise may be required by applicable law; or to protect our rights, property, or safety or those of others.
• With affiliates of SkillUp Online or the Members, or with successors in the event of a merger, acquisition or reorganization, for their use consistent with this Privacy Policy.
• As otherwise described to you at the point of collection or pursuant to your consent.
• For integration with third party services. For example, videos and other content may be hosted on YouTube and other websites not controlled by SkillUp Online.
• In addition, we may share aggregated information that does not personally identify you with the public and with third parties, including but not limited to researchers and business partners.

USE FOR PERSONALIZATION AND PEDAGOGICAL IMPROVEMENTS

Our goal is to provide current and future visitors with the best possible educational experience. To further this goal, we sometimes present different users with different versions of course materials and software. We do this to personalize the experience to the individual learner (assess the learner's level of ability and learning style, and present materials best suited to the learner), to evaluate the effectiveness of our course materials, to improve our understanding of the learning process and to otherwise improve the effectiveness of our offerings. We may publish or otherwise publicize results from this process, but, unless otherwise permitted under this Privacy Policy, those publications or public disclosures will not include Personal Information.

LINKS TO OTHER WEBSITES

The Site contains links to websites published by third parties, including other content providers as well as certain service providers, such as those who process payments on behalf of SkillUp Online. These other websites are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by such websites, unless we have otherwise indicated in this Privacy Policy. We encourage you to be aware when you are being redirected to a third party website and review the privacy policies of each website you visit and use.

HOW TO MANAGE YOUR PERSONAL INFORMATION

You can manage your Personal Information through learner features on the SkillUp Online Site and requests to the SkillUp Online learner support team. SkillUp Online will provide support to the extent required by applicable law (for example, learners in the European Union) and more broadly, when possible, as a courtesy in our sole discretion. SkillUp Online will notify you in the event that SkillUp Online is unable to meet a request that is not legally required.

Access and correct your Personal Information

Much of your Personal Information is available in your SkillUp Online account. Your name, email address, and other identifiable profile information is editable through the profile settings in your SkillUp Online account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any Certificates you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact SkillUp Online learner support to access and update this or other information.

Exceptions:

Usernames cannot ever be changed. This is a SkillUp Online system restriction. Because usernames identify you in courses and elsewhere on the SkillUp Online Site, SkillUp Online encourages you to use discretion in choosing your username. If you want to protect your identity, do not use your real name or a name identifiable to you as your username.

SkillUp Online does not track or index every time or every place on the SkillUp Online Site when or where a learner may volunteer Personal Information, so SkillUp Online will be able to help you locate or manage all such instances. SkillUp Online encourages you to use discretion before volunteering Personal Information on the SkillUp Online Site.

Restrict or object to the processing of Personal Information

If you want to manage emails and other communications to you, you may follow the steps described in links at the bottom of email messages or contact SkillUp Online learner support. You may object to, or request that SkillUp Online stop, its use of your Personal Information for other purposes by contacting the SkillUp Online learner support team. Please note that if you choose to restrict SkillUp Online’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the SkillUp Online Site, you may not be able to establish an SkillUp Online user account or enroll for a course, and SkillUp Online may not be able to provide you with those services or products.

Delete account and Personal Information

To request deletion of your SkillUp Online account and Personal Information, you may contact SkillUp Online learner support. Because deletion on the SkillUp Online system is a permanent action and cannot be reversed, SkillUp Online may ask you to complete a process that aims to confirm your authority to manage the SkillUp Online account affected by your request.

With respect to your SkillUp Online account, SkillUp Online will permanently:

• • deactivate your SkillUp Online account,
• • remove the active profile,
• • retire your username, and
• • remove you from SkillUp Online email lists.

With respect to your Personal Information, SkillUp Online will permanently delete your SkillUp Online account profile Personal Information from the SkillUp Online Site.

As noted above, to the extent that SkillUp Online associates the information that SkillUp Online collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your SkillUp Online account profile. By erasing the Personal Information in your SkillUp Online account profile, the remaining information about your activity on the SkillUp Online Site will no longer be associated with you, except as noted below.

Exceptions:

• • Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally "age-off" the SkillUp Online system.
• • SkillUp Online does not track or index every time or every place on the SkillUp Online Site when or where a learner may volunteer Personal Information, so SkillUp Online will be able to help you locate or manage all such instances. SkillUp Online encourages you to use discretion before voluntarily sharing your Personal Information on the SkillUp Online Site.
• • SkillUp Online will archive course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives are used to produce encrypted research data packages, and Personal Information may not be deleted from research data packages.
• • SkillUp Online cannot always delete records of past interactions and transactions. For example, records relating to previous purchases on the SkillUp Online Site must be retained for financial reporting, audit, and compliance reasons.
• • SkillUp Online will retain and use Personal Information as necessary to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law.

Data retention

SkillUp Online will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with SkillUp Online’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that SkillUp Online deactivate your account and delete your information, SkillUp Online will follow the process described above, including without limitation archiving your course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives will be used to produce encrypted research data packages.

STORAGE & SECURITY

SkillUp Online stores information, including Personal Information, on its own servers and also on servers of companies that SkillUp Online hires to provide services. In each case, information may be stored in the United States and in other countries where SkillUp Online operates, and in countries where SkillUp Online’s respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that SkillUp Online may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region.

SkillUp Online controls its own copy of information collected through the SkillUp Online Site and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. SkillUp Online uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, SkillUp Online cannot guarantee its absolute security. While SkillUp Online works hard to ensure the integrity and security of its network and systems, SkillUp Online cannot guarantee that its security measures will prevent "hackers" or other unauthorized persons from illegally accessing or obtaining information.

If SkillUp Online learns of a security breach involving its copy of your Personal Information, SkillUp Online may attempt to notify you electronically so that you may take appropriate protective steps. By using the SkillUp Online Site or providing Personal Information to SkillUp Online, you agree that SkillUp Online can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the SkillUp Online Site. If a security systems breach occurs, SkillUp Online may post a notice on the SkillUp Online homepage (https://skillup.online/) or elsewhere on the SkillUp Online Site and may send an email to you at the email address associated with your SkillUp Online account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

CHANGING OUR PRIVACY POLICY

Please note that we review and may make changes to this Privacy Policy from time to time. When changes are made, the Privacy Policy link will include a notation "Revised (date)." indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in the Privacy Policy link for at least seven (7) days after the update has been made. By accessing the Site after any changes have been made, you signify your agreement on a prospective basis to the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

PRIVACY CONCERNS

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the information we maintain about you, please contact us at [email protected].

Effective Date:

May 14, 2018