Global Privacy Policy

Why does Upskill need my information?

How Upskill uses your information depends in part on the context in which you are interacting with us. You may be a user of Upskill’s products, a visitor to our website, a customer, a potential customer, and/or a prospective employee. These uses are explained below under the heading “How does Upskill Use my Information.”

More generally, we may also use the personal information collected about you for the following purposes:

• Verify your identity to ensure security for the other purposes listed here;
• Operate, evaluate and improve our business (including developing new products and services; managing our communications; performing market research; determining and managing the effectiveness of our advertising and marketing; analyzing our products, services and websites; administering our websites; and performing accounting, auditing, billing, reconciliation and collection activities);
• Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
• Conduct investigations and comply and enforce applicable legal requirements or, industry standards and our policies and terms, such as this and other Upskill sites’ terms of use; and
• Ensure the safety of Upskill network services, information resources and employees.

Upskill as a Data Controller

Upskill may process your personal data pursuant to contract (such as, when you provide us with information when requesting a Service), or to pursue legitimate business interests (such as to support direct marketing efforts, or to prevent fraud). We will only use your information when we have a lawful basis for its use. We note, for individuals from the European Economic Area (EEA), that when we obtain your personal data we serve as a data controller. If you believe that your personal information has been used in a manner that is not consistent with the relevant privacy policy, please contact us at privacy@upskill.io. You have a right to make a complaint regarding our data practices with the applicable supervisory authority in the members state or country of your residence.

Upskill as a Data Processor

In certain cases, Upskill may process your information as it relates to your use of our Product on behalf of an Upskill customer or other third party who is acting as the data controller with respect to your information (the “Controller”). For example, we may process information that is collected from you by the Controller in your capacity as an employee of the Controller. In a situation where we are processing data on behalf of another data controller, your rights are primarily determined by your relationship with that Controller, and not with us. In that case, certain provisions of this policy may not apply to you.

On Premises Installations of the Product

Some Upskill customers choose to deploy our Product’s services within their own data center or cloud infrastructure rather than use our Software as a Service (SaaS) offering. In these situations, the customer has full control over the Product environment and Upskill may not process any of your data. In this scenario, Upskill is not acting as either a Data Controller or a Data Processor and certain provisions of this policy may not apply to you.

What information does Upskill collect?

Depending on how you interact with Upskill, we may collect some or all of the following types of information from you:

Name:  Your first and last name
Email:  Your email address
Company:  The name of your employer
Phone Number:  Your phone number
Job Title:  Your position and seniority at your employer
Country:  The country in which you reside
IP Address:  The IP address of the device from which you access the Product, website, or Services
Location:  Location information obtained from your web browser or mobile device you’re using to access the Product, website, or Services
Device Information:  Information regarding device from which you are accessing the Product, website, or Services. This may include data elements such as the type of device, operating system being used, application identifiers, or unique device identifiers
Log Data:  This may include the IP address of the device being used, the address of a page visited before using the website or Services, language preferences, cookie data, and similar information
Application Events:  Information regarding events that the user has triggered in the system such as navigating a workflow, completing tasks, or triggering other functionality

How does Upskill use my information?

How Upskill uses your information depends on the context in which you are interacting with us. You may be a user of Upskill’s products, a visitor to our website, a customer, a potential customer, and/or a prospective employee.

Product Users

Users typically gain access to our Product and Services through their employer that is a customer (the “Customer”) who acts as the controller of their data and is responsible for the provisioning of user accounts and the management of user data. In this case we act as processor as described above, and follow the instructions provided by the Customer regarding the processing of your data.

A user of our Product may interact with us in the following ways:

General Product Use

While each Customer uses the platform differently (and thus different information may be collected about its use), there is some basic information collected on all users that is used to operate the Product. This information may include:

• Name
• Email
• Company
• IP Address
• Location
• Device Information
• Log Data

The Product makes use of products and services from the following sub-contractor(s) that may process your data:

• Amazon Web Services
• Datadog
• Microsoft AppCenter
• Twilio Programmable Video

Application Monitoring

In order to appropriately monitor the infrastructure that supports our Product, we collect information about errors, usage, and the performance of the system. Collecting this information allows Upskill to improve the product and ensure we maintain contracted service level agreements.

Data collected during application monitoring includes:

• User ID
• Domain
• Device Information
• Log Data

Product Analytics

The Product can be configured to collect various metrics about usage of the system to provide to the Customer for analysis. This feature can be configured on a per-Customer basis to allow for full collection, anonymous collection, or no collection of data regarding system activities.

When full collection is enabled by the Customer, the data collected during use includes:

• Email (note that this information is omitted if the Customer configures anonymous collection)
• Company
• Application Events

When used as Software as a Service (SaaS), the Product makes use of products and services from the following sub-contractor(s) that may process your data:

• Amazon Web Services

Website Visitors

In order to provide the best possible browsing experience, debug errors, and measure traffic to the website, Upskill collects certain information from visitors to help us make decisions. This data includes:

• IP Address
• Location
• Log Data

We may use the following sub-contractors to process this data:

• Google Analytics
• Pardot

Prospective Customers

If you’ve submitted your information to Upskill via our website, in-person, or via a partner we may have the following interactions with you.

Personalized Advertising

Upskill may use the data you’ve provided us to target particular visitors or demographics with advertising. In this process we use the following information:

• Name
• Email
• Company
• Location

We may use the following sub-contractor(s) to process this data:

• Pardot
• Google Adwords
• Social sites (i.e. LinkedIn, Facebook, Twitter)
• 3rd party ad platforms (i.e. RollWorks)

Prospective Customer Database

Upskill maintains a prospective customer database that we use as part of our sales and marketing operations. In this database we collect the following information:

• Name
• Email
• Job Title
• Company
• Location

We may use the following sub-contractor(s) to process this data:

• Salesforce
• Pardot
• Data appending services (i.e. Synthio)

Customers

If you’re an active Upskill customer, we may have the following interactions with you:

Billing and Account Management

We collect information necessary to facilitate billing for our products/services and to enable account management. We collect the following information in this context:

• Name
• Email
• Company

We may use the following sub-contractor(s) to process this data:

• Salesforce

Prospective Employees

If you’re a job seeker wishing to be considered for a position at Upskill, we collect the following information from you in order to better manage our pool of applicants:

• Name
• Email
• Company
• Phone Number
• Location

We may use the following sub-contractor(s) to process this data:

• Indeed
• Jobvite

Who has access to my information?

Upskill Employees & Affiliates

At Upskill, we ensure that those accessing data we’ve collected from you can only do so with a legitimate need-to-know the information in connection with their responsibilities. Every member of our team is bound by non-disclosure and appropriate use documentation. All Upskill employees also receive regular training on the appropriate way to handle customer data of all kinds. Any affiliate which receives access to data collected by Upskill undergoes these same or equivalent processes.

Legal Requirements

We may disclose your information if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Product or Services, (d) act in urgent circumstances to protect the personal safety of Customers or the public, or (e) protect against legal liability.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Customer information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Upskill (or its assets) will continue to have the right to use your information and other information in accordance with the terms of this policy.

Sub-Contractors

Upskill may share your data with sub-contractors in the course of operating our business. In any situation in which your data is shared with a sub-contractor, we obtain contractual or other assurances that the contractor will process your data in a manner consistent with what we describe in this privacy policy.

How is my information protected?

We utilize industry-standard best practices to safeguard the storage of the data you or your employer provides to us. We have put in place physical, administrative, and technical measures to protect your data from any unauthorized or unlawful processing. In addition, we protect your data from any accidental loss, destruction, or damage.

Where does my information reside?

Upskill is based in the United States but does business all across the globe. Your information is primarily stored within the United States or the European Economic Area. To facilitate Upskill’s global business operations this data may be transferred or access from around the world where Upskill or our customers do business. Data originating from the EEA will be transferred subject to appropriate regional regulations.

What rights do I have when it comes to my information?

If you are a resident of the European Union (EU), you have certain rights with regards to your data under the European General Data Protection Regulation (GDPR). This entitles you to:

• Receive notification about the processing of your information
• Gain access to the information stored about you
• Make corrections to the information stored about you
• Request that the information being held about you be erased when it is no longer needed
• Object to the processing of your information
• Request the restriction of the processing of your information
• Receive your information output as a machine-readable format for transmission to another data controller
• Withdraw your consent to the processing of your information at any time
• Lodge a complaint with the local Data Protection Authority

If you are a resident of the EU and wish to exercise these rights, please submit your request here or reach out to us at privacy@upskill.io.

Note that if you are not an EU resident, you may not have these rights by law. That being said, Upskill believes strongly in transparency and appropriate processing of personal data and will make every effort to provide you with as much control over the data collected about you as possible.

Note also that in situations where our Customer is acting as data controller for your data, their own data privacy policies determine the types of interactions you can have and how your data is handled.

If you are a resident of California, you may request and obtain information annually that Upskill has shared with other businesses for their own direct marketing use within the prior calendar year (as defined by California’s “Shine the Light Law”). To obtain this information please send an email message to privacy@upskill.io with “California Shine the Light Privacy Request” in the subject line as well as in the body of your message. We will then respond to that email with the requested information.

Sharing and Transfer of Your Personal Information

We do not sell or otherwise disclose personal information about our website visitors outside Upskill and its affiliates, except as described here:

We may share information provided by our visitors to this and other Upskill sites with service providers we have retained to perform services on our behalf. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. We may also share information pursuant to the “Legal Requirements” and “Business Transfers” sections, above.

Use of Cookies and Similar Technology

Like most companies, Upskill uses cookies and similar technologies (“cookies”) on our websites to facilitate and improve your online experience.

How we use Cookies

Cookies contain small amounts of information which are downloaded to your device when you visit our website. Cookies are sent back to our website to allow us to recognize your device.

Recognizing your device with essential cookies allows our site to help you navigate efficiently to obtain the information and services you have requested.

Analytical and customization cookies allow our site to remember your preferences such as language selection and help you to view information that is most relevant to your interests; these cookies also help us to maintain and improve our websites by providing information on how visitors find and use the sites, and how well the sites are performing.

In some cases advertising cookies may be used to make advertising messages more relevant to you.

Unless you disable the cookies on our website, by using our website you agree to our use of those cookies.

Sharing Tools

To enhance your experience on our websites, we sometimes embed content and sharing tools from other (third party) sites, such as “like” buttons from social networking sites; these third-party sites may also place and access cookies on your device. Upskill does not control the placement or access of these third-party cookies. You should check the relevant third-party website(s) for more information about these cookies and whether and how you may make choices about them.

Links to Other Sites

We provide links to other websites for your convenience and information. These sites may have their own privacy statements or policies in place, which we recommend you review if you visit any linked websites. We are not responsible for the content of linked sites or any use of the sites.

Children’s Privacy

Our website is intended for individuals 18 and over and is not directed to children under the age of sixteen and we do not knowingly collect personal information from children under the age of sixteen on this site or other Upskill sites. If we become aware that we have inadvertently received personal information from a visitor under the age of sixteen, we will delete the information from our records.

Changes to this Policy

This policy may be updated periodically and without prior notice to you to reflect changes in our online information practices. When changes are made to this policy it will be posted to the website and the “last updated” date at the top of this policy will be revised. We also encourage users to periodically check this policy to understand how Upskill protects and uses your information

How do I get in touch with Upskill?

If you have any questions, concerns, or wish to submit an appropriate data request as outlined in this policy, please contact Upskill’s dedicated privacy team at privacy@upskill.io.

Should you prefer to make such a request by traditional mail or phone, please use the following address/phone number:

Upskill
8614 Westwood Center Drive
Suite 440
Vienna, VA 22182
1-703-436-9283

Last Updated:  August 2018