Coursby. Learn AI by Doing.

This Privacy policy describes the personal data that is collected or processed when You interact with SKILLSETTER LTD (hereinafter – "We", "Skillsetter"), a legal entity incorporated under the laws of Cyprus, registration number: HE 421968, address: 28 Oktovriou, 367, MEDITERRANEAN COURT, Floor 1, Flat/Office A5, 3107, Limassol, Cyprus, CIF/NIF 10421968R, VAT ID: CY10421968R, in particular through our website https://coursby.com (the "Site"), digital experience, online events, etc. It also explains how Your personal data is used, transferred and protected, what choices You can make regarding Your personal data and how You can contact us.

If you have any questions about the processing of your personal data, would like to leave a comment or have any questions or complaints, or would like to exercise your rights related to your personal data, you can contact us by writing an email to support@coursby.com.

When you visit our Site, we may process certain technical data (e.g. cookies, IP address) in accordance with this Policy. Some cookies are necessary for the functioning of the site and do not require consent. The use of analytical and marketing cookies is carried out only with your consent, which you can provide or withdraw through cookie settings.

We will not use your information or share it with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms of Service available on the Site, unless otherwise defined in this Privacy Policy.

Legal Bases for Processing Personal Data

We process your personal data on the following legal bases:

Performance of a contract or taking steps prior to entering into a contract, where the data subject is a party or beneficiary of such contract.
Legitimate interests – to improve our services, ensure security, and prevent fraud.
Your consent – for marketing communications or other purposes where required by law.
Legal obligation – where processing is necessary to comply with applicable laws.

INFORMATION COLLECTION AND USE

To enhance your experience while visiting the Site and to provide and improve our services, Skillsetter may ask you to provide certain personal information, including but not limited to: your name, phone number, location (residential) address, email address, and other details.

The information we collect will be used for communication, identifying you, and/or delivering the appropriate services to you.

What information We collect

We ask You for certain personal data to provide You with the services You request.

Skillsetter may collect certain personally identifiable information ("PII") voluntarily provided by website visitors during their website usage session(s).

This personal data includes your:

contact details including name, email, telephone number, billing address;
login and account information, including screen name, password and unique user ID;
personal details including gender, date of birth;
payment or credit card information.

When interacting with our website, certain data is automatically collected from Your device or web browser, as further described below in the section titled "Cookies and Pixel Tags." This data includes:

Device IDs, call state, network access, storage information; and
Cookies, IP addresses, referrer headers, data identifying Your web browser and version, web beacons, tags, and interactions with our website.

Is the Provision of Data Mandatory?

Providing essential data is a mandatory condition for using the Website, without which the Website may not function properly or may not function at all.

Providing basic contact information is a necessary condition for accessing our services.

Other types of data (such as marketing preferences) are provided voluntarily, and you may update your preferences at any time.

Disclosure of Personal Data to Third Parties

In the course of its business operations, the Skillsetter uses services provided by third-party vendors, such as Facebook (Meta Platforms, Inc.), Google Ads and Google Analytics (services by Google), as well as other similar providers (such as TikTok, Amplitude, Clerk, Stripe, Lemon Squeezy etc.). This means that some of your personal data may be transferred to these third parties as part of the use of their services.

In particular, the use of advertising and analytics tools from Google and Facebook involves the exchange of information about your activity with Google and Meta.

Please note that these third-party providers may process personal data on servers located outside the European Union (e.g., in the United States), meaning your data may be transferred across borders.

In cases where such international data transfers take place, the Skillsetter ensures the use of appropriate legal safeguards as required by applicable legislation to guarantee an adequate level of data protection and confidentiality. These safeguards may include, in particular, the use of Standard Contractual Clauses (SCCs) or other applicable protective measures.

Our partners who assist in providing services include, in particular:

Payment systems (e.g., Stripe, PayPal) – to process financial transactions.
Analytics services (e.g., Google Analytics, Facebook Pixel, Amplitude) – to improve our services.
Advertising platforms (e.g., Google Ads, Meta Ads) – only with your consent.

Retention Period for Personal Data

Contact details – retained for 3 years after the user's last activity.
Account data – retained until the account is deleted.
Payment data – retained for 5 years, in accordance with tax and accounting laws.
Cookie data – retained for up to 1 year, depending on the type of cookie and unless the user withdraws their consent earlier.

Child Data Processing

We recognize the importance of protecting children's privacy online.

We do not knowingly collect personal data from children under the age of 18 (or the minimum legal age in the user's country) without the verified consent of a parent or legal guardian.

If we become aware that a child has provided us with personal data without parental consent, we will promptly delete such information.

If you are a parent or legal guardian and believe that your child has provided us with personal data without your consent, please contact us using the contact details provided in this Privacy Policy.

The Skillsetter makes reasonable efforts to verify the age of users and the existence of parental or guardian consent for individuals under the age of 18. However, if a minor user intentionally provides false information about their age or otherwise circumvents our age verification mechanisms, the Skillsetter cannot be held liable for such actions. Upon discovery of any processing of a child's personal data without valid parental consent, the Skillsetter will immediately cease such processing and delete the relevant data.

How to Exercise Your Rights

You may exercise any of these rights by contacting us using the contact information provided in this Privacy Policy.

Where We Collect Personal Data

PII is only collected when supplied voluntarily by website users during their website usage session(s). We may ask for PII in the following places: During sign-up and usage of the Site, during checkout, during email newsletter signup, and/or during interactions with our managers. General site usage data is collected using cookies (please see below the section regarding Cookies).

Your Rights Regarding Personal Data

You have the following rights under applicable data protection laws:

Right of access – to obtain confirmation of whether we process your personal data and to access such data.
Right to rectification – to correct inaccurate or outdated personal data.
Right to erasure ("right to be forgotten") – to request deletion of your personal data in certain cases.
Right to restrict processing – to request limited use of your data under specific circumstances.
Right to data portability – to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

every individual who is in the State of California for other than a temporary or transitory purpose and
every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose;

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
For investigations and fraud detection and prevention;
For business transactions provided certain conditions are met.
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
For identifying injured, ill, or deceased persons and communicating with next of kin;
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
If the collection is solely for journalistic, artistic, or literary purposes;
If the information is publicly available and is specified by the regulations.

Why and how do We use Your PII

We use Your personal data in the following ways:

To provide the Services You request

When You use our website, we will use Your personal data to provide the requested services. For example, if You make a purchase on https://coursby.com, we will use the contact information You give us to communicate with You about the purchase. If You contact our support services, we will use information about you, such as Your personal information or payment information, or the service You have purchased to help You resolve a problem or question.

In many cases, to use features within our website You may need to provide Skillsetter with additional data or additional consent to use particular data in a certain way.

To Provide Information About Our Services and for Other Marketing Purposes

If you are already a Skillsetter client (for example, if you have placed an order with us), we may use your contact information to send you marketing communications about similar Skillsetter services, where permitted by applicable law (unless you have opted out of such communications).

In other cases, we will request your explicit consent before sending you marketing information.

We may use the information you provide to personalize messages and advertisements about our services that may be of interest to you. For registered users, this may include data collected during your interactions with the Website, linked to your account across different devices.

You can opt out of receiving marketing communications or analytical tracking at any time by adjusting your preferences in your profile settings or by contacting us using the details provided in this Privacy Policy.

To operate, improve and maintain our business and Services

We use the personal data You provide to us to operate our business. For example, when You make a purchase, we use that information for accounting, audits and other internal functions. We may use personal data about how You use our services to enhance Your user experience and to help us diagnose technical and service problems and administer our website.

To protect our or others' rights, property or safety

We may also use personal data about how You use our website to prevent, detect, or investigate fraud, abuse, illegal use, violations of our Terms of Service, and to comply with court orders, governmental requests or applicable law.

For the Purposes of Research and Analytics

We use data about how our users interact with the Website to better understand user behavior and preferences.

To improve our services, we utilize analytical and advertising tools (such as Google Analytics and Meta Ads). These tools help us analyze traffic patterns and optimize user experience and content delivery.

You may opt out of personalized advertising in your profile settings or by using available advertising opt-out tools.

Other purposes

We may also use Your personal data in other ways and will provide specific notice at the time of collection and obtain Your consent where necessary.

SHARING of Your Personal Data

Skillsetter may share each of the categories of personal data we collect with the following types of entities for the business purposes described:

Service providers processing personal data (including the personal data noted in the "What Information We Collect" section) for business purposes on Skillsetter's behalf, for example to process credit cards and payments, manage and service our data, distribute emails, research and analysis, advertising, analytics, manage brand and service promotions as well as administering certain services and features, including on our website.
Other third parties to the extent necessary to: (i) comply with a government request, a court order or applicable law; (ii) prevent illegal uses of our website or violations of our website's Terms of Service and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).
To any other third party where You have provided Your consent.

We may also transfer personal data about you in the event of a sale or transfer of all or part of our business or assets (including in the case of a reorganization, spin-off, or liquidation).

If we transfer personal data outside the European Union (e.g., to the United States for processing by services such as Google or Meta), we ensure an adequate level of protection through appropriate legal mechanisms in accordance with applicable data protection laws.

Please note that we do not sell your personal data.

PROTECTION and MANAGEMENT of Your Personal Data

Encryption & Security: We use a variety of technical, administrative, and organizational security measures, including encryption tools in certain circumstances, to maintain the safety of Your personal data.

Despite our efforts, no website, mobile application, database or system is completely secure or "hacker proof." You can help keep Your data safe by taking reasonable steps to protect Your personal information against unauthorized disclosure or misuse.

Retention of Your personal data: We retain Your personal data for as long as necessary to fulfil the purposes described in this policy, unless otherwise required or permitted by law.
Managing Your personal data: You may have the right to request: (i) access to Your personal data; (ii) an electronic copy of Your personal data; (iii) correction of Your personal data if it is incomplete or inaccurate; or (iii) deletion or restriction of Your personal data in certain circumstances as provided by applicable law. We do not sell Your personal data. We will not discriminate against You for the exercise of these rights. If You request to delete Your account or personal data, You can create a new account and provide us with Your personal data one more time on our website at any time.

If You have a request regarding Your personal data that cannot be fulfilled from Your account settings, please contact us. Contact details, a link to the webform for these requests can be found in the "Questions, Complaints and Feedback" section below. We will verify Your request either through a message sent to the email address associated with Your account (so You must have access to this email account) or by asking You to provide information matching what we have for You within our systems. You or Your authorized agent may request to exercise Your rights. Before we can act on a request from Your authorized agent, we may require verification of Your identity and proof from the authorized agent that they can act on Your behalf.

Managing Your notifications: If You have an Skillsetter account, You can opt-out of receiving Skillsetter's marketing communications by modifying the preferences in Your account settings. Alternatively, You can opt-out by following the opt out or unsubscribe instructions in the message or by contacting us. Contact details are in the "Questions, Feedback and Metrics" section below.

Please be informed that our Web site is primarily operated and managed on servers located and operated within the United States. In order to provide our products and Services to you, you may be sending your Personal Data outside of the country where you reside or are or even outside the EU. Accordingly, if you reside or are located outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal data. We are committed to protecting the privacy and confidentiality of personal data when it is transferred. If you reside or are located within the EEA, United Kingdom, Switzerland, or other regions that offer similar protections, and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA or other regions to the extent feasible under applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Secure Payment Processing

The Website uses secure verification methods to transmit your payment card data from a secure web page to a secure payment application.

We cooperate with trusted payment providers such as Stripe, PayPal, and others to process transactions. All payments are processed in compliance with the PCI DSS (Payment Card Industry Data Security Standard).

The processing of payment data is based on the performance of a service contract and the fulfillment of legal obligations under the GDPR (e.g., for financial and accounting purposes).

We do not store the full details of your payment card in any of our systems. Your card information is securely transmitted during the checkout process to our payment partners for authorization and confirmation.

After a transaction is processed, the only card-related information we may retain includes:

the card type (e.g., Visa, MasterCard),
the last four digits of the card number,
and the expiration date.

We do not store the full card number or CVV/CSC. This practice helps us protect your financial information and reduce risk.

Communications

By providing Your contact information, You agree to receive certain electronic communications from us. You agree that any notice, agreement, disclosure, or other communication that we send You electronically will satisfy any legal notice requirements, including that such communications be in writing. All calls, emails, and other communications between You and Skillsetter may be recorded.

By providing us with Your email, phone number and other personal data or subscribing via our subscription form on our website, You give Your consent that we may send You marketing offers, advertisement and other messages and notifications regarding our services.

COOKIES and Pixel Tags

Skillsetter collects information, which may include personal data, when You use our website. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include Your (i) IP-address; (ii) unique cookie identifier, cookie information and information on whether Your device has software to access certain features; (iii) unique device identifier and device type; (iv) domain, browser type and language, (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about Your interaction with our website such as click behavior, purchases and indicated preferences; and (ix) access times and referring URLs.

A cookie is a small amount of information that's downloaded to Your computer or device when You visit our website. We use several different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make Your browsing experience better by allowing the website to remember Your actions and preferences (such as login and region selection). This means You don't have to re-enter this information each time You return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance, whether it's their first time visiting or if they are a frequent visitor.

We use cookies and pixel tags to track usage of the website and to understand our customers' preferences. This enables us to provide services to our customers and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about website traffic and website interaction, to identify trends and obtain statistics so that we can improve our website. There are generally three categories of cookies used on our website:

Functional: These cookies are required for basic website functionality and are therefore always enabled. These include cookies that allow You to be remembered as You explore our website within a single session or, if You request, from session to session. They help make, for example, checkout process possible as well as assist in security issues and conforming to regulations.
Performance: These cookies allow us to improve our website's functionality by tracking usage. In some cases, these cookies improve the speed with which we can process Your request and allow us to remember website preferences You have selected. Refusing these cookies may result in poorly-tailored recommendations and slow website performance.
Social media and Advertising: Social media cookies offer the possibility to connect You to Your social networks and share content from our website through social media. Advertising cookies collect information to help better tailor advertising to Your interests. In some cases, these cookies involve the processing of Your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to You or You not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing You to share content on social media.

Your browser can help You manage cookies. You can choose to have Your computer warn You each time a cookie is being sent, or You can choose to turn off all cookies. You do this through Your browser settings on each browser and device that You use. Each browser is a little different, so look at Your browser Help menu to learn the correct way to modify Your cookies. If You turn cookies off, You may not have access to many features that make our website more efficient and some of our services will not function properly.

Facebook Ads conversion tracking (Facebook pixel)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Facebook advertising network with actions performed on this application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and Audience Network. Personal Data collected: Cookies, Usage Data.

Google Ads conversion tracking (Google Inc.)

Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location this application is accessed from, that connects data from the Google Ads advertising network with actions performed on this application. Personal Data collected: Cookies, Usage Data.

Display Advertising extension for Google Analytics (Google Inc.)

Google Analytics on this application might use Google's Interest-based advertising, 3rd-party audience data, and information from the DoubleClick Cookie to extend analytics with demographics, interests, and ads interaction data. Personal Data collected: Cookies, Usage Data.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. Google Inc. utilizes the Data collected to track and examine the use of this application, to prepare reports on its activities, and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies, Usage Data.

Receiving information from Skillsetter

Email

When You place an order on our website, we may send You an email receipt confirming Your order. Similarly, when You create an account on our website, we will send You an email confirming account creation. You will receive these emails, otherwise known as transactional emails, regardless of whether or not You choose to sign up for our email subscription. Please note that Your receipt of our transactional emails does not automatically enroll You in our email subscription program.

We periodically send emails to our email subscribers to help keep You informed of our new services, features, and/or special promotions. We only send emails to visitors who sign up during checkout or who subscribe to our email subscription on our website. In every email that we distribute, we include instructions on how to unsubscribe from our email subscriber list.

You may opt out of these or future emails at any time by clicking the "unsubscribe" link in the footer of such emails.

Right to Object to the Processing of Personal Data

You have the right to object to the processing of your personal data if such processing is not strictly necessary for the provision of our services or for your use of the Website.

In particular, you may:

opt out of receiving marketing communications (emails, SMS, advertisements),
opt out of the use of your data for analytics or personalized advertising, where such processing is not essential.

Once you exercise your right to object, we will cease processing the relevant data, unless we have other lawful grounds for continuing such processing (e.g., contractual or legal obligations).

You may exercise this right by contacting us via the email address provided at the beginning of this Privacy Policy, or by following the instructions outlined in the section "Receiving Information from Skillsetter" of this Policy.

Automated Decision-Making

The Skillsetter does not make any decisions based solely on automated processing of personal data (including profiling) that would produce legal effects concerning users or similarly significantly affect them.

CHANGES to our Privacy Policy

By using our website, You consent to the collection and use of this information by Skillsetter.

It also should be noted that applicable law and our practices change over time. If we decide to update our Privacy policy, we will post the changes on our website. If we materially change the way in which we process Your personal data, we will provide You with prior notice, or where legally required, request Your consent prior to implementing such changes. We strongly encourage You to read our Privacy policy and keep yourself informed of our practices.

Inquiries, Complaints, and Feedback

You have the right to contact us with requests to exercise your rights under the GDPR (such as access, rectification, erasure, restriction of processing, objection, etc.). The Skillsetter will review and respond to such requests without undue delay and no later than 30 days from the date of receipt of the request, following successful verification of your identity.

If necessary, due to the complexity or number of requests, this period may be extended by up to an additional 60 days. You will be informed of any such extension and the reasons for the delay.

Identity Verification

To protect your privacy and ensure that personal data is disclosed only to the rightful data subject, we must verify your identity before fulfilling your request.

If the Skillsetter has reasonable doubts regarding the identity of the person making the request, we may request additional information necessary to confirm the requester's identity. For example:

we may only send responses to the email address associated with your account, or
we may ask you to provide data that already exists in our systems to verify a match.

The 30-day period for response begins only after successful identity verification.

Our responses to such requests are provided free of charge, unless a request is manifestly unfounded or excessive.

If You wish to provide feedback or if You have questions or concerns, or wish to exercise Your rights related to Your personal data, please send us an email at support@coursby.com.

You may also contact us at: 28 Oktovriou, 367, MEDITERRANEAN COURT, Floor 1, Flat/Office A5, 3107, Limassol, Cyprus.

If You contact us with a privacy complaint it will be assessed with the aim of resolving the issue in a timely and effective manner.