Skilful Privacy policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.

1.2 Our website uses cookies. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

2. What personal information do we collect?

2.1 We may collect, store and use the following kinds of personal information:

(a) information about your computer and about your visits to and use of this website (including [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);

(b) information that you provide to us for the purpose of subscribing to Skilful, website services, email notifications and/or newsletters (including name, email address, company, job role, contact details etc)

(c) information that you provide when completing your profile on our website (including your name, profile pictures, social media details and employment details);

(e) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);

(f) information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);

(h) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and

(i) any other personal information that you choose to send to us.

2.2 Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

3. Using your personal information

3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

3.2 We may use your personal information to:

(a) administer our website and business;

(b) personalise our website for you;

(c) enable your use of the services available on our website;

(d) supply to you services purchased through our website;

(e) send you non-marketing commercial communications;

(f) send you email notifications that you have specifically requested;

(g) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);

(h) send you marketing communications relating to our business (or the businesses of carefully-selected third parties) which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);

(i) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);

(j) deal with enquiries and complaints made by or about you relating to our website;

(k) keep our website secure and prevent fraud; and

(l) verify compliance with the terms and conditions governing the use of our website.

3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

3.4 Your profile settings can be used to limit the publication of your information on our website, and can be adjusted using ‘publicly available’ check box in your profile settings on the website.

3.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

4. Disclosing personal information

4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

4.3 We may disclose your personal information:

(a) to the extent that we are required to do so by law;

(b) in connection with any ongoing or prospective legal proceedings;

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and

(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

(f) to MailChimp (name and email address only) if you subscribe to our newsletter. Their privacy policy can be viewed at http://mailchimp.com/legal/privacy/

(g) to Disqus (public comments only). Their privacy policy can be viewed at: http://help.disqus.com/customer/portal/articles/466259-privacy-policy

(h) to Pure Chat (any information you submit in the chat widget at the bottom of the web page). We use a service called Pure Chat to assist users on our website with any questions they may have. Any information submitted via the Pure Chat widget (located at the bottom of the page) will be processed and stored by Pure Chat. Their privacy policy can be found at https://www.purechat.com/privacy

(i) where your Skilful membership is paid for by your employer, we may from time to time provide progress and usage updates to employer, both on an aggregate and individual basis.

4.4 Except as provided in this policy, we will not provide your personal information to third parties.

5. International data transfers

5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

5.3 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

5.4 You expressly agree to the transfers of personal information described in this Section 6.

6. Retaining personal information

6.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:

(a) to the extent that we are required to do so by law;

(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

7. Security of personal information

7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers located in the EEA.

7.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.4 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

8. Amendments

8.1 We may update this policy from time to time by publishing a new version on our website.

8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3 We may notify you of changes to this policy by email.

9. Your rights

9.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) the payment of a fee (currently fixed at GBP 10); and

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

9.2 We may withhold personal information that you request to the extent permitted by law.

9.3 You may instruct us at any time not to process your personal information for marketing purposes by sending an email to us ()

9.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

10. Third party websites

10.1 Our website includes hyperlinks to, and details of, third party websites.

10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

11. Updating information

11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. Cookies

12.1 Our website uses cookies.

12.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.3 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

12.5 We use both session and persistent cookies on our website.

12.6 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:

There are two types of cookie you may encounter when using this website:

First party cookies: these are our own cookies, controlled by us and used to provide information about usage of our site.

Third party cookies: these are cookies found in other companies’ internet tools which we are using to enhance our site, for example Facebook or Twitter have their own cookies, which are controlled by them.

First party cookies

Name Expiry Description
skilfulcocookie Session Used to authenticate users on our systems.
XSRF-TOKEN 2 hours Used to enhance the security of our website by checking the authenticity of form submissions.
remember_web_* 5 years Used when a user chooses to 'remember me' upon log in.

Third party cookies

Google Analytics

We use Google Analytics to track our website site traffic and improve our services.

Cookie Name Expiration Time Description
_ga 2 years Used to distinguish users.
_gat 10 minutes Used to throttle request rate.
__utma 2 years from set/update Used to distinguish users and sessions.
__utmt 10 minutes Used to throttle request rate.
__utmb 30 mins from set/update Used to determine new sessions/visits.
__utmc End of browser session Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.
__utmz 6 months from set/update Stores the traffic source or campaign that explains how the user reached the site.
__utmv 2 years from set/update Used to store visitor-level custom variable data.

For more information on Google's Privacy policy, visit: http://www.google.com/intl/en_uk/policies/privacy/

For more technical information on Google Analytics cookies, visit: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Disqus

When posting comments to our blog, the comments and all related information is processed and stored by a service called Disqus. Please see their privacy policy for more information.

Name Description
disqus_unique, testCookie Used by the Disqus service to enable commenting on blog posts.

More information: http://help.disqus.com/customer/portal/articles/466259-privacy-policy

12.7 Most browsers allow you to refuse to accept cookies; for example:

(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";

(b) in Firefox (version 44) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and

(c) in Chrome (version 48), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.

12.8 Blocking all cookies will have a negative impact upon the usability of many websites.

12.9 If you block cookies, you will not be able to use all the features on our website.

12.10 You can delete cookies already stored on your computer; for example:

(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);

(b) in Firefox (version 44), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and

(c) in Chrome (version 48), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".

12.11 Deleting cookies will have a negative impact on the usability of many websites.

13. Our details

13.1 This website is owned and operated by Skilful.

13.2 We are registered in England and Wales under registration number 07659654, and our registered office is at Skilful, 3 Park Farm, Black Notley, Essex, CM77 8JX

13.3 You can contact us:

(a) by post, using the postal address Skilful, 3 Park Farm, Black Notley, Essex, CM77 8JX;

(b) using our website contact form at https://skilful.co/contact;

(c) by telephone, on 0203 621 5174; or

(d) by email, using

14. Credit

14.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).

15. Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

16. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

16.1. verify your identity for security purposes
16.2. sell products to you
16.3. provide you with our services
16.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

17. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including [job opportunities and] our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us hello@skilful.co. However, if you do so, you may not be able to use our website or our services further.

18. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

19. Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of Stripe or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.

20. Data may be processed outside the European Union

Our websites are hosted in the UK.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America or in Australia.

We use the following safeguards with respect to data transferred outside the European Union:

20.1. the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
20.2. the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union
20.3. we comply with a code of conduct approved by a supervisory authority in the European Union
20.4. we are certified under an approved certification mechanism as provided for in the GDPR

21. Access to your personal information

21.1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
21.2. To obtain a copy of any information that is not provided on our website you may send us a request at hello@skilful.co.
21.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

22. Removal of your information

If you wish us to remove personally identifiable information from our website, you may contact us at hello@skilful.co
This may limit the service we can provide to you.

23. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

24. Use of site by children

24.1. We do not sell products or provide services for purchase by children, nor do we market to children.
24.2. If you are under 18, you may use our website only with consent from a parent or guardian

25. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

26. How you can complain

26.1. If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is hello@skilful.co
26.2. You can find further information about our complaint handling procedure at https://skilful.co/contact
26.3. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
26.4. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/

27. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

27.1. to provide you with the services you have requested;
27.2. to comply with other law, including for the period demanded by our tax authorities;
27.3. to support a claim or defence in court.

28. Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

29. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.


Updated on 22/05/2018