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Entity: Re-skill, Inc., a Delaware corporation.
Re-skill, Inc. ("Re-skill", "we", "us" or "our") explains here how we collect, use, share and protect personal data when you use our website, services and platform (together, the "Services").
We work to the DIFC Data Protection Law No. 5 of 2020, the EU General Data Protection Regulation, and the UK GDPR.
Two roles, and the difference matters. For our own website and for the accounts we hold, we are the controller. For the documents and learner data a customer puts into the platform, the customer is the controller and we are the processor, acting on their instructions under a data processing agreement. This policy covers what we do as controller. Customers processing personal data through the platform should read their DPA, which governs that relationship.
1. What we collect
Identity and contact data. Name, email address, phone number, employer.
Account data. Sign-in credentials, preferences, settings.
Usage data. Pages visited, interaction logs, IP address, device and browser information.
Learning data. Quiz scores, completion records, progress through material.
Content you provide. Documents, URLs and other source material you upload for course generation, and the courses generated from them.
Support data. Your correspondence with our team, and feedback you send us.
Marketing data. Your communication preferences and how you respond to what we send.
2. Why we process it
To provide, operate and improve the Services. To personalise what you see. To answer enquiries and support requests. To send administrative and legal notices. To understand how the Services are used and how they perform. To meet legal obligations.
We do not sell personal data, and we do not use it for advertising.
3. Legal bases
Basis | Example |
|---|---|
Performance of a contract | Delivering the Services you signed up for |
Legal obligation | Tax, accounting and regulatory reporting |
Legitimate interests | Securing accounts, improving the platform, understanding usage |
Consent | Marketing email, and analytics cookies on our website |
Where we rely on legitimate interests we have considered whether our interest is overridden by your rights, and you can object at any time using the contact details below.
4. Who we share it with
Service providers. We use third parties to host, process and deliver the Services. Each is bound by contract to confidentiality and data protection terms, and may use the data only to provide services to us.
The categories we use, and where data sits, are described at re-skill.io/legal/subprocessors. The complete list of named subprocessors is Exhibit C of our Data Processing Agreement, available on request.
Corporate affiliates, where they support delivery of the Services.
Authorities and regulators, where we are legally required to disclose.
Acquirers, if we are ever party to a merger, acquisition or sale of assets. We would notify you and any successor would be bound by this policy or one no less protective.
5. International transfers
We are a Delaware company and some of our providers are in the United States, which is not an adequate jurisdiction under DIFC law. Primary customer data storage is in the European Union (AWS, Frankfurt); some AI processing, observability and delivery providers operate in the United States.
Where data leaves your jurisdiction we rely on Standard Contractual Clauses and our providers' data processing terms.
6. How long we keep it
Account data for as long as your account is active, and for a limited period afterwards to meet legal and accounting obligations.
Customer content according to your agreement with us. On termination, Starter accounts can retrieve data for 30 days; other plans follow their agreement.
Website analytics on our provider's standard retention.
Correspondence for as long as needed to handle the matter and to keep a record of it.
We delete or anonymise data when the purpose it was collected for has ended and no legal obligation requires us to keep it.
7. Your rights
Subject to local law, including DIFC and GDPR, you may:
Access the personal data we hold about you
Correct it if it is wrong
Ask us to delete it
Restrict or object to how we process it
Receive it in a portable format
Withdraw consent, without affecting processing already carried out
Complain to the DIFC Commissioner of Data Protection or your local supervisory authority
Contact info@re-skill.io to exercise any of these. We respond within one month, and will tell you if we need longer. We do not charge for this.
If your data is in the platform because your employer put it there, they are the controller and we will refer your request to them.
8. Cookies
Analytics cookies on this website are off until you accept them. A banner asks on your first visit, and you can change your answer at any time through Cookie settings in the footer.
We use no advertising or marketing cookies. Full detail is in our Cookie policy.
9. Security
We encrypt data in transit and at rest, control and authenticate access, and monitor and log platform activity. We keep the number of people who can reach customer data to those who need it.
No system is perfectly secure. If a breach affects your personal data we will notify you and the relevant authority as the law requires, without undue delay.
10. Children
The Services are for organisations and their workforce. They are not directed at children and we do not knowingly collect data from anyone under 16. If you believe we have, contact us and we will delete it.
11. Contact
Data protection contact: info@re-skill.io, or through our contact page.
Re-skill, Inc., a Delaware corporation.
12. Changes
We may update this policy. Material changes will be communicated on this website, and by email where we hold your address. The date at the top always reflects the current version.