PRIVACY POLICY

Last Modified: May 05, 2021

INTRODUCTION

Grazitti Interactive LLP and its Affiliates (Grazitti Interactive Inc.; Grazitti Interactive; Grazitti Interactive PTE Ltd.) (collectively, "Grazitti," "we," "us," or "our") is a global innovation leader leveraging cloud, mobile and social media technologies to reinvent the way you do business. Since 2008, Grazitti has been helping companies power their businesses with its marketing automation and cloud innovation services. As a global consultancy with strategic partnerships, the data privacy of our users is our highest priority. We consider it our duty to be transparent, in relation to the data collected and its utilization and to consider the interest of our employees as of paramount importance. Your privacy is very important to us. Accordingly, we have developed this Privacy Policy to help you understand what information we collect, why we collect it, how we use, and how you can update, manage, export, and delete your Personal Data (as defined below).


POLICY STATEMENT

Welcome to SkillStone, a community to learn and upgrade your skills. The SkillStone website https://SkillStone.in/ (the “Site”) and the operations offered by SkillStone including internal tools, portals, applications (web and/or mobile), products, and other properties through which the content is delivered (collectively, the “Services”) are all covered under the privacy policy. The website and its contents are owned, operated and distributed by Grazitti.

This Privacy Statement outlines how SkillStone collects, utilizes, stores and discloses your information with respect to your rights provided by the applicable privacy law(s). By accessing any part of the Services, you are agreeing to the terms and conditions described below (this “Privacy Policy”) and the terms and conditions of our terms of service (the “Terms of Service”). If you do not agree to any of these terms, you should not use the Services.

By using our services, where applicable, you as a “Data Principle” or “Data Subject” as per GDPR, consent to the use of your information as described in this Privacy Statement and agree to the terms of this policy. All categories of personal information shall be processed consistent with Applicable laws at the time of processing of such data and in accordance with appropriate IT industry standards. We make sure that all data is acquired with consent when necessary and required by law, and is processed fairly in a lawful manner with transparency safeguarding the rights of those accessing our services.

We encourage you to read this notice, together with any additional and more specific information we may provide to you on various occasions when we are collecting or processing personal data on Grazitti websites, products or applications, events and initiatives so that you are aware of how and the purpose for which we are processing your personal data.

Please note: We issue a different privacy notice which applies where there is an employment relationship between Grazitti and its employees.

Please note: All information in this privacy notice is applicable to you unless otherwise indicated based on your residency status. For the additional terms which may be applicable to you based on your residency status, please refer to your country-specific terms at the end of this notice.


SCOPE OF THIS POLICY

This privacy policy describes the processing of information provided or collected on the Sites where this privacy policy is published, except those products or websites or applications that have a separate Privacy Statement. This Privacy Policy applies to users of our Services anywhere in the world, or other services including both users who are simply viewing content available via the Services and users who have registered as users of SkillStone.

This notice specifically applies to:

  • Users of the Site
  • Users using Services
  • Offline users using SkillStone services


DATA COLLECTION AND USES

What, How, And Why Do We Collect Information?

When you register with us and become a SkillStone user, when you choose to teach or attend a training, we will ask you for Personal Data. “Personal Data'' is used to represent any information relating to an identified or identifiable person; country-specific notices might adopt a different terminology. This includes, but is not limited to, your name, email address, but does not include your billing information. We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

In order to send you an email from SkillStone, we need your email address. To provide you with additional services, we may also request your name, general location, and telephone number. We will not give your name, email, or other Personal Data to unaffiliated third parties except with your consent or as otherwise set forth in this privacy policy. Though we employ industry standard measures to preserve user privacy, we may need to disclose Personal Data when required by law or when we have a good faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process that we receive or to protect our interests or the safety of others. In addition, we may provide Personal Data to employees, consultants or other businesses or persons for the purpose of processing such information on our behalf. In such circumstances, we require that these parties agree to protect the confidentiality of such information and to comply with the terms of this Privacy Policy. We may use your Personal Data to operate, improve, understand and personalize our Services.

Further, a minimum amount of personal data would be required to be obtained in order to provide our services. If you do not intend to share such personal data, it is advised to not proceed with the use of our services.

Information We Collect Directly From You

We collect the personal information you provide - such as your name, username, or business/personal email address, contact and other related information - when you contact us, participate in an online survey, use our products, solutions and services, create an account, request for demos/trials/sign-ups/attend webinars, participate in community discussions or chat rooms on other platforms, apply for employment, interact with us at in-person events, or otherwise interact with us. Furthermore, we also get information when you register on our website/product and willfully provide us your information like business/personal email, contact and other information related to your account. We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

  • First and last name
  • Email address
  • Date of birth
  • Gender
  • Biographical information
  • Location information (limited to city, state, zip code, country, and time zone)
  • Employment history
  • Links to your social media accounts
  • Any other information you choose to share publicly on the Services, for example, anything you post to a public part of your Profile or an online classroom on the Services
  • Payment details

Information About Payments

We collect personal information in connection with the purchase of services or products from us. This information includes payment information such as first name, last name, business/personal email address, and billing and contact details.

Note: We do not store credit card details related to any transaction with Grazitti.

Information We Receive From Third Party Sources

Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following:

  • Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
  • Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
  • Information from third party service providers: Some of our third party service providers collect Personal Data about our employees and job candidates and share that information with us.

Information We Collect When You Use Our Services

Some Personal Data is automatically collected when you use our Services, such as the following:

  • Registration information you provide when you create an account, such as your first name and surname, country of residence, gender, date of birth, email address, username, and password.
  • IP address
  • Your activity on the Services. This includes class usage information such as class enrollment and which classes you’ve watched. It also includes community interaction data, such as which members you’re following, your comments, your projects, or project likes.
  • Device identifiers
  • Web browser information
  • Page view statistics
  • Browsing history
  • Transaction information (e.g. transaction amount, date and time such transaction occurred)
  • Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.). For more information, please review the “Cookies, Third-Party Technologies, and Newsletters” section below.
  • Location information (e.g. IP address)
  • Log data (e.g. access times, hardware and software information)


Cookies, Third-Party Technologies, and Newsletters

Cookies

A cookie is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing. We collect this information to provide a better user-journey of our website and to enhance the overall experience of our website/products. For more information on our cookie policy, refer to the link here.

Subscription To Newsletters

Upon visiting the SkillStone website, users are given the opportunity to subscribe to our enterprise newsletters and regular emails after providing consent. The newsletter may only be received if you have opted in for it. Each newsletter comes with a link providing the user with the option to opt-out of the service. The newsletter contains tracking pixels that provide us the information if and when an e-mail was opened. Such data collected in the tracking pixels are used to analyze and optimize the shipping time of the newsletter and to improve the content of future newsletters as per the interests of the receivers.


How Do We Use Personal Data?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

  • Create and manage user accounts and profiles
  • Personalize content on the Services. This includes showing users their saved classes and class watch history, and providing class recommendations.
  • Provide users and trainer with community features
  • Provide trainers with student lists and pay trainers appropriately
  • Communicate with you about the Services
  • Contact you with announcements, updates or offers regarding the Services
  • Process orders
  • Provide support and assistance for the Services
  • Analyze and improve the Services
  • Meet contract or legal obligations
  • Respond and fulfill user inquiries and requests
  • Resolve disputes
  • Protect against or deter fraudulent, illegal or harmful actions
  • Complete corporate transactions (for more information, see our “Business Transfers” section below)

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.


GROUNDS FOR PROCESSING

Legal Obligations

It may be necessary - by law or as a result of a legal process, or requests from governmental or other legal authorities within or outside your country of work - for us to disclose your personal information. Grazitti is obliged to share your personal information under any or all or /all applicable and judicial laws with or /without your consent if we determine that for purposes of disclosure is necessary or appropriate.

Contractual Necessity

We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Legitimate Interest

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

  • First and last name
  • Email address
  • Location information
  • IP address
  • Your activity on the Services, including class usage information and community interaction data

Examples of these legitimate interests include:

  • Operation and improvement of our business, products and services
  • Personalization of web content on the Service
  • Analyzing the use of the Services
  • Marketing of our products and services
  • Provision of customer support
  • Protection from fraud or security threats
  • Compliance with legal obligations
  • Completion of corporate transactions

Voluntary Disclosure

Any Personal Data or content that you voluntarily disclose in public areas becomes publicly available and can be collected and used by other users for any reason. Your profile pages (“Profile”) and any online classrooms you participate in are typically publicly available. You have the ability to change your account settings to limit access to your profile, and may delete content you post to public classrooms. If you need assistance with controlling your account privacy settings or with deleting content, please contact us at [email protected]. Removal of posted content does not ensure complete or comprehensive removal of the content or information (e.g., some content may be “invisible” to other users but remain on our servers in some form). You should exercise caution before disclosing your Personal Data via these or any other public venues.

For example, if you choose to sign up for a SkillStone account, you may have a Profile on the site or on our internal application(s), containing your full name and some basic information including your location and bio. You may also add additional optional information to your Profile. You may control what type of Profile information is shown to others through your Account Settings. Any information you choose to provide as part of your Profile should reflect how much you want other SkillStone users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage members to think carefully about what information about themselves they disclose in their profile pages. You can review and revise your profile information at any time.


INFORMATION SHARING AND DISCLOSURE

We only share your personal information with third-party companies as stated in this policy below and strictly for the purpose of employment. However, we may share the information internally within the Grazitti departments. We may use your data for marketing purposes and the same shall be informed and express consent would be obtained. We make certain personal information available to strategic partners that work with us. Personal information will only be shared by us with these companies in order to provide or improve the offering of our products and services; it will not be shared with third parties for their own marketing purposes without your prior express consent.


Sharing Your Information With Other Entities

1. Affiliates

We may share personal information with all Grazitti affiliates. For the purposes of this Privacy Statement, two entities are "Affiliates" if both of the entities are controlled/owned 50% or more by the same owner(s).

2. Service Providers

Grazitti is in contract with third-party auditing companies and may make available some information during external audits, to show its compliance with the applicable law(s). These companies are obligated to protect your information. All the information shall be provided on a need to know basis and for only the specific purpose.

3. Legal Compliance And Security

It may be necessary - by law or as a result of a legal process, or requests from public or governmental authorities within or outside your country of residence - for us to disclose your personal information.

Grazitti is obliged to share your personal information under any/all applicable and judicial laws with/without your consent if we determine that for purposes of disclosure is necessary or appropriate.

Note: Grazitti does not sell your personal information.


DATA SECURITY, INTEGRITY, AND RETENTION

Grazitti is compliant to ISO27001:2013, PIMS, and HIPAA. The security, integrity, and confidentiality of your information are extremely important to us. To ensure the safety of your information we have implemented reasonable, technical, administrative, and physical security measures. Considering the potential risks to data, we conduct VAPT from third-party and perform regular internal/external audits. Please check the Grazitti security & compliance page for more details.

If you feel that the security of your personal information has been compromised, please contact us immediately at [email protected]. Please be aware that, despite our best efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.

Other Sites

The Services may contain links to other websites or services. We are not responsible for the privacy practices or the content of such websites or services, and you should review the privacy policy of each such website or service to make sure that you are comfortable with it before providing any Personal Data. As discussed above, we do not receive any banking information you provide to our third party payment processors, and all such information is subject to their privacy policies.

Data Retention And Deletion

We retain Personal Data about you for as long as you have an open user account with us or as otherwise necessary to provide you Services or for a period of 10 years. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.


YOUR RIGHTS ON YOUR INFORMATION

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected] with the subject of the email clearly identifying the purpose of the email. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Right of Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. Furthermore, you have a right to obtain information as to whether personal data is transferred to a third country or to an international organization. Where this is the case, you have the right to be informed of the appropriate safeguards relating to the transfer.
  • Right to Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by making changes to your Profile. Additionally, we shall be sending emails annually asking for any rectifications or updates of your personal data. Information shall be stored and processed on the basis of the latest email received from your registered email address. (Please note that this shall also imply a renewal of consent for storing and processing of personal information.)
  • Right to Erasure: You can request that we erase some or all of your Personal Data from our systems. You have the right to request the erasure of your personal data where one of the following grounds applies:
  • The Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject objects to the processing and there are no overriding legitimate grounds for the processing.
  • The personal data has been unlawfully processed.

If one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by Grazitti, you may request the same.

  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time and in accordance with this privacy policy. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Right of Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Right to Object: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes. You have the right to object to the processing of your personal data. We will no longer process your personal data in the event of the objection being raised unless we can demonstrate compelling legitimate grounds for the processing.
  • Right to Restrict Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about SkillStone’s practices with respect to your Personal Data with the supervisory authority.

EU Resident's Rights

If you are a European resident, GDPR provides consumers (Europe residents) with specific rights regarding their personal information. To make such a request, you may contact SkilStone at [email protected] and include "GDPR Rights Request" in the subject line of the request to exercise your rights under the applicable data privacy law(s). We will do our best to respond to your inquiries within 30 days.

California Resident's Rights

If you are a California resident, CCPA provides consumers (California residents) with specific rights regarding their personal information. To make such a request, you may contact SkillStone at [email protected] and include "California Privacy Rights Request" in the subject line of the request to exercise your rights under the applicable data privacy law(s). We will do our best to respond to your inquiries within 30 days.

Other Rights

You may reside in a country not covered by the above privacy laws. In such cases, we have put in place the appropriate measures to ensure that your personal data will be secure according to the laws of the country in which you reside. To make such a request, you may contact SkillStone at [email protected] and include the privacy law of the country of your residence in the subject line of the request to exercise your rights under the applicable data privacy law(s). We will do our best to respond to your inquiries within 30 days. If you require further information about these protective measures, you can request it from our Data Protection Officers (see contacts below) or send an email to [email protected].


CHILDREN’S PRIVACY

As noted in our Terms of Service, we do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Data about yourself. If we learn that we have collected Personal Data from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Data, please contact us at [email protected].


COPYRIGHT NOTICE

All aspects of our website(s) – design, text, graphics, forms, underlying source code, and all other literary and artistic aspects – are copyright of Grazitti and its affiliates.

In accessing these web pages, you agree that any downloading of content is for non-commercial and non-transferrable reference only. No part of this website or Services may be copied in any form or by any means without prior Grazitti permission.


CHANGES TO THIS PRIVACY STATEMENT

Grazitti reserves the right to modify or update this Privacy Statement periodically to keep pace with new technologies, industry practices, and regulatory requirements. All the changes are expected to be minor and will be updated on our website with immediate effect. Therefore, we encourage you to read our policy regularly for any recent updates. If any fundamental changes are introduced which are bound to significantly affect your rights, the same shall be communicated to you via an appropriate platform or forum.

If you have any questions or queries related to our Privacy Statement, please feel free to contact us at [email protected].

HOW TO CONTACT US

Grazitti has a designated Data Protection Officer, who shall act as the point of contact for clients, customers, and individuals to ensure their data safety and security. If you have any questions regarding this Privacy Statement or its implementation, you may email the Data Protection Officer at [email protected]. You may also write to us at:

Grazitti Interactive
Attn: Data Protection Officer
Phone: +91 172 504 8500

Plot 198, Phase 2 Industrial Area,
Panchkula, Haryana 134113, INDIA

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