LAST UPDATE: JULY 5, 2015

We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy discloses the privacy practices and policies of SkillSmart, Inc. (“SkillSmart”, “we”, “us” or “our”) for skillsmart.wpengine.com and all related sub-domains, tools, and services or through downloadable mobile or other applications that SkillSmart makes available to You (“Website”), including without limitation SkillSmart’s platform (the “SkillSmart Platform”) for enabling individuals to assess their qualifications for various employment opportunities, identifying training which can improve individuals’ qualifications for opportunities, and enabling employers to seek qualified candidates (collectively, the SkillSmart Platform and such related services, the “Services”).

More specifically, the SkillSmart Platform is an exchange for enabling communication among Candidates, Educators and Employers. It is an online platform that enables individuals (each, a “Candidate”) to assess their qualifications for various employment opportunities, and that enables employers (each, an “Employer”) to seek qualified Candidates. Candidates and representatives of Employers together are collectively referred to as “Users” and each individually as a “User.” The platform also enables Candidates to identify training provided by third-party educators (each, an “Educator”) which could improve Candidates’ qualifications for job opportunities (each, an “Opportunity”).

This Privacy Policy covers information that we collect through the Website and our Services, as well as information that we collect about you when our Services are used, whether you are a Candidate, Educator, Employer or simply a visitor to our Website.   This policy does not apply to the practices of companies other than SkillSmart, including Educators and Employers, or to individuals that SkillSmart does not employ, including Candidates. SkillSmart is not responsible for how Educators, Employers or other Users collect or use information when you interact with them directly. You should always review, and if necessary adjust, your privacy settings on any applicable third-party websites and services that you connect to in connection with our Services. We may combine the information you submit under your account with information from other services or third parties. For certain of our Services, we may give you the opportunity to opt out of combining such information. Your access and use of the Services is subject to this Privacy Policy and to our separate Terms of Service. Capitalized terms used but not defined in this Privacy Policy have the meaning assigned to them in the Terms of Service.

Notice of Information We Collect And How We Use It

Our primary purpose in collecting Personal Information (as defined below) is to provide you with a safe, smooth, efficient, and customized experience using our Services and to enable Employers and Educators to interact with you in connection with potential Opportunities and Training. This allows us to provide services and features that most likely meet your needs, and to customize our Services to make your experience easier and more productive. “Personal Information” means information that specifically identifies an individual (such as a name, e-mail address, etc.) or other information about that individual that is directly linked to Personal Information. Personal Information does not include “de-identified” or “aggregate” information, which is data we collect about the use of our Services that SkillSmart does not use to identify such individual. We collect and store information, including Personal Information, which you provide to us when registering or when using the Services. Some such information is required in order for you to register as a user of our Services. You can choose not to provide us with certain information, but by doing so, you may not be able to take advantage of many of our features and functionality. We use Personal Information to deliver the Services to you, to improve the delivery of our Services, which may include advertising, and to develop analytics and to enable us and our partners to improve our Services and correspond with you.

We also collect and store non-personally identifiable information that is automatically generated when you use the Services. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community.

In general, our collection and use of information is as follows:

SkillSmart collects Personal Information you knowingly choose to submit to us during registration, such as your name, email address, information about yourself (such as age, race, gender, and veteran status), and any information you provide to us to validate your skills (such as work history, education history, extracurricular activities, references, etc.) which we use for the following general purposes: identification and authentication of a User; provision of User Information to other Users of the Service (as discussed below); contacting you; making improvements to the Services; research; and generation and reporting of aggregated, anonymous data.

SkillSmart may automatically receive and record information on our server logs or from your browser, including your IP address, cookies, and the pages you request. IP addresses are automatically reported by your browser each time you view a web page. Your IP address may be stored by SkillSmart when you register with SkillSmart. IP addresses may be used for various research purposes, and/or delivering unique functionality to our Services. A variety of non-personal information may be collected through online tracking mechanisms and used for targeted online advertising, as explained below.

Cookies

By using our Website or other Services, you indicate your consent for SkillSmart and our affiliates to send cookies to your computer in order to uniquely identify your browser and improve the quality of our services; you may turn off cookies in your browser though, in doing so, some of our Services may not work.   A “cookie” is a piece of alphanumeric data stored on a visitor’s hard drive that enables us to improve your access to our Website and identify repeat visitors to our Services. We use the non-personally identifiable information obtained from cookies, such as your browser version, IP address, referring domains, pages visited, your mobile carrier, device and application IDs, the nature of your use of the Website and cookie information, to improve our Website delivery, including advertising, and to develop analytics and aggregated data that allow us and our partners to utilize our Service and reach out to you via our Services or otherwise. If you wish to restrict or block the cookies which are set by SkillSmart, or by any other website, you can do this through your browser settings. The Help function within your browser should tell you how to do so. For information on how to delete cookies on the browser of your mobile phone as applicable you will need to refer to your handset manual.

Log Files

Like many websites, we may automatically gather certain information about our Website traffic and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track users’ movements around the Website and to gather demographic information about our user base.

We may link this automatically collected data to Personal Information. IP addresses may be tied to Personal Information to troubleshoot access issues and ban users by IP address from certain communities upon appropriate request.

We may use a third-party tracking service that uses log files and cookies, see “Notice of Information We Collect and How We Collect It” above, to track non- Personal Information about visitors to the Website in the aggregate. This service captures usage and volume statistics as well as geographical location data to compile usage reports and maps for optimization and troubleshooting purposes.

Clear Gifs (Web Beacons/Web Bugs)

We may employ, and our third party advertising partners may employ, a software technology called clear gifs, also referred to as web beacons or web bugs, that help manage content on the Website by tracking what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may use clear gifs in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see “Choice and Opt-out.”

Online behavioral and interest-based advertising

In the future, the Website may enable third parties to use the tracking mechanisms described above to collect your non-personal information for use in online behavioral advertising. For example, third parties may use the fact that you visited the Website to target online ads for SkillSmart services to you on non-SkillSmart websites. In addition, our third-party advertising networks might use information about your use of the Website to help target non-SkillSmart advertisements based on your online behavior in general. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

Any use of online tracking mechanisms by third parties would be subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here.

Information We Collect To Respond To Your Choices and Requests

Registration

In order to use many of our Services, you must first complete the registration form and provide an email address and password (“Login Credentials”). During registration, you are required to complete the registration form and create a user name and password and are required to give truthful contact information (such as name and email address) and other User Information in accordance with our Terms of Service.

We may combine the information you submit under your account with information from other services or third parties in order to provide you with a better experience and to improve the quality of our Services. For certain services, we may give you the opportunity to opt out of combining such information. Further, we will display your User Information in our Services and may compute and display a Score based on the User Information you provide.

Interactions with Other Websites and Services

We may permit you to log in to our Services using sign-in services such as Facebook Connect, or other similar services. These services will authenticate your identity and provide you the option to share certain personal information with us (such as your name and email address) to pre-populate our sign-up form. Services like Facebook Connect also give you the option to post information about your activities on the Services to your profile page to share with others within your social network.

If you log in with Facebook Connect or another similar third-party service, we may use the information we receive from such third party to populate your SkillSmart Platform profile.

Profiles

Upon registering on our Website, a user profile may automatically be created for you.

Billing Account

If you purchase or subscribe to a fee-based Service or other products or services from us, we request certain Personal Information from you. We may require you to provide contact information (such as name, email, and shipping address) and financial information (such as account number, expiration date if paying through a third party payment processing service). We may use an outside payment processing company to bill or process payments for goods or services.

We use this information for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.

Surveys or Contests

We may provide you the opportunity to participate in contests or surveys on our Services. If you participate, we will request certain Personal Information from you. The requested information typically includes contact information (such as name and mailing address) and demographic information.

We use this information to notify contest winners and award prizes, to monitor site traffic, or to personalize our Services (in the case of anonymous information collected in surveys).

We may cooperate with third parties to offer you surveys, contests, products and services through our Services. When you participate in such surveys or contests, or purchase related products and services, you authorize us to share information about you, including Personal Information, with such third parties. If you have any questions or concerns regarding how such third parties use your information, please consult the applicable third party’s privacy policy. You agree that we will not be responsible or liable for any loss or damage incurred in connection with our cooperation with such third parties, their activities on our Services, and the sharing of your information with such third parties.

Communication from Us or Our Services

When you send email or other communications to SkillSmart, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. When you send and receive messages we may collect and maintain information associated with those messages. We may also occasionally send you information on products, services, special deals, and promotions offered by us or one of our partners. You can sign up for these emails from us on our registration page.

Service-Related Announcements

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Service is temporarily suspended for maintenance, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Customer Service

Based upon the Personal Information you provide us, we will send you a welcoming email to verify your username and password. We will communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes. You may contact customer service at support@skillsmart.us.

User Profile

We may store information that we collect through cookies, log files, clear gifs, to create a “profile” of your preferences. We may use this profile in order to improve the content of the Services for you, and may provide promotions and marketing offers to you in accordance with these preferences.

For more information about our third-party advertisers, or to learn more about the choices available to you regarding this profile information, please contact privacy@skillsmart.us.

We do not share your profile with other third parties other than as set forth in this Privacy Policy or in our Terms of Service.

Conditions Under Which We Share Information

We may share Candidates’ User Information with Employers and Educators, where such Candidate provides User Information regarding their qualifications and experience. Further, we may share de-identified, aggregated information about our user base with our other partners. This de-identified, aggregated information does not identify individual users. We may use and publicize aggregate information in any manner that does not identify you, without your consent.

Except as described in this Privacy Policy and the Terms of Service, we do not sell, trade, or otherwise transfer to outside parties your Personal Information without your consent. However we may share your Personal Information in situations described below:

We may share your user profile information and certain other Personal Information with Educators and Employers to enable your procurement of applicable Training and connection with Employers regarding Opportunities

We may release your Personal Information to authorized agents who are employed by us to perform tasks on our behalf and when we need to share information with them to provide products, services and offers to you.

We may share your information where we believe it is necessary to investigate potential violations of our Terms of Service, to enforce the Terms of Service, to comply with law or to protect ours or others’ rights, property, or safety.

If we or our business are acquired, your non-personal information and your Personal Information would be transferred to the buyer as part of that transaction, provided that the conditions of this Privacy Policy would continue to apply.

We reserve the right to disclose your Personal Information as required by law and when we believe that disclosure is necessary to protect our rights; to comply with a judicial proceeding, court order, or legal process served on us or the Website; or in connection with an actual or proposed corporate transaction or insolvency proceeding involving all or part of the business or asset to which the information pertains.

Choice and Opt-out

If you no longer wish to receive our communications, you may opt-out of receiving them by following the instructions included in each communication or by emailing us at support@skillsmart.us.

Access to or Changing Your Information

If your Personal Information changes, or if you no longer desire our Service, you may correct, update, delete or deactivate it by emailing our customer support at support@skillsmart.us, or by contacting us by postal mail at the contact information listed below.

Please keep in mind that whenever you submit User Information or you voluntarily make your other Personal Information or other private information available for viewing by third parties online – for example on blogs, discussion forums, or social networking websites – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

Third party links

We include links on our Website to certain Educators, Employers and other third party websites. These third party websites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked sites. This Privacy Policy applies only to information collected by the Website and Services. Nonetheless, we seek to protect the integrity of our Services and welcome any feedback about these websites.

Minors

Our Services are not directed to people under 13 years of age. If you become aware that your child has provided us with Personal Information without your consent, please contact us at support@skillsmart.us. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we take steps to remove that information and terminate the applicable account.

Terms of Service

Please also visit our Terms of Service, establishing the use, disclaimers, and limitations of liability governing the use of our Website and Services.

Your Consent

By using the Website or our Services, you consent to our latest Privacy Policy.

Security

SkillSmart uses commercially reasonable physical, electronic, and procedural safeguards to protect your personal information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof, and thus we cannot guarantee the absolute security of your personal or other information.

Changes to our Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make a material change to our Privacy Policy that will retroactively apply to information that we have collected from you, we will notify you at the e-mail address specified in your account (if any) and by means of a notice posted on our Website. We encourage you to periodically review the Privacy Policy posted on our Website for the latest information about our privacy practices. We will treat your continued use of the Services following such notice as your acceptance of the changes. However, to the extent required by law, we will seek your consent prior to applying material changes to this Privacy Policy. If you have questions or concerns regarding our Privacy Policy, please contact us at: support@skillsmart.us.

Contact Us

If you have any questions or suggestions regarding our privacy policy, please contact us at:

SkillSmart, Inc.

P.O. Box 1116

Germantown, MD 20875

support@skillsmart.us

.