Privacy Policy

Shmi Solutions LLC. DBA SkillsTrail (“SkillsTrail” or “we“) has created this privacy policy (the “Policy“) to explain our privacy practices so you will understand when and how information is collected, used, disclosed and protected with respect to our SkillsTrail application, research content, requirements templates, analyst reports, Leaderboards, phone consultations, email surveys and other services (collectively and individually, “Service“) and Web Site located at http://www.SkillsTrail.com (“Site“). By using the Service, you consent to the privacy practices described in this Policy.

Because of changes in technology and the growth and development of our business, SkillsTrail may need to modify this Policy from time to time. Changes to this Policy are discussed at the end of this document.

1. TYPES OF INFORMATION WE COLLECT ABOUT YOU

SkillsTrail collects, uses and discloses two types of information: Personal Information and Non-Personal Information (individually and collectively, “Information”). “Personal Information” is information that is directly associated with a specific person or entity such as a user’s name, initials or nickname, e- mail address, university name, phone number and user-chosen credentials. “Non-Personal Information” is information that, without the aid of additional information, cannot be directly associated with a specific person or entity.

2. CHILDREN

The Site is not intended for children under 18 years of age. We do not knowingly collect information from anyone under the age of 18.

3. GATHERING, USE AND DISCLOSURE OF NON-PERSONAL INFORMATION

(i) Web Browsers Like most Site operators, SkillsTrail gathers from users of the Site Non-Personal Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (“IP”) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving the Site. At this time, the Site does not acknowledge browser “do not track” settings.

(ii) Cookies A cookie is a small amount of data, often including an anonymous unique identifier that is sent to your browser from a Site’s computers and stored on your computer’s hard drive. Most browsers automatically accept cookies as the default setting. SkillsTrail uses cookies to track a user’s use of the Site during each Site session, both to help SkillsTrail improve users’ experiences and to help SkillsTrail understand how the Site is being used. YOU CAN MODIFY THE SETTING TO REJECT COOKIES OR TO PROMPT YOU BEFORE ACCEPTING A COOKIE FROM THE SITES YOU VISIT BY EDITING BROWSER OPTIONS. IF YOU DECIDE NOT TO ACCEPT OUR COOKIES, HOWEVER, YOU WILL NOT BE ABLE TO USE THE SERVICE.

(iii) Google Web Analytics Service We also use cookies as part of the Google Web Analytics service that SkillsTrail utilizes on the Site. SkillsTrail may collect, use and disclose Non-Personal Information by means of the cookies used in connection with Google Web Analytics, and such use is subject to this Policy. In addition, Google may collect Non-Personal Information about you by means of the Google Web Analytics service. Google’s use of this Non-Personal Information is subject to the Google Privacy Policy (currently located at http://www.google.com/intl/en/privacypolicy.html). For further information about third parties’ collection of Non-Personal Information and Personal Information by means of the Site, please see Section 5 below.

(iv) Web Beacons A “Web Beacon” is an object that is embedded in a web page. It is usually invisible to users but allows Site operators to check whether a user has viewed a particular web page. Web Beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all cookies or modifying your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. Third parties are not permitted to use Web Beacons on the Site.

B. Use and Disclosure of Non-Personal Information

We use cookie technology to: (i) collect information so that we can improve our Site by seeing which areas and features are most popular; (ii) personalize the Site and improve the Site experience; and (iii) allow you to visit the Site without re-entering your member ID and/or password. While we use cookies to record current session information, we do not use permanent cookies. SkillsTrail analyzes Non-Personal Information gathered from Site users to help SkillsTrail better understand how the Site is being used. By identifying patterns and trends in usage, SkillsTrail is able to better design the Site to improve users’ experiences, both in terms of content and ease of use. We may share Information about our users in the aggregate with third parties for various purposes, including to help us better understand and improve our Service, as well as for advertising and marketing purposes. The latter allows us to offer our Site and Service to prospective software buyers at no cost. In case you are using the free SkillsTrail Free Edition offering (as described in our End User License Agreement), based on certain Information, vendors may display and/or send you an advertisement, message, enquiry, email or phone call, publicizing or offering you their products; such messages would be a result of targeted advertising based on your profile type or Information shared. In the case of users using the SkillsTrail Paid Edition offering (as described in our End User License Agreement), vendors do not have access to your Personal Information via the Site; in such cases, only Non-Personal Information may be shared with them. In either case, please note that you initiating interaction (or having SkillsTrail Support personnel do so on your behalf) with a course vendor initiated by the Site or your response to any vendor message or email may result in that vendor viewing your Personal Information.

4. COLLECTION, USE AND DISCLOSURE OF PERSONALI NFORMATION.

A. Collection of Personal Information

As defined above, Personal Information is information that can be directly associated with a specific person or entity. Given that one of the primary objectives of our Service is to easily and meaningfully connect technology buyers and vendors, we collect a range of Personal Information from and about Site and Service users. Much of this Personal Information is information provided by users themselves when they register with the Site or register with a third-party SkillsTrail-affiliated site, or when using the Site and Service, or when speaking with a SkillsTrail representative on the phone, or when interacting with SkillsTrail content on social media. For example, when you register with the Site to use the Service, you may submit your name, initials or nickname, e-mail address, phone number and access approval request via LinkedIn.com or Google account. You may also create a user-chosen ID and password for your use when accessing the Service in lieu of Linkedin.com or Google account. You may also input Personal Information pertaining to your skills and university. BY REGISTERING WITH THE SITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION SECTION.

SkillsTrail collects the above kinds of Personal Information:

• when you provide information to SkillsTrail, such as when you register or sign up for SkillsTrail service, subscriptions, e-mails, contests, newsletters, memberships, RSS Feeds, content delivery via SMS text or other technologies, webcasts, white papers, online seminars, conferences and other communications with SkillsTrail;
• when you register or sign up on the SkillsTrail website or SkillsTrail-affiliated third-party websites, or when you register for any other SkillsTrail products or services on SkillsTrail websites or through SkillsTrail affiliates or business partners,
• when you engage with a SkillsTrail representative via telephone, email or in-app messaging or chat,
• when you use the Site or the Service;

SkillsTrail may add other information collected from third-party sources to enhance and/or update the Personal Information that you provided to SkillsTrail.

B. Use and Disclosure of Personal Information

SkillsTrail may use the Information a user submits for any purposes related to SkillsTrail’s business purposes, including, but not limited to: (i) understanding a user’s requirements and career goals; (ii) allowing users to identify, short-list and establish contact with relevant course vendors (and share any information the user has provided to the vendors); (iii) allowing vendors to respond back to the user; (iv) generating statistical studies; (v) estimating usage; (vi) measuring aggregate traffic patterns; (vii) understanding Site demographics, customer interest and other trends about users; (viii) improving Services, information and products; (ix) communicating with the user; (x) providing a user with Services or support; (xi) updating the user on Services, information and products; (xii) personalizing the Site for the user; (xiii) notifying the user of any changes with the Site which may affect the user; (xiv) enforcing terms of use on the Site; (xv) in the case of users of SkillsTrail Free Edition offering, displaying vendor advertisements, messages, enquiries and other types of promotional activities; and/or (xvi) allowing the user to access Services or otherwise engage in activities the user selects.

We may share Personal Information about certain of our users with third parties for various purposes, including to help us better understand and improve our Service, as well as for advertising and marketing purposes. In case you are using the free SkillsTrail Free Edition offering (as described in our End User License Agreement), based on certain Information, SkillsTrail personnel and/or vendors may display and/or send you an advertisement, message, enquiry, email or phone call publicizing and offering you their products; such messages would be a result of targeted advertising and follow-up based on your profile type or Information shared. In the case of users using the SkillsTrail Paid Edition offering (as described in our End User License Agreement), vendors do not have access to your Personal Information via the Site; in such cases, only Non-Personal Information may be shared with them. In either case, please note that you initiating interaction (or having SkillsTrail Support personnel do so on your behalf) with a vendor through the Site or your response to any course vendor message may result in that vendor viewing your Personal Information.

Addresses (physical / postal addresses, email addresses, IP addresses), telephone numbers, and associated Personal Information of the SkillsTrail Free Edition will be used to promote SkillsTrail as well as third-party products and services to users, and may be shared with and/or licensed to third-parties and advertisers for promotional purposes. When you provide your email address to us, you agree to receive email from SkillsTrail and/or third-party affiliates. We allow users to “opt-out” of receiving email from SkillsTrail when email address is collected. Also, you can individually “opt-out” of receiving further email from SkillsTrail every time an email is received by you. If a user does not choose to “opt-out” at the time the email address is collected, the address may be rented and/or licensed for use to third-parties.

C. Disclosure of Personal Information As described in Section 4(A) (“Collection of Personal Information”), users may, at their option, disclose their own Personal Information by any means they choose. SkillsTrail will also disclose Personal Information, in the following circumstances:

(i) Material You Choose to Reveal in On-line Forums, Blogs, Message Boards, Chat Rooms, Site or Service, Course Vendor Interactions or Similar Services You may post Personal Information on areas of the Site that may be viewed by other users, specific vendors or even the public at large. We urge you to use good judgment and not post Personal Information that you do not want other users to know. Users may not be able to change or remove public postings once they are posted. Such Personal Information may be used by visitors of these pages to send you unsolicited messages.

YOU ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM YOUR VOLUNTARY DISCLOSURE OF PERSONAL INFORMATION BY USING OUR SITE AND SERVICE.

(ii) DMCA Infringement Notifications, Notices of Violations of Site Terms of Service and Other Communications Directed to SkillsTrail By submitting a Digital Millennium Copyright Act (“DMCA”) Infringement  Notification or other communication (including communications about content stored on or transmitted through the Site) you consent to have this  communication forwarded to the person or entity who stored or transmitted the content addressed by your communication, in order to facilitate a prompt resolution. For notices other than DMCA Infringement Notifications, upon request, SkillsTrail will edit out your name and contact information. However, DMCA Infringement Notifications (including any personally identifiable  information set forth in the Notifications) will be forwarded as submitted to SkillsTrail without any deletions.

(iii) Surveys From time to time, SkillsTrail may also ask Site users to participate in surveys designed to help SkillsTrail improve the Site. Any Personal Information provided to SkillsTrail in connection with a survey will be used only in relation to that survey, and will be disclosed to third parties not bound by this Policy only in non-personally-identifying, aggregated form.

(iv) Employees and Third Party Processors SkillsTrail will disclose Personal Information to those SkillsTrail employees, contractors, affiliates, course vendors and suppliers who process Personal Information on SkillsTrail’s behalf or participate with SkillsTrail in the provision or operation of the Site.

(v) By Law, to Protect Rights and to Comply with SkillsTrail Policies SkillsTrail discloses Personal Information if: (1) required to do so by law, or in response to a subpoena or court order; (2) SkillsTrail believes in its sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of SkillsTrail, other users, third parties or the public at large; and (3) SkillsTrail believes that you have abused the service by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws.

(vi) Business Transfers; Bankruptcy SkillsTrail reserves the right to transfer all Personal Information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of SkillsTrail assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Policy, or to a new privacy policy if you are given notice of that new privacy policy and you affirmatively opt-in to accept it. Personal Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

(vii) Contests, Giveaways and other Promotions From time to time, SkillsTrail may offer Site users the opportunity to participate in contests, giveaways and other promotions offered by SkillsTrail or certain course vendors. Any information submitted in connection with promotions will be subject to the terms of the promotion, not this Policy. You may be given the option to consent to the use of your Personal Information at the time you sign up for the promotion. You will not be required to participate in any promotion, if you are a user of the SkillsTrail Corporate Edition offering.

(viii) Use of your credentials with SkillsTrail From time to time, such as when troubleshooting an error or problem or when auditing usage, a SkillsTrail support representative may need to log in as you (referred to as “sudo access”) into the Site to replicate the problem or to view the relevant error message. Please be aware that during such times, the SkillsTrail support representative will have access to your data and projects within the Site; however support representatives do not have access to your password at any time.

5. COLLECTION AND USE OF INFORMATION BY THIRD PARTIES NOT COVERED BY THIS POLICY

Third parties are under no obligation to comply with this Policy with respect to Personal Information or Non-Personal Information that users provide directly to those third parties or that those third parties collect for themselves (including, without limitation, Google as described in Section 3(A)(iii)). Please be aware that we may provide links to third party sites as a service to our users and we are not responsible for the content or information collection practices of those sites. SkillsTrail does not control the third party websites accessible through the Site. This Policy does not apply to information provided to or gathered by third parties that operate them. Third parties’ privacy policies will differ from those of SkillsTrail. Therefore, we encourage you to review and understand third parties’ privacy practices before visiting third party sites or providing third parties with information, and take those steps necessary to, in your discretion, protect your privacy.

6. SECURITY

SkillsTrail takes reasonable precautions to prevent unauthorized release, corruption, or loss of your personal and project data. However, neither people nor security systems are foolproof. Therefore, while we have taken efforts to guard your personal information, we cannot guarantee its absolute security.

7. MODIFYING YOUR PERSONAL INFORMATION

If you are a registered user of our Service, you may view, correct, and delete your Personal Information, simply by logging into the Service and editing your profile and other data.

8. OPTING OUT OF FUTURE SKILLSTRAIL COMMUNICATIONS

If at any time you would like to opt out or unsubscribe from receiving future marketing emails from SkillsTrail, you can email us at unsubscribe@SkillsTrail.com and we will remove you from all our marketing correspondence within 24 business hours. Some of our marketing emails will allow you to also unsubscribe by either responding back to it or clicking on the link at the bottom of the email; specific instructions will be in the email body.

Please note that opting out of marketing emails does not mean that you will not receive any future communications from SkillsTrail or a course vendor partner to whom your information has already been shared with, based on your verbal (via telephone) or electronic (via the Site) approval. For example, future SkillsTrail communications could be transactional, rather than marketing-related. Such transactional emails would be related to your usage of the Service and Site, such as responses to an ongoing RFI or RFP, or a password reset request. If you wish to delete your account within the Site or Service, please email support@SkillsTrail.com with your account information, and such request will be addressed within 24 business hours per the terms of the current EULA you have agreed to.

For removal of your information from any vendor partner’s database, please contact them directly. Please know that you have the right to know which vendor partners your Personal Information may have been shared with. Such vendor information would already have been emailed to you previously (subsequent to your phone or electronic approval, and prior to such sharing). If you wish to receive that data again from SkillsTrail, please email support@SkillsTrail.com.

EU Citizens

If you are a citizen of the European Union and/or other areas that are within the scope of the General Data Protection Regulation (GDPR), as of May 25, 2018, you may have additional rights as stipulated by the above directive. If you believe that is the case, please email support@SkillsTrail.com with your specific request or concern. Please note that in order to verify your identity, and appropriately comply with your request, we may require you to provide us with additional Personal Information.

Canadian Citizens

If you are a citizen of Canada and within the scope of the Canadian Anti-Spam Legislation (CASL) as of July 1, 2017, you may have additional rights as stipulated by the above directive. If you believe that is the case, please email support@SkillsTrail.com with your specific request or concern. Please note that in order to verify your identity, and appropriately comply with your request, we may require you to provide us with additional Personal Information.

9. UPDATING THIS POLICY

We may revise and update this Policy if our practices change, as technology changes, or as we add new services or change existing ones. Whenever possible, SkillsTrail may alert you by email if this policy is revised. In addition, any changes to this Policy will be posted on the Site, and we will update the “last updated” date set forth above. It is therefore important that you register with the Site and notify us if you change email addresses. In any case, you should regularly check our Policy whenever you use the Service to see if it has been updated since your last visit.

10. APPLICABLE LAW

Our collection, storage and use of any and all Information shall be governed by the laws of Denver, Colorado, United States of America.

11. CONTACTING SKILLSTRAIL

Any questions about this Policy or changes to your account information should be addressed to SkillsTrail by email at: support@SkillsTrail.com.