PRIVACY POLICY

Version 1: Last updated October 28th, 2021

Thank you for choosing to be part of our community at SkillsBase App Ltd (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy, including any applicable rights under EU GDPR. If you have any questions or concerns about our policy or our practices regarding your personal information, please get in touch with us at info@skillsbase.io.

When you visit our mobile application and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the most straightforward way possible what information we collect, how we use it and what rights you have about it. We hope you take some time to read through it carefully, as it is essential. If there are any terms in this privacy policy that you disagree with, please discontinue the use of our App and our services.

This privacy policy applies to all information collected through our mobile application (“App“) or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites“).

Please read this privacy policy carefully, as it will help you make informed decisions about sharing your personal information with us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. ON WHAT BASIS DO WE COLLECT YOUR INFORMATION, AND HOW DO WE USE IT?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6. DO WE COLLECT INFORMATION FROM MINORS?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. DO WE MAKE UPDATES TO THIS POLICY?

9. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

The personal information you disclose to us

In Short: We collect personal information that you provide to us, such as name, email address, phone number, password and also a photo should you choose to include one.

We collect personal information that you voluntarily provide to us when signing up, when using the App, or otherwise contacting us.

Information automatically collected

In Short: Some information – such as IP address or browser and device characteristics – is collected automatically when you visit our App.

We automatically collect certain information when you visit, use or navigate the App. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our App and other technical details. This information is primarily needed for our analytics and reporting purposes.

Information collected through our App

In Short: We may collect information regarding your regional geo-location and mobile device when you use our App.

If you use our App, we may also collect the following information:

· Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, microphone, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

· iOS: Camera (for taking photos, scanning QR codes, uploading content for review, AI and AR Features), Photo Library (for uploading pictures) and Microphone (for uploading videos).

· Android: Camera (for taking photos and scanning QR codes), Write to device storage (for saving and storing information) and Internet (for viewing the latest content).

Push Notifications. We may request to send you “Push Notifications” regarding your account or the mobile application. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings. It is recommended that you enable Push Notifications to make the most out of the App’s updates.

2. ON WHAT BASIS DO WE COLLECT YOUR INFORMATION, AND HOW DO WE USE IT?

In Short: We process your information for purposes based on legitimate interests, compliance with our legal obligations, and/or your consent.

We use personal information collected via our App for a variety of purposes described below. We process your personal data for these purposes in reliance on our legitimate interests (“Business Purposes”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Abiding by Contractual Obligations to Clients”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

· To facilitate account creation and logon process.

· Request Feedback. We may use your information to request feedback and to contact you about your use of our App.

· To connect you with your chosen content providers and to give you access to their content.

· For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and evaluating and improving our App, products, services, marketing and your experience.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent to comply with laws, protect your rights, or fulfil business obligations.

We may process or share data based on the following legal basis:

Where applicable, we may share reporting generated from usage data with Clients. The data that we share may be usage reporting by employees of client companies, which we will only share with the relevant client company.

Examples of the usage data gathered and reported

· App Content being viewed and when and for how long.

· General App Usage

· Training Course data (if access to a course has been granted)

Examples of where data is shared:

· Data generated from your App usage is stored in the cloud by our 3rd party cloud hosting providers, which necessitates sharing data with them. However, you can be assured that data is encrypted in transit and storage, and we only use trusted hosting service providers. The App’s security is critical, with all customer’s data kept on different databases to ensure no cross-contamination.

Legal Obligations: We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a more extended retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than the period in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We capture minimal information from you and your use of the App. A password of your choosing is required for the sign up of the App.

Data generated from your usage of the App is stored in the cloud by our 3rd party cloud hosting providers, which necessitates sharing data with them. However, you can be assured that data is encrypted in transit and storage, and we only use trusted hosting service providers. The App’s security is critical, with all customer’s data kept on different databases to ensure no cross-contamination.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 13 years of age.

This App is designed for telecoms engineers and is unlikely to attract the attention of other potential users, including children. We do not knowingly solicit data from or market to children under 13 years of age. By using the App, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the App. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to delete such data from our records promptly. If you become aware of any data we have collected from children under age 13, don’t hesitate to contact us at info@skillsbase.io.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some jurisdictions, such as the EU or the European Economic Area, you have rights to allow you greater access to and control your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EU and the European Economic Area), you have certain rights under applicable data protection laws. These may include the right:

1. To request access and obtain a copy of your personal information.

2. To request rectification or erasure.

3. To restrict the processing of your personal information.

4. If applicable, to data portability.

In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request following applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Account Information

You have direct control over the following from the ‘My Account’ page in the App:

· Change your account details, such as password and profile picture.

· Change your operator type

· Change your notification settings.

8. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of protecting your information.

9. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO) at info@skillsbase.io or by post to:

Skillsbase App Ltd

Unit 2 Pinnacle Business Park, Ballytrasna,

Little Island, Cork T45 FV18 Ireland