Privacy Policy

Skill Focus Privacy Policy
Effective as of March 18, 2022

Introduction
When we talk about “Skill Focus,” “we,” “our,” or “us” in this Privacy Policy, we are referring to Skill Focus, Inc., the company with registered address at Abba Heiil Silver road 99 of 6, Ramat Gan, Israel, which provides the Services. When we talk about the “Services” in this policy, we are referring to our online application and platform. Our Services are currently available for use via a web browser. Any person accessing or using the Services is referred to as “you”.

This Privacy Policy describes the types of information we may collect from you in connection with the Services, how this information may be used, disclosed and safeguarded, and how you can control its use.

Please read this privacy policy carefully.

Changes to this Privacy Policy
WE MAY CHANGE THIS POLICY FROM TIME TO TIME, AND IF WE DO WE WILL POST ANY CHANGES ON THIS PAGE. IF YOU CONTINUE TO USE THE SERVICES AFTER THOSE CHANGES ARE IN EFFECT, YOU AGREE TO THE REVISED POLICY.

Accordingly, we encourage you to periodically review this Privacy Policy in order to keep apprised of our current privacy practices. If you do not agree to our privacy practices as detailed here, please do not use the Services. In conjunction with this Privacy Policy, you should also review our User Terms of Service, for a more complete understanding of the rules, and terms and conditions, governing your use of the Services.

Information we collect and receive
1. Customer Data

Content and information submitted or uploaded by users to the Services is referred to in this policy as “Customer Data.” As further explained below, Customer Data is controlled by the organization or other third party that created an account (the “Customer”). Where Skill Focus collects or processes Customer Data, it does so on behalf of the Customer. Here are some examples of Customer Data (but keep in mind they are only examples and there may be others): uploaded datasets, and other types of datasources. A user may also choose to enter information into their profile, such as first and last name, or a photo.

If you use an account, you are a “user,” as further described in the User Terms of Service. If you are using the Services by invitation of a Customer, whether that Customer is your employer, another organization, or an individual, that Customer determines its own policies regarding storage, access, modification, deletion, sharing, and retention of Customer Data which may apply to your use of the Services. Please check with the Customer about the policies and settings it has in place.

2. Other information

Personal information is provided to us directly by you

The information you may provide us is Personally Identifiable Information that identifies an individual or may with reasonable efforts cause the identification of an individual, and may include the following data:

Account creation information. Users provide information such as an email address and password to create an account.
Account setup information. When a Customer creates a team using the Services, we collect an email address, a team name, user name for the individual setting up the team, and password. For more information on team set-up, click here.
Billing and other information. For Customers that purchase a paid version of the Services our third party payment processors may collect and store billing address and credit card information on our behalf.
Services usage information. This is information about how you are accessing and using the Services, which may include administrative and support communications with us and information about the teams, features, and what third party integrations you use (if any).
Contact information. With your permission, any contact information you choose to import is collected when using the Services.
Log data. When you use the Services our servers automatically record information, including information that your browser sends whenever you visit a website or your web app sends when you are using it. This log data may include your Internet Protocol address, the address of the web page you visited before using the Services, your browser type and settings, the date and time of your use of the Services, information about your browser configuration and plug-ins, language preferences, and cookie data.
Device information. We may collect information about the device you are using the Services on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings.
Geo-location information. WiFi and IP addresses received from your browser or device may be used to determine approximate location.
Services integrations. If, when using the Services, you integrate with a third party service, we will connect that service to ours. The third party provider of the integration may share certain information about your account with Skill Focus.
Information you provide about others

In providing personal data about other individuals (such as someone in whose name you are registering an account), you represent that you have notified them of (i) the purposes for which information will be used (ii) the recipients of their personal data and (iii) how they can access and correct the information. You further represent that You have obtained all necessary consents from them.

Information we might obtain from third parties

We do not obtain any data from third parties.

Our Cookie Policy
Skill Focus uses cookies and similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies.

Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit our Services. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.

Some cookies are associated with your account and personal information in order to remember that you are logged in and which teams you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things. If you access the Services through your browser, you can manage your cookie settings there but if you disable some or all cookies you may not be able to use the Services.

Skill Focus sets and accesses our own cookies on the domains operated by Skill Focus. In addition, we use third parties like Google Analytics for website analytics. You may opt-out of third party cookies from Google Analytics on its website.

How we store your information
We take Client confidentiality and security very seriously. We are committed to protecting the Personal Data you share with us. We use a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure.

The data processing consisting in hosting provider services (storage and maintenance of databases containing your personal data, protected by password) is performed on our behalf and under confidentiality agreements by our authorized data processor Amazon Web Services, Inc. ('AWS').

As Amazon Web Services, Inc. is part of a global organisation with local operating companies in a number of countries worldwide. All information is stored on Amazon Web Services datacentres in the US East (N. Virginia) Amazon Region. AWS participates in the EU-US Privacy Shield framework. Please find more information here. GDPR DPA is incorporated into the AWS Service Terms.

The agreements with the data processor guarantees that the requirements of the GDPR will be met and the rights of data subjects are protected. The data processor will only act on behalf of our documented instructions, have direct responsibilities under the GDPR and may be subject to fines or other sanctions if they don’t comply.

Once this contract is concluded, data processor will return data to us or transmit to another processor appointed by us, and erase any copy in its possession. However, the processor may keep the data locked to address possible administrative or jurisdictional responsibilities.

How we use your information
We use your information to provide and improve the Services. We process all personal data lawfully, fairly and in a transparent manner. We use the data we collect for the following basic purposes, described in more detail below:

1. Customer Data

Skill Focus may access and use Customer Data as reasonably necessary and in accordance with Customer’s instructions:

to provide, maintain and improve the Services;
to prevent or address service, security, or technical issues, or at a Customer’s request in connection with customer support matters;
as required by law and;
as set forth in our agreement with the Customer or as expressly permitted in writing by the Customer.
Additional information about SkillFocus’s confidentiality and security practices with respect to Customer Data is available at our Security page.

2. Other information

We process all personal data lawfully, fairly and in a transparent manner. We use the data we collect for the following basic purposes, described in more detail below:

To understand and improve our Services. We carry out research and analyze trends to better understand how users are using the Services and how to improve them.
To communicate with you by:
Responding to your requests. If you contact us with a problem or question, we will use your information to respond.
Sending emails. We may send you Service and administrative emails and messages. We may also contact you to inform you about changes in our Services, our Service offerings, and important Service related notices, such as security and fraud notices. These emails and messages are considered part of the Services and you may not opt-out of them. In addition, we sometimes send emails about new product features or other news about Skill Focus. You can opt out of these at any time.
Billing and account management. We use account data to administer accounts and keep track of billing and payments.
Communicating with you and marketing. We often need to contact you for invoicing, account management and similar reasons. We may also use your contact information for our own marketing or advertising purposes. You can opt out of these at any time.
Investigating and preventing bad stuff from happening. We work hard to keep the Services secure and to prevent abuse and fraud.
We might hold your information for as long as is necessary to comply with our and legal obligations and in accordance with our legitimate interests as a data controller after the contractual relationship between you and us elapses. The lawful basis for such retention is Legitimate interests and Legal obligation. As the data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph “Your rights”.
This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable user or Customer of the Services.
Your choices
1. Customer Data

Customer provides us with instructions on what to do with Customer Data. A Customer has many choices and control over Customer Data. For example, Customer may enable or disable third party integrations, manage permissions and roles, share datasets and dashboards. Since these choices and instructions may result in the access, use, disclosure, modification or deletion of certain or all Customer Data, please review the Help Center pages for more information about these choices and instructions.

2. Other information

We may retain your Personal Information (contact details) for as long as your User Account is active or as otherwise needed to provide you with information about our Services. As the data subject you have rights related to processing of your personal data and the option of withdrawing your consent to receive promotions at any time. Please see paragraph “Your rights”.

If you have any questions about your information, our use of this information, or your rights when it comes to any of the foregoing, contact us at help@skill-focus.com.

Other Choices

In addition, the browser you use may provide you with the ability to control cookies or other types of local data storage. Your mobile device may provide you with choices around how and whether location or other data is collected and shared. Skill Focus does not control these choices, or default settings, which are offered by makers of your browser or mobile device operating system.

Sharing and Disclosure
There are times when information described in this privacy policy may be shared by Skill Focus. This section discusses only how Skill Focus may share such information. Customers determine their own policies for the sharing and disclosure of Customer Data. Skill Focus does not control how Customers or their third parties choose to share or disclose Customer Data.

1. Customer Data
Skill Focus may share Customer Data in accordance with our agreement with the Customer and the Customer’s instructions, including:

With third party service providers and agents. We may engage third party companies or individuals to process Customer Data.
With third party integrations. Skill Focus may, acting on our Customer’s behalf, share Customer Data with the provider of an integration added by Customer. Skill Focus is not responsible for how the provider of an integration may collect, use, and share Customer Data.

2. Other information
We do not rent, sell, or share personal information about you with other people or other companies without your consent except to provide products or services you've requested, when we have your permission, or under the following circumstances:

About you with the Customer. There may be times when you contact Skill Focus to help resolve an issue specific to a team of which you are a member. In order to help resolve the issue and given our relationship with our Customer, we may share your concern with our Customer.
We provide the information to trusted partners who provide us services under confidentiality agreements who work on our behalf under confidentiality agreements and might store, maintain or process your data. These companies do not have any independent right to share this information.
During changes to our business structure. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Skill Focus’s assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence). In this event, we will notify you by electronic means before information about you is transferred and becomes subject to a different privacy policy.
We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.
To enforce our rights, prevent fraud, and for safety. To protect and defend our rights, property, or safety, or the rights, property, or safety of or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.
We may disclose or use aggregate or de-identified information with third parties, such as potential customers, business partners, marketers, and funding sources, for marketing, advertising, research or similar purposes. This information does not identify you individually and is used to help us to analyze patterns among groups of people. We do not link aggregate user data with Personal Information.

International data transfers
Skill Focus complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Skill Focus has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov. For more information, see our Privacy Shield Notice.

Email marketing preferences
Skill Focus respects your email marketing preferences. If you prefer not to receive promotional email messages from Skill Focus, you can unsubscribe from Skill Focus’s email marketing list in your account any time by accessing "account settings" page, or contact us at help@SkillFocus.com with “UNSUBSCRIBE” in the subject line. Note: Please allow 5 business days to be removed from email communications.

Your rights
Ensuring that PII we hold about you is accurate and complete is important to us.

You have the following rights in accordance with the General Data Protection Regulation

1. THE RIGHT TO BE INFORMED. In this privacy statement we supply you detailed information related to your personal data storage, maintenance and processing.

2. THE RIGHT TO ACCESS INFORMATION HELD ABOUT YOU.

3. THE RIGHT TO RECTIFY YOUR PERSONAL DATA if it is inaccurate, incomplete or out-of-date.

4. THE RIGHT TO ERASURE (DELETE OR REMOVE) YOUR PERSONAL DATA.

5. THE RIGHT TO RESTRICT (BLOCK) PROCESSING. When processing is restricted, we will store your personal data, but not further process it.

6. THE RIGHT TO DATA PORTABILITY is your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another controller from the current controller applicable if: The processing is based on consent or on a contract, and the processing is carried out by automated means.

7. RIGHTS RELATED TO AUTOMATED DECISION MAKING INCLUDING PROFILING.

8. THE RIGHT TO WITHDRAW YOUR CONSENT OR OBJECT TO DIRECT MARKETING AND OTHER TYPES OF PROCESSING IF APPLICABLE.

You can exercise your rights by contacting us at help@SkillFocus.com

9. THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You have The right to lodge a complaint with a supervisory authority if you have a concern about our information rights practices.

Privacy Shield Principles
Skill Focus complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
In compliance with the Privacy Shield Principles, Skill Focus commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Skill Focus at help@SkillFocus.com

In the event we are unable to resolve your concern, you may contact EU Data Protection Authorities for EU/EEA Data Subjects which provide an independent third-party dispute resolution body. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means.

Skill Focus may disclose personal data to trusted third parties as indicated in the Privacy Policy. Skill Focus requires that its agents and service providers that have access to Personal Data within the scope of this Privacy Shield Policy provide the same level of protection as required by the Privacy Shield Principles. We ensure that our agents process Personal Data received under the Privacy Shield in a manner consistent with our obligations under the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. We may need to disclose Personal Data in response to lawful requests by public authorities, for law enforcement or national security reasons, or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law.

U.S. Federal Trade Commission Enforcement
Our organisation is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Links to Other Sites
Our website may contain links to other sites over which we have no control. Privacy policies on such linked sites may be different from our privacy policy. We encourage you to review the privacy policy at any site you visit.

Children’s information
Our Services are not directed to children, and we do not knowingly attempt to solicit or receive any information from children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us.

Contacting Skill Focus
Please also feel free to contact us if you have any questions about Skill Focus’s Privacy Policy or practices. You may contact us at help@SkillFocus.com.