Privacy Policy

Last updated 15th Aug 2019

We know your privacy is important to you, and we want you to know it’s important to us too. This Privacy Policy is meant to explain our practices when it comes to your use of our platform, services, and websites. We encourage you to take the time to review it carefully, to understand what information we collect, why we collect it, and what we do with it. Below, we cover the following topics:

Who we are

What information we collect

Why we collect your information and how we use it

EEA users and our “lawful bases” for using their data

Who we share your data with and why

How we protect your information

Where we store your information and international transfers

How long we keep your information

How to access and control your information

Other important information

How to contact us

Cookies and Tracking Notice

 

Who we are

Skill Beyond Boundaries Limited, is a subscription based platform for optimisation of human capital in your enterprise. For our customers, we offer a data sharing platform and means of communication. Where applicable we use APIs and SDKs, enabling our customers use our services.

This Privacy Policy applies to our customers, prospective customers, our customers’ employees and visitors to our company websites, including but not limited to skillbeyondboundaries.com, skillbeyondboundaries.co.uk. If you do not agree with this Privacy Policy, do not access or use our services or interact with any other aspect of our business.

 

What information we collect

We collect your information in the following ways:

Information you provide directly to us. When you subscribe to our newsletters, register for one of our webinars, sign up for our services, request us to contact you, or through other interactions with us, we may ask you for certain personal information, such as name, birthdate, address, e-mail address, telephone number, company name, company number, job title, experience details or payment information, among others. When you request support from us, we may also collect information from you such as contact information, documentation, screenshots, or other information you or we may believe is helpful to delivering our service or solving an issue.

When you speak with our customer service or sales representative on the phone, your calls may be recorded and/or monitored for quality assurance and training purposes. In certain circumstances, we may collect your Tax Compliance number, as applicable in your country, from you for a limited purpose, such as for tax reporting relating to a payment for a customer referral or to facilitate an international money transfer.

Information that you or your employees provide to us for delivering the service that the platform is designed for, this is including but not limited to personal information, such as name, birthdate, address, e-mail address, telephone number, company name, job title, experience details, education qualifications, work breaks, trainings and awards.

Information we collect automatically when you visit our websites. We and our third-party partners, such as our advertising and analytics partners, collect information about your visits to our websites and your interactions with our ads or content, together with information such as your IP address, cookies, and other tracking technologies (e.g., web beacons, device identifiers, and pixels). For more information, please see our “How to access and control your information” & “Cookies and Tracking Notice”, which includes information on how to control or opt out of these cookies and tracking technologies.

Information we get from third parties. Third party sources of information include:

Credit agencies. We may obtain your credit information from third party reporting agencies in order to control our own credit risk in on boarding new customers.

Demographic, lead, and interest data. We may obtain information from your company such as information of your employment status, your job title with your current employer, your business contact information and the authenticity of the company.

Information about our customers’ users. Our customers and other third parties may also provide us with personal information about our customers’ users and others. For example, we may receive personal information and other information from our customers, message senders, and other third parties. This information may include, without limitation, name, and date of birth, address, telephone numbers, business email address, job titles current & past, experience details current & past, education qualifications & certification, other information relevant to your professional profile. This is information collected in connection with the use of services delivered via our platform.

Communications usage information. This includes information about your communications delivered via our platform such as the time and duration of usage, source and destination identifiers, completion status, location, IP address, and amount of usage.

Communications content. To enable you to send and receive communications via our platform, we need to be able to handle the content of the messages, calls, and other communications channels used by you.

 

Why we collect your information and how we use it

How we use the information we collect depends on which of our services you use, how you use them, and specific preferences you may have communicated to us. We list below the specific purposes for which we collect your information.

To deliver our services. We use your information because it is necessary to perform our obligations in delivering our services to our customers. This includes displaying your resources profiles, delivering your communications to the intended end user, processing transactions with you (such as billing), authenticating you when you log into our platform, providing customer support, and operating and maintaining our services. We also need your information to communicate with you about the services, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, administrative messages, and other communications necessary to usage of the services.

To carry out core activities relating to our services. To effectively deliver our services to you, we use your information to engage in important supporting activities such as:

Display of skills and experience of your profiles, including other profile details;

billing and collections, including maintenance of records in the event of a subsequent billing dispute;

preventing fraud, violations of our acceptable use policies, and unlawful activities;

troubleshooting, quality control, and analytics; and

monitoring the performance of our systems and platform.

For research and development. We are constantly looking for ways to improve our services, to make them more reliable, secure, and useful to you and our users generally. We use data regarding our users’ communications on our platform to understand how our services are performing and how they are being used in order to identify areas where we can do better. For instance, we may use message delivery information to gauge the effectiveness of our routing to ensure that your messages are delivered. We and our service providers may use your information to assess the level of interest in, and use of, our services, our communications to our customers, and our other messaging campaigns, both on an individual basis and in the aggregate. We also use information about your use of our websites to understand how our website visitors are using our websites. Among other things, this usage information, along with tracking technologies, enables third-party analytics companies, such as Google Analytics, to generate analytics reports on the usage of our services. To opt out of your usage information being included in our Google Analytics reports, you may follow these instructions.

To market, promote, and drive engagement of our products and services. We use data about you to send promotional communications that may be of specific interest to you. Based on information we collect about you, we may decide whether and how to promote certain of our products or services to you over others. These communications are to drive your engagement and maximize the value of our services to you. To perform the above functions and others described in this Privacy Policy, we may match information collected from you through different means or at different times, including personal data and usage information, and use such information along with information obtained from other sources (including third parties). Subject to your ability to opt out, by providing your contact information to us, you consent to receive e-mail messages, text messages, phone calls, faxes and postal mail, including that of a promotional nature, from SBB. Where local law permits, you consent to receive phone calls from SBB and its affiliates even if your phone number is listed on “do not call” registries. Where local law permits, an auto-diallers and/or artificial or pre-recorded message may be used to make calls to you. You may provide someone else’s contact information as required by the platform, however such information provided by you will not be used for any purpose other than to provide the services of the platform. You are not required to agree to promotional communications in order to purchase goods or services from us. You can control whether you receive these kinds of communications as described below in Opt out of communications.

To comply with legal requirements. Applicable laws or regulations may require our processing of your data, such as laws mandating retention of communications data.

To protect our legitimate business interests and legal rights. Where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

According to your explicit consent. If we wish to use your information for certain purposes which require consent under applicable law, we will first seek out and obtain your consent. This may include, for example, testimonials or case studies that identify you in your individual capacity.

 

Economic Area users and our “lawful bases” for using their data

European data protection law requires organizations like us to provide a lawful basis to collect and use your information.

Our lawful basis to collect and use information from our EEA users include when:

– we need it in order to provide you with the services and to carry out the core activities related to our provision of the services.

-we need to comply with a legal obligation.

– we have a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests.

You give us your consent to do so for a specific purpose.

 

Who we share your information with and why

We may share your information as detailed below:

Third-party service providers that help us to deliver the services and allow us to operate our businesses.

Business operations vendors. We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. We only work with carefully selected vendors, and we require any vendors with whom we share personal data to protect the confidentiality of such information and use it solely for the purposes for which it was shared.

Third party websites. Our services and websites may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

Compliance with law enforcement requests and applicable laws; enforcement of our rights. We may disclose personal data as required by applicable law, regulation, legal process or government request; to protect SBB, our services, our customers or the public from harm or illegal activities; and to enforce our agreements, policies and service terms.

With your explicit consent. We share information about you with third parties when you give us consent to do so. For example, we often display use cases or testimonials of satisfied customers on our public websites and require your consent to identify you in your individual capacity. If you are a business customer, and have requested this, your business name and phone number may be included in public directories.

Sharing with senders and recipients of communications. The name on your account, or a portion thereof, and/or your email address may be displayed to people so that they may contact you.

SBB affiliates; business transactions. We share your information with and among our corporate affiliates in order to operate and improve the services we provide to you; and we may share your information in connection with a sale, merger, liquidation, or reorganization of our business or assets.

Credit control. We conduct credit checks on new customers in order to control the risk of non-payment. In the event of non/or late payment, we may disclose your name, address and other details to credit bureaus and agencies. They may use that information to assess your credit rating and provide that rating to other companies.

 

How we protect your information

SBB has implemented administrative, physical, and technical safeguards to help protect the personal data that we transmit and maintain. However, no system or service can provide a 100% guarantee of security, especially a service that relies upon the public internet. Therefore, you acknowledge the risk that third parties may gain unauthorized access to your information. Keep your account password secret and please let us know immediately if you think your password was compromised. Remember, you are responsible for any activity under your account using your account password or other credentials.

 

Where we store your information and international transfers

Personal information held by SBB is stored on and processed on computers situated in the United Kingdom, the EEA, India, and in other jurisdictions. We and/or our service providers also process data in some other countries for customer care, account management and service provisioning.

If you are an EEA resident, your personal data held by SBB may be transferred to, and stored at, destinations outside the EEA that may not be subject to equivalent data protection laws, including India. When you sign up for service with SBB or inquire about our services, we transfer your information to India and other countries as necessary to perform our agreement with you or to respond to an inquiry you make. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

Accordingly, by using our services, you authorise the transfer of your information to India and to other locations where we and/or our service providers operate, and to its (and their) storage and use as specified in this Privacy Policy and any applicable terms of service or other agreement between you and SBB. In some cases, SBB may seek specific consent for the use or transfer of your information overseas at the time of collection. If you do not consent, we may be unable to provide you with the services you requested. India and other countries where we operate may not have protections for personal information equivalent to those in your home country.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this Privacy Policy.

International transfers within SBB and its corporate affiliates. To facilitate our global operations, we transfer information among our corporate affiliates in countries whose privacy and data protection laws may not be as robust as the laws of the countries where our customers and users are based. We utilise standard contractual clauses approved by the European Commission and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for data transfers from the EEA to India and other countries.

International transfers to third parties. Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of users in the EEA or Switzerland with such third parties, we shall make use of legally-recognized data transfer mechanisms, like the European Commission’s standard contractual clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.

 

How long we store your information

We store your information until it is no longer necessary to provide the services or otherwise relevant for the purposes for which it was collected. This time period may vary depending on the type of information and the services used, as detailed below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from anonymized information retained or used for these purposes.

Customer account information. We store your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services.

Communications usage information. While you’re an active customer, we retain the communications usage information generated by your use of the services until the information is no longer necessary to provide our services, and for a reasonable time thereafter as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services.

Marketing information, cookies and web beacons. If you have elected to receive marketing e-mails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an e-mail from us or visited our websites. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

 

How to access and control your information

Your choices. To request deletion of your SBB account, please contact us. You should know that deletion of your SBB account will result in you permanently losing access to your account and all data to which you previously had access through your account. Please note that certain data associated with that account may nonetheless remain on SBB servers in an aggregated or anonymized form that does not specifically identify you. Similarly, data associated with your account that we are required by law to maintain will also not be deleted. If you are an end user of an application that uses SBB services, you should direct requests for access and/or deletion of your data associated with that application to the relevant application provider in accordance with that application provider’s own privacy policy.

Access to your account information. Consistent with applicable laws and data security requirements, we will reasonably honour written requests from you to access or amend your account information, such as name, address, and billing information. You are responsible for ensuring that the information on file with SBB is current and accurate. You may access and update your information by logging into your account or contacting us as described in this Privacy Policy. Where permitted by law, we may charge a reasonable fee to process requests for access to data and may limit the number of requests per year. Your right to amend your information is subject to our records retention policies.

Opt out of communications. You may opt out of receiving promotional communications from us by using some or all of the following methods: the unsubscribe link within each e-mail, updating your e-mail preferences within your service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional e-mail list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our services. Depending on your type of account with Vonage, you may be able to opt out of some notification messages in your account settings.

Your rights as an EEA resident. If you are from the EEA, you may have broader or additional rights, including:

– to be provided with a copy of your personal data held by us;

– to request the rectification or erasure of your personal data held by us;

– to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);

– to object to the further processing of your personal data, including the right to object to marketing and profiling; and

– to request that your provided personal data be moved to a third party.

Where the processing of your personal data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. If you do not want your personal data used by SBB for any direct marketing purposes, or shared with third parties for their own marketing use, then you may opt out of such use or sharing by contacting us, even if you have previously consented to such use.

You can exercise the rights listed above at any time by contacting us and if you feel that your request or concern has not been satisfactorily resolved, you may approach your local data protection authority. The Information Commissioner is the supervisory authority in the United Kingdom and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

 

Other important information
Information from children. SBB does not sell products or services for purchase by children and we do not knowingly solicit or collect personal data from children or teenagers under the age of eighteen. If you believe that a minor has disclosed personal data to SBB, please contact us.

Changes to this policy. In the event we make changes to this Privacy Policy, we’ll let you know by posting a notice on our website at www.skillbeyondboundaries.com/privacy-policy and, in relation to substantive changes that broaden the types of personal data collected or their usage, we will notify you via e-mail to the e-mail address associated with your account, via our platform or websites, or by some other means.

 

How to contact us

If you are a resident of the EEA or other part of the world, the data controller responsible for your information is Skill Beyond Boundaries Limited, which you can contact as follows:

 

Skill Beyond Boundaries Limited

Attn: Data Protection Officer

322 Addington Road, Croydon, CR2 8LF, UK

E-mail: privacy@skillbeyondboundaries.com