While we have not made any material changes to the way we process data about our users, we have updated this policy to make it shorter and easier to read, and to comply with the EU General Data Protection Regulation coming into force on March 06, 2019.
Table of Contents
1. What Data We Get
We collect certain data from you directly, like information you enter yourself, data about your participation in courses, and data from third-party platforms you connect with GrowSkills. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.
1.1 Data You Provide to Us
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect. When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:
In order to use certain features (like enrolling in a course), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, gender, and date of birth, and assign you a unique identifying number (“Account Data”).
You can also choose to provide profile information like a photo, headline, website link, social media profiles, or other data. Your Profile Data will be publicly viewable by others.
Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a course page, asking or answering questions, sending messages to students or instructors, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.
When you enroll in and take courses, we collect certain data including which courses, assignments and quizzes you’ve started and completed; your exchanges with instructors, teaching assistants, and other students; and essays, answers to questions, and other items submitted to satisfy course requirements.
Student Payment Data
If you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code. For security, GrowSkills does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
Instructor Payment Data
Data About Your Accounts on Other Services
We may obtain certain information through your social media or other online accounts if they are connected to your GrowSkills account. If you login to GrowSkills via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday, and list of friends or contacts.
Sweepstakes, Promotions, and Surveys
Communications and Support
The data listed above is stored by us and associated with your account.
1.2 Data We Collect through Automated Means
When you access the Services (including browsing courses), we collect certain data by automated means, including:
Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).
Usage statistics about your interactions with the Services, including courses accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Services (“Usage Data”).
Approximate Geographic Data
An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.
The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.
2. How We Get Data About You
We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
2.1 Cookies and Data Collection Tools
GrowSkills uses the following types of cookies:
We use third-party browser and mobile analytics services like Google Analytics, Hotjar, and Intercom on the Services. These services use Data Collection Tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application was downloaded from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.
2.3 Online Advertising
We use third-party advertising services like Taboola, Facebook, Google’s ad services, and other ad networks and ad servers to deliver advertising about our Services on other websites and applications you use. The ads may be based on things we know about you, like your Usage Data and System Data (as detailed in Section 1), and things that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services, and may be tailored to your interests.
3. What We Use Your Data For
We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity.
We use the data we collect through your use of the Services to:
4. Who We Share Your Data With
We share certain data about you with instructors, other students, companies performing services for us, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.
GrowSkills takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and GrowSkills, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact firstname.lastname@example.org with any concerns.
6. Your Rights
You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.
6.1 Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.
If you have any questions about your data, our use of it, or your rights, contact us at email@example.com.
6.2 Accessing, Updating, and Deleting Your Personal Data
You can access and update your personal data that GrowSkills collects and maintains as follows:
6.3 Our Policy Concerning Children
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children under 13 (or under 16 in the European Economic Area) should not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.
7. Jurisdiction-Specific Rules
If you live in Nigeria, you have certain rights to request information. Users outside of the Nigeria should note that we transfer data to the NG and other areas outside of the European Economic Area.
7.1 Users in California
If you are a Nigerian resident, you have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to firstname.lastname@example.org with the phrase “Nigeria Show the Light” and include your mailing address, state of residence, and email address.
7.2 Users Outside of the Nigeria
GrowSkills, Inc. is headquartered in California, and in order to provide the Services to you we must transfer your data to the United States and process it there. By visiting or using our Services, you consent to storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.
8. Updates & Contact Info
When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email or postal mail with any questions, concerns, or disputes.
What are cookies?
Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your activities across websites, including on GrowSkills. Cookies also allow us to remember things about your visits to GrowSkills, like your preferred language, and to make the site easier to use.
Authentication and security
For example, cookies help authenticate your access to GrowSkills and prevent unauthorized parties from accessing your accounts.
For example, cookies help us remember your preferred language or the country you’re in, so we can provide content in your preferred language without asking each time you visit.
Analytics and research
For example, cookies help us test different versions of GrowSkills to see which features or content users prefer, web beacons help us determine which email messages are opened, and cookies help us see how you interact with GrowSkills, like the links you click on.
For example, cookies help us show a personalized list of recommended courses on the homepage.
To provide you with more relevant advertising
To learn more about targeting and advertising cookies and how you can opt out, visit www.allaboutcookies.org/manage-cookies/index.html, or if you’re located in the European Union, visit the Your Online Choices site.
What are my privacy options?
Updates & Contact Info