SkillsReNEW is committed to safeguarding your privacy online. Please read the following policy to understand how your personal information will be treated as you make full use of SkillsReNEW. This policy may change from time to time so please check back periodically.

This Privacy Policy explains how SkillsReNEW collects, uses, and shares information about you when you use the SkillsReNEW Website, Mobile App and Learning Management System Platform (“Platform”), or otherwise interact with us. It also goes over how you can exercise your privacy rights and choices.

The Platform is designed to allow Course Creators (“trainers”) to build, design, publish, and sell courses, coaching, consulting and other services to their Students (“learners”). This Privacy Policy applies when you access or use the services and tools offered through our Platform (“SkillsReNEW Services”), or otherwise interact with us. Your access to our Platform and use of SkillsReNEW Services is also governed by our Terms of Use. Capitalized terms used but not defined in this Privacy Policy can be found in our Terms of Use.

Please read this Privacy Policy carefully prior to accessing our Platform and using SkillsReNEW Services. If you have any questions, please contact us at: privacy@ulavitech.com

As stated in our Terms of Use, you must be at least 18 years old to use the Platform, or, if you are between the ages of 13 and 18, you must have your parent or guardian’s permission to use the Platform. SkillsReNEW does not knowingly collect or store any personal information from or about children under the age of 13, and we will delete such information if we become aware that it has been submitted through our Platform.

Parents or guardians who believe that SkillsReNEW might have any personal information from or about a child under the age of 13 may submit a request to privacy@ulavitech.com for us to remove such information.

Personal information refers to any information that relates to an identified or identifiable individual. How we handle your personal information will depend on whether we act as a “data owner” or as a “data processor” of the personal information. The data owner is the entity that decides how and why to process personal information. The data processor processes personal information on behalf of the data owner at the data owner’s direction.

SkillsReNEW’s Role as a “data owner” of Your Personal Information. SkillsReNEW is the data owner of personal information that it collects and processes in connection with the use of our marketing site and the provision of SkillsReNEW Services. This includes personal information that you provide to us when you create an account on the Platform, subscribe to a SkillsReNEW plan, enrol in a course, purchase Coaching & Consulting services through our Platform, etc. Please refer to the “What personally identifiable information is collected from you” section of this Privacy Policy for more information about personal information that SkillsReNEW collects as a data owner.

SkillsReNEW’s Role as a “data processor” of Personal Information Collected by Trainers. Course Trainers who are the owners of their course content that they upload, submit, or otherwise provide to the Platform (“Trainer Content”) and are the data owner with respect to any personal information included in their Trainer Content. SkillsReNEW acts as a processor when it processes Trainer Content on behalf of the Trainer.

When a Learner enrols in Trainer Content, SkillsReNEW will provide the Trainer access to a limited set of personal information about the Learner (“Learner Data”) to enable the Trainer to provide their services to the Learner. SkillsReNEW and Trainers may each use Learner Data for their own business purposes, at all times subject to the terms of this Privacy Policy, the Data Processing Agreement and our Terms of Use. The Trainer and SkillsReNEW each act as an independent data owner with respect to their particular use of Learner Data.

Trainers acknowledge and agree that they are responsible for complying with all applicable laws and regulations related to the protection of personal information for which they are data owners.

If you are a Learner whose personal information has been collected by a Trainer, please contact the Trainer directly and view the Trainer’s privacy policy if you have questions about how the Trainer uses your personal information.

SkillsReNEW collects personal information about you in several different ways, depending on how you interact with our Website and/or Platform. Please note that the types of personal information we collect differs depending on how you’re using our Platform, for example, as a Trainer or a Learner.

Some personal information is gathered when you register. During registration, we ask for your first, last name and email address. The system will also ask for your region, street address, city, state/province, zip/postal code, country, telephone number, and the URL of your web site, although only fields that are marked with an asterisk (*) on the registration field are required or in future only required fields will be presented for registration. This information assists you in navigating the system by automatically filling in certain forms (such as the ad posting form) with your information so that you don’t have to continually re-enter it. Once you register you are no longer anonymous to SkillsReNEW – you have a username and are able to take full advantage of the many offerings of SkillsReNEW.

In addition to registration we may ask you for personal information at other times, including (but not limited to) when you make payment, place ads or take advantage of the other features of SkillsReNEW. If you contact us, we may keep a record of that correspondence. Every page footer within SkillsReNEW includes a link to this Privacy Policy.

We collect personal information you directly provide to us. We may also receive personal information about you from others; e.g. from another user or our trainers or our payment processors.

• Account Information. To use certain features of our Platform (such as to create a course or to enrol in a course), you’ll need to register for an account with SkillsReNEW. To do so, you’ll need to provide us with certain personal information, such as your name, email address, and password.
• Third Party Integrations. You may allow our Platform to interact with third party services (such as Facebook, Instagram, LinkedIn, Twitter, Zoom, WebEx and GoToMeetings, and other software & hardware service providers where applicable). The information you allow SkillsReNEW to access varies by service, and it is affected by the privacy settings you and those that you are connected with establish while using such services. Third-party services are operated, controlled, and maintained by third parties that are not operated, controlled, or maintained by SkillsReNEW. We recommend that you read the terms of use and privacy policies of those third party services to understand how they collect, use, and share your personal information with us or other third parties.
• Other Personal Information. You may choose to provide us with other personal information. For example, we may collect your name, email address and other personal information when you fill out a survey, participate in a SkillsReNEW-sponsored contest or promotion, request customer support, or otherwise communicate with us.

• SkillsReNEW Plans. When you subscribe to a paid SkillsReNEW plan, we will collect certain personal information from you for the purposes of billing your subscription fees and any payment service fees, such as your business registration name and/or tax number, business and billing address. You’ll also need to provide certain payment-related information to us and/or directly to our third party-payment processors, as described below.
• Trainer Payment Information. If you’re using SkillsReNEW’s Native Payment Gateways, you’ll need to link your payment account to our Platform to receive pay-out’s. By linking your payment (bank) account, SkillsReNEW will receive certain payment related information about you, including your payment card type and last four digits, postal code, country of origin, payment expiration date, and any email address associated with the payment type. Further, we will collect certain personal information for tax purposes. This tax information may include your full name, address, and business registration name and number.

• Learner Payment Information. To purchase a course, coaching, consulting or other services through our Platform, you’ll need to provide us with certain personal information, such as your name, address, and information about the service you are purchasing. You may also need to provide certain payment-related information directly to us and/or our third party payment processors, as described below.
• Third Party Payment Processors. We use third party payment processors like Red Dot Payment, Razor Pay, PayPal and Stripe to process payments through the SkillsReNEW Platform. For payments processed via SkillsReNEW Native Gateways, the third party processor provides us with information related to the payment status of your account; this information includes your payment card type and last four digits, payment expiration date, zip code, approximate location based on IP address, country of origin, and any email address associated with the payment type. For security purposes, SkillsReNEW does not collect or receive or store any sensitive payment information, such as your complete card number or authentication data. Our third-party payment processors are independent from SkillsReNEW and have their own privacy policies. For additional information about how your payment information is processed and stored, we recommend that you review the applicable payment processor’s privacy policy.
• Participation in Trainer Content. When you enroll in a course, coaching and/or consulting service, or use or access other Trainer Content, SkillsReNEW will collect personal information relating to your participation in the Trainer Content, such as courses you have enrolled in, quiz results, lecture progress, course video progress and certifications.

We automatically collect certain information from your interactions with our Platform.

• Usage Data. SkillsReNEW logs usage information when you visit and use our Platform. This information may include IP address, browser type, operating system, and other information about the use of our website, such as the pages you viewed, when you viewed them, and links that were clicked.
• Cookies and Similar Technology. SkillsReNEW may collect information about you through the use of cookies and other similar technologies. Cookies are pieces of data in the form of text files that your browser stores on your hard drive and sends back to us when making requests, and similar technologies. For more information on our use of cookies and similar technologies, please refer to our Cookie Policy.
• Approximate Location. We may receive and process information about your approximate location. For example, we may be able to determine your approximate location from your IP address and other information about you. SkillsReNEW does not ask for or track any precise location-based information.

As part of offering and providing customizable and personalized services, SkillsReNEW may use cookies to store and sometimes track information about you. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Several features of SkillsReNEW require that you accept cookies in order to work properly.

Generally, we use cookies for the following purposes:

• To identify and label all “new” ads since your last visit to the site.
• Optionally to permanently save your password on your computer so you don’t have to re-enter it each time you visit our site.
• To enable you to “checklist” ads that you want to mark for future retrieval and viewing.

SkillsReNEW also collects IP addresses for system administration and to report aggregate information to our advertisers.

We also use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address, or telephone number) about your visits to SkillsReNEW and other websites in order to provide advertisements about goods and services of interest to you.

In particular, Google uses the DART cookie to serve ads based on your visit to SkillsReNEW and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

Your browser may give you the option to send a “Do Not Track” instruction to websites you visit. However, since there is no accepted standard for how a website should respond to this instruction, we do not currently recognize or respond to these signals.

SkillsReNEW primary purposes for using your personal information are to provide you with a smooth, efficient, and customized experience, for customer support, advertising and marketing communications, research and service development, and to keep our Platform and users safe and secure.

Specifically, we may use your information for the following business purposes:

To provide and improve our services. We use personal information that we collect about you to allow you to access our Platform, to provide you with the services you request, and to improve and customize SkillsReNEW Services.

For customer support. We use personal information to investigate, respond to, and resolve customer queries, send you technical notices and security alerts, and provide other support and administrative services.

For advertising and marketing communications. We use personal information to develop targeted advertising both on and off our Platform about SkillsReNEW Services, and to communicate with you about our products, services, offers and promotions, including making recommendations about SkillsReNEW Services you may be interested in.

For research and service development. We use personal information to conduct market research and to develop new services in order to provide you with a better experience and to drive growth in our business.

For legal and security purposes. We use personal information to prevent, detect, investigate, and take measures against criminal activity, fraud, misuse of or damage to our Platform or network, and other threats and violations to SkillsReNEW’s or a third party’s rights.

When you are asked for personal information on SkillsReNEW, you are sharing that information with SkillsReNEW, unless it is specifically stated otherwise with third parties for some activities, by their very nature, result in your personal information being revealed to other users of SkillsReNEW. We have listed below “How We Share Personal Information We Collect” below in detail. For example, when you enter personal information on the payment page, ad posting form, this information will generally be included in your payment processing or ad, unless specifically stated otherwise.

Other than information displayed as part of your profile, as a general rule, SkillsReNEW will not disclose any of your personally identifiable information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below. Please see the Terms of Service or Use Agreements for each of our products and services for more detailed information about how your personal information may be shared.

SkillsReNEW may disclose account information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Terms of Service of SkillsReNEW or may be causing injury to or interference with (either intentionally or unintentionally) the rights or property of SkillsReNEW, other users of SkillsReNEW, or anyone else that could be harmed by such activities. SkillsReNEW may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services.

Certain features at SkillsReNEW, including but not limited to course material, video & audio uploads, are outsourced to partner sites. If you wish to access these features, your registration information will be submitted to the relevant partner site in order to open an account on your behalf. This new account is necessary to manage content posted by your account at SkillsReNEW, as such content will be managed off-site.

SkillsReNEW only shares your personal information with third parties under the circumstances described below. We do not sell or otherwise disclose personal information we collect about you for monetary or other valuable consideration.

Sharing of Learner Information with Trainers

When you participate in Trainer Content, SkillsReNEW will share certain personal information about you (“Learner Data”) with the Trainer on need-only basis to allow the Trainer to provide you with their services. The set of personal information that we may share with Trainers are limited to the following:

• Account information, including your name and email address (optional)
• Purchase information, including amount paid, your address or country or region, and other billing information (but never your complete card number, which we do not collect & store)
• IP address
• Information about your participation in the Trainer Content, including the Trainer Content you enrolled in, lecture completion status, course progress, quiz results, and certificates.
• Any messages you exchange with the Trainer through SkillsReNEW

SkillsReNEW will only provide Learner Data to a Trainer upon a purchase by or enrolment of a Learner in the Trainer’s Content.

SkillsReNEW does not disclose any other types of personal information about Learners to Trainers.

Any additional personal information that is shared by a Learner with a Trainer is done so at the discretion of the Learner. The Trainer is responsible for protecting Learners’ personal information that they collect and processing that information in accordance with applicable data protection laws. Learners who have questions about Trainers’ privacy practices should contact the Trainers directly and ask to review the Trainers’ privacy policies.

Sharing of Trainer Information with Learners and Other Users When you use SkillsReNEW Services to publish Trainer Content, information contained in your Trainer Content will be viewable to users who are given access to your Trainer Content. For example, when you publish your bio on a sales, marketing & landing page, personal information in your bio will be viewable to persons who visit your or general sales, marketing and landing page.

Please keep in mind that all of the information that you share or content that you publish in your bio, posts, comments, or other public portions of our Platform becomes public information. Because this information is publicly available, we cannot control how others treat it. We ask you to exercise care in deciding what personal information you choose to share, and refrain from sharing your sensitive personal information and those of others.

We may also share your personal information in the following ways:

With Integrated Services

When you choose to integrate third party services with our Platform, your personal information may be shared with these third parties. We recommend that you read the terms of use and privacy policies of those third party services to understand how they collect, use, and share your personal information.

With Your Consent

SkillsReNEW may send your personal information to a third party when you give us consent to do so or at your direction. For example, this may occur when we complete a transaction at your request.

With Service Providers

We may share personal information with vendors, consultants, payment processors, and other service providers that provide us with certain services and process personal information on our behalf. These services may include providing customer support, performing business and sales analysis, supporting our website functionality, facilitating payment processing, and supporting contests, surveys, and other features offered on our Platform.

These service providers are not permitted to use your personal information for any other purpose, and their use of such personal information will be subject to appropriate confidentiality and security measures.

With Business Partners

We sometimes partner with third parties to offer you events, promotions, contests and other programs. To participate in these offers, you may be required to provide your email address and other personal information. We will only share your email address and other personal information with a business partner when you expressly authorize us to do so.

With Advertising and Analytics Partners

We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device. For more information on our use of cookies and similar technologies, please refer to our Cookie Policy.

With Affiliates & Partners

We may share personal information with our parent, affiliates & partners, and other companies under common control and ownership, subject to the terms of this Privacy Policy .

We may also share your personal information in connection with a substantial corporate transaction, such as a sale of our business, a divestiture, merger, consolidation, or asset sale, in the event of bankruptcy, or in preparation for any of these events. Any other entity which buys us or becomes part of our business will have the right to continue to use your personal information, but only in the manner set out in this Privacy Policy unless you agree otherwise.

SkillsReNEW may be required to disclose personal information if directed by a court of law or other governmental entity. Without limiting the foregoing, we reserve the right to disclose such information where we have a good faith basis to believe that such action is necessary to:

• comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests;
• protect and defend SkillsReNEW’s or a third party’s rights and property, or the safety of SkillsReNEW, our users, our employees, or others; or
• prevent, detect, investigate and take measures against criminal activity, fraud and misuse or unauthorized use of our Website, Platform and/or to enforce our Terms of Use or other agreements or policies.

To the extent permitted by law, we will attempt to give you prior notice before disclosing your information in response to such a request.

We may share your information for reasons not described in this policy. We will tell you before we do this.

If you choose not to register or provide personal information, you can still use most of SkillsReNEW, but you will not be able to access areas or use features that require registration.

You also have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you will be unable to use those services of SkillsReNEW that require registration in order to participate. These services include the identification of new ads that have been posted since your last visit, auto-filling of the logon form, and the Checklist feature. You can still use most of the features of SkillsReNEW even if you do not accept cookies.

You can also choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Platform because that information may be required for you to register for an account, purchase SkillsReNEW Services, enroll in Trainer Content, participate in our promotional offerings, get customer support, or engage in other activities on our Platform.

Please refer to the ‘Data Privacy Requests and Verification’ section below for information on how to make a data privacy request.

SkillsReNEW does not sell or rent user information to anyone. We will notify you at the time of data collection or transfer if your data will be shared with a third party and you will always have the option of not permitting the transfer. If you do not wish to allow your data to be shared, you can choose not to use a particular service.

Rights of Learners Related to Personal Information Shared with a Trainer.

Please note that in cases where you wish to exercise your data privacy rights with respect to personal information for which a Trainer is the controller, you’ll need to directly contact the Trainer to exercise your rights.

We will provide you with the means to ensure that your personal information is correct and current. You may edit your user profile at any time by clicking on the “Profile Icon”,  “Edit Profile” link or graphic or image provided by the system once you are logged in. Once you have logged onto the system during a given session, wherever you go on SkillsReNEW, your information will stay with you until or unless you click on the “Logout” link, which is accessible from within the “Profile Icon”, “Log Out” option.

If you are a previously registered user and you have lost or forgotten your password, you may obtain it by email by using our “Forgot Password?” feature. Click the button on any login page to request that your password be emailed to you. We cannot provide your password by any other means.

If you believe that any personal information we are holding about you is incorrect or incomplete, we will work with you to make corrections deemed necessary. Note that we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you’d like SkillsReNEW to delete your account or delete personal information it holds about you, you can submit a deletion request. Note that when we delete your account, personal information that you have shared with others (for example, through comments or an intake form) may still be visible. SkillsReNEW will also retain certain personal information about you were reasonably necessary to comply with our legal obligations or for our legitimate business purposes.

Your SkillsReNEW account once deleted will result in not being able to access any of the features of the program that require user registration.

Data Privacy Requests and Verification

You can request to access, update, or delete your personal information by emailing us at privacy@ulavitech.com from the email address associated with your account.

If you would like to make a request under the privacy laws of your jurisdiction, please let us know where you reside and which rights you’d like to exercise. For more information about exercising your jurisdiction-specific privacy rights, please see section ‘Jurisdiction Specific Provisions’ below.

To protect your privacy, we need to verify your identity before we process your data privacy request. As part of this process, you may contact us via the email address associated with your account. Depending on the nature of the request, we may also need to obtain additional information necessary for us to verify your identity.

You may designate an authorized agent to make a data privacy request on your behalf. To do so, we will need to receive written permission by you or a valid power of attorney, and we may also verify the validity of the request directly with you.

Controlling Promotional Communications

You can opt out of receiving some or all of our promotional communications through the unsubscribe link in the email or by emailing support@ulavitech.com

If you opt out of promotional communications, we may still send you transactional communications, such as service announcements, administrative and legal notices, and information about your account, without offering you the opportunity to opt out of these communications. If you no longer wish to use our Platform or receive any communications from us (except for those that are legally required), please contact support@ulavitech.com to have us delete your account.

Please note that opting out of promotional email communications only affects future communications from us. If we have already provided your information to a third party (such as a credit card processing partner) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party.

The kind of security precautions that are in place to protect the loss, misuse, or alteration of your information

Other than the administrator or other authorized personnel of SkillsReNEW, you are the only person who has access to your personal information. Your user registration is password protected to prevent unauthorized access.

We recommend that you do not divulge your password to anyone. SkillsReNEW will never ask you for your password in an unsolicited phone call or in an unsolicited email. As an extra security precaution, you may want to logoff once you have completed a session in SkillsReNEW. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, SkillsReNEW cannot ensure or warrant the security of any information you transmit to us or from our online services, and you do so at your own risk. Once we receive your transmission, we make our best effort to ensure its security on our systems or with our partner outsourced hosting systems.

What else you should know about your online privacy

Please keep in mind that whenever you voluntarily disclose personal information online – for example in ads that you post or through email – the information can be collected and used by others. In short, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return.

Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you’re online.

Your consent and rights
Governing law and jurisdiction

Nothing in this Privacy Policy shall limit the rights of the data subject under the PDPA. This Privacy Policy shall be governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts.

Jurisdiction Specific Provisions

Users in Singapore

By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this policy.

Under the Personal Data Protection Act (the “PDPA”), individuals have the right:

• to check whether we hold personal data about you and to access such data
• to require us to correct as soon as reasonably practicable any data relating to you that is inaccurate
• to ascertain our policies and practices in relation to personal data and the kind of personal data held by us and
• to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us
• You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to: privacy@ulavitech.com

In accordance with the terms of the PDPA, we have the right to and may charge a minimum fee for processing any data access request.

Users in the European Economic Area, UK, and Switzerland

Under the General Data Protection Regulation (“GDPR”) and other applicable laws, users in the European Economic Area (“EEA”), UK, and Switzerland have the right to, under certain conditions, request access to, rectification of, or erasure of their personal information; request restriction of processing; object to processing; withdraw consent from processing; data portability; and submit a complaint to a data protection authority.

If you are in the EEA, UK and Switzerland and would like to exercise these rights, please email us at privacy@ulavitech.com pursuant to the ‘Data Privacy Requests and Verification’ section above. Please include the phrase “GDPR request” in the subject line and provide us with your mailing address and country of residence.

SkillsReNEW only collects and processes personal information about you where it has lawful bases for doing so. The specific legal basis applied to the processing will depend on the context in which the personal information is being processed, including the service used and the type of personal information involved.

SkillsReNEW uses the following legal bases for processing:

• For the performance of a contract. We will process your personal information to fulfill our contractual obligations with you, such as to provide you with access to SkillsReNEW Services, to communicate with you regarding your use of SkillsReNEW Services, and to comply with our Terms of Use.
• For legitimate interests. We will process your personal information for our legitimate interests or those of others (as long as the processing is not outweighed by your data protection interests). This includes but is not limited to, preventing fraud and other abuse, ensuring the security of our Platform, protecting our legal rights and interests, conducting market research and product development, and for marketing purposes.
• To comply with legal obligations. We will process your personal information to comply with all applicable laws, regulations, court orders, and government and law enforcement agencies’ requests.
• Consent. We will process your personal information when you have given us consent to do so, such as when you consent to receive certain communications from us.

If you’d like to withdraw your consent or object to our processing of your personal information, please contact privacy@ulavitech.com

If you believe that we have not adequately addressed your concerns or wish to report an alleged infringement of applicable data privacy laws, you may file a complaint with your local supervisory authority.

SkillsReNEW has yet to appoint its EU representative for purposes of GDPR. Interim you can contact us via privacy@ulavitech.com

Users in California

California Consumer Privacy Act. If you are a California resident, you have specific privacy rights governed by the California Consumer Privacy Act (“CCPA”). These rights include:

• Right to Know. You have the right to request a report showing the Personal Information collected, shared, and sold about you in the past 12 months.
• Right to Opt-Out of Sale of Your Personal Information. You have the right to opt-out of the sale of your Personal Information to third parties.
• Right to Deletion. You have the right to request that we delete any Personal Information collected from you.
• Right to Non-Discrimination. We shall not discriminate against you based on your exercise of any of the above rights.

You or your authorized agent may submit a request to exercise any of the above rights by emailing us at privacy@ulavitech.com with the subject line “CCPA Request”. Please also provide us with your mailing address and state of residence.

We may require additional information to verify your identity or to verify that your authorized agent has the authority to make the request on your behalf before responding to a CCPA rights request. We will respond to your request within 45 days if possible and required under the law.

Personal Information Collected on California Residents

The following are categories of Personal Information that we may collect about you, as well as examples of the types of Personal Information that may be collected:

We collect Personal Information from the following sources:

• Directly from you (e.g. Information provided when you register on our Platform, submit payment, or use any of our Platform’s services);
• Automatically collected information (e.g. collected automatically through cookies, etc.);
• Information provided by third parties, including those that you request to share information with us.

Personal Information Disclosed for a Business Purpose to Third Parties

The categories of Personal Information listed above may be disclosed to the following categories of third parties:

• For Learners, we may share your information with Trainers;
• For Trainers, we may share your information with Learners and on our Platform for the purposes of marketing or sharing information about our services;
• Integrated third parties with whom you choose to share information;
• Our service providers (e.g. cloud services providers, technical service providers, law firms, accounting firms, etc.);
• Business partners (e.g. companies that we partner with for events, promotions and contests, etc.);
• Advertising partners to provide advertising based on your interests;
• SkillsReNEW affiliates & partners, including our parent company and other companies under common control and ownership;
• When you ask us to provide information to a third party; or
• To law enforcement or others if required by law.

The disclosures to third parties listed above may be for any of the following business purposes:

• To provide you with our services;
• For marketing purposes;
• To provide you with ads or information we think may be of interest to you;
• To improve our Platform and services;
• To maintain the safety and security of our services; or
• As otherwise permitted by law.

We do not sell or otherwise disclose personal information we collect about you for monetary or other valuable consideration.

Under California’s ‘Shine the Light’ law, California residents have the right to request certain information relating to personal information we have shared with third parties for those third parties’ direct marketing purposes. Note that we only share information with third parties for their direct marketing purposes when you request us to do so or you expressly consent to it.

If you are a California resident and would like to exercise your rights under the CCPA or California’s ‘Shine the Light’ law, email us at privacy@ulavitech.com pursuant to the ‘Data Privacy Requests and Verification’ section above. Please specify which privacy right you’re exercising in the subject line (for example ‘CCPA deletion request’) and provide us with your mailing address and state of residence.

Information Security

SkillsReNEW uses a range of physical, technical, and administrative security measures to protect your personal information. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of financial information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. However, no method of data transmission or storage system is absolutely secure, and we cannot guarantee that your personal information will not be accessed, disclosed, altered, or destroyed in the event of a breach of any of our security measures.

Where we have given you (or where you have chosen) a password to access certain parts of our Platform, you are responsible for protecting this password and keeping it confidential. As the safety and security of your information also depends on the precautions you take, we ask you not to share your password with anyone. If you believe your password or the security of your account has been compromised, you should change your password immediately and contact security@skillsrenew.com with any concerns.

Data Retention

We save personal information we collect for as long as it is necessary for the purposes for which the personal information is collected and processed. Generally, we will keep your personal information until your account is deleted, or as needed to provide you with our services. We will also retain certain personal information to comply with our legal obligations or for our legitimate business purposes.

International Transfers of Information

SkillsReNEW is based in the Singapore and it stores, processes, and transfers information in and to servers and databases located in the Singapore, United States and India. It may also store, process, and transfer information in and to servers in other countries depending on the location of its outsourced partners, affiliates and service providers.

If you use our Platform outside the United States, including in the EEA, UK, and Switzerland, your information will be transferred to, stored, and processed in the Singapore, United States and India. By accessing our Platform or otherwise giving us information, you consent to the transfer of information to the Singapore, United States, India and other countries outside your country of residence.

We rely on legal bases to transfer information outside of the EEA, UK, and Switzerland. For example, transfers involving personal information of Trainers located outside the United States are necessary for the performance of the contract between SkillsReNEW and our Trainers, as established in our Terms of Use. With respect to the processing of information by our service providers on our behalf, we take all necessary steps required under applicable law to ensure that their transfer of information across borders is compliant with applicable law. This may include the use of EU model clauses.

We take many steps to protect your privacy, including entering into a Data Processing Agreement with our Trainers. If you’d like more information about the safeguards we have in place, please contact us at privacy@ulavitech.com

Third Parties and Other Personal Information Collectors

Except as otherwise expressly specified in this Privacy Policy, this document only addresses the use and disclosure of personal information SkillsReNEW collects from you. To the extent that you disclose your personal information to other parties through our Platform, whether between Trainer and Learner or with other users, different rules may apply to how they use and share your personal information. Accordingly, you will need to look at the privacy policies of these third parties to understand their data privacy practices.

As further explained in our Terms of Use, our Platform may include links to third party websites. We are not responsible for the content of such websites or the protection and privacy of any information which you provide while visiting those sites. We recommend that you exercise caution and review the privacy policies applicable to the websites in question.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of our Platform.

Changes to Our Privacy Policy

We encourage you to periodically review this Privacy Policy to stay informed about our privacy practices, as we may review and update our processes from time to time.

If we make a change that, in our sole discretion, is material, we will notify you through email, by posting a notification on our website, or as required by law. Unless otherwise stated, changes to this Privacy Policy will take effect immediately as of the date it is posted. By continuing to use our Platform after Privacy Policy changes go into effect, you agree to be bound by the revised Privacy Policy.

If you have questions or concerns regarding this Privacy Policy or SkillsReNEW’s handling of your personal information, or if you would like to exercise your rights described in this Privacy Policy, please contact us at:

Ulavi Technologies Pte. Ltd.
72 Hougang Avenue 7, #09-10
Singapore, 538805
Email: privacy@ulavitech.com