THE Play2learn is owned by Skillcore, a company that deeply values the privacy of its users. In keeping with this commitment, we have developed this Privacy Policy to explain how we treat the personal information of users on our platform. By using our services, you consent to the collection and use of your personal data as described herein.
THE SKILLCORE values the protection of its users' privacy very much, and that is why we pay great attention to the way we treat our users' personal data. To this end, we have developed this Privacy Policy, which describes how we treat personal information and data on our platform. By using our services, the user understands and declares to be aware that their personal data and information will be collected and used as described in this Privacy Policy.
If the user or his/her organization has entered into a specific/individual contract with the SKILLCORE, said contract may contain specific provisions on privacy that complement, restrict or even expand the rules present in this Privacy Policy. For this reason, it is essential that the user reviews the content of said contract so that he/she is fully aware of the duties and obligations assumed.
This Privacy Policy does not apply to third-party websites, applications, services and products that the user may have access to through the P2L Platform and its services. Therefore, we advise the user to always read the Privacy Policies and Terms of Use of third parties before accepting any offer.
The P2L Platform is a tool equipped with artificial intelligence (“AI”) technology that allows its users to create training and learning journeys by creating immersive and interactive scenarios/games to assist in teaching specific topics, developing users’ skills, analyzing profiles and behaviors, among other applications. SKILLCORE, therefore, provides the services of access to and use of the P2L Platform and licenses the right to use it and the content generated by it and made available to the user exclusively for the purposes described in its respective Terms of Use. In this sense, our services necessarily include user registration and the offering of payment methods for transactions on our platform. For this reason, the provision of some personal data, strictly for the purposes proposed on this platform, will be necessary, in accordance with the rules of this Privacy Policy.
Out of respect for our users, we have adopted the concept of privacy by design as one of the pillars of our business, that is, we collect and process only the personal data that is essential for the service we provide. If there is any type of change in our business model that requires the use of other personal data of our users, we will always inform our users in advance about this so that they can choose to maintain their subscription.
It is important that you read this entire Privacy Policy, but if you have any specific interest, we have prepared a summary below to make it easier for you to navigate through this instrument:
- Definitions
- Data Collection
- Data Processing
- Data Sharing
- Data Storage/Retention
- Owner Limitation/Change Options
- Other Rights of the Holder
- Provision of personal data in P2L Platform inputs
- Children's Data
- Security and Protection Measures
- Privacy Policy Changes
- Trade Secret
- Contact – Privacy Department
- General provisions
1. Definitions
- Database: structured set of data, established in one or more locations, in electronic or physical support;Cookies: files sent by the SKILLCORE server to the computer of the person accessing the P2L Platform, for the purpose of identifying the computer, personalizing access and obtaining browsing data to improve and make the services offered by SKILLCORE more efficient;
- Personal data: information related to an identified or identifiable natural person;
- Personal data consented: personal data that have received explicit consent from their holder for processing and that are not public personal data;
- Public personal data: personal data that are publicly accessible and personal data made public by the data subject and/or third parties authorized to do so and which, therefore, do not require prior consent for processing;
- SKILLCORE: the company SKILLCORE as a whole, including its group of companies, website, mobile applications, and platforms used to provide its services;
- Input: data that the user provides to the P2L Platform tool (e.g.: subject of the training to be carried out; positions of the characters/people involved; etc.) for the creation of gamified training using the tool;
- Output: result generated by the P2L Platform tool in response to inputs provided by platform users;
- P2L Platform: tool provided by SKILLCORE that consists of a platform for creating training and learning journeys through a gamification process and artificial intelligence;
- SKILLCORE Services: the services and licenses, whether paid or free, provided by SKILLCORE through the P2L Platform;
- Holder: natural person to whom the personal data refer;
- Treatment: any operation carried out with personal data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction;
- Users: all those who register on the P2L Platform;
- Paying Users: all those registered on the P2L Platform and/or who have purchased a plan offered by SKILLCORE for use of the P2L Platform;
2. Collection of Personal Data
In order for SKILLCORE services to be provided efficiently and with quality and always aiming at their constant improvement, as well as to support our advertising and marketing activities, we collect personal data and information from our users, the devices they use and their location.
This collection may occur directly and voluntarily, when users fill out forms with their personal data. This collection may also be done automatically by SKILLCORE, especially data/information about electronic devices, internet browsers used and their locations, without a form being filled out for this purpose. Furthermore, SKILLCORE may collect data/information from users through other sources for which the user has authorized the sharing of personal data (e.g.: when the user registers via social media API), or collect public personal data.
Visiting our websites, installing our mobile applications and providing personal data are optional, but to use some of SKILLCORE's services, providing certain personal data is essential, such as purchasing a subscription to the P2L Platform.
2.1 Collection of Personal Data provided by the User
SKILLCORE collects personal data provided by the user, when the user:
- (i) Register or log into your account created on the P2L Platform;
- (ii) Create and/or edit your user profile on the P2L Platform;
- (iii) Carry out a financial transaction through the P2L Platform;
- (iv) Contact our customer service department;
- (v) Provides personal data for inviting new users, for inputs intended for the system and in documents used on the P2L Platform;
- The personal data that may be collected in this way by SKILLCORE are:
- (i) Full Name;
- (ii) CPF;
- (iii) Email;
- (iv) Address;
- (v) Telephone number;
- (vi) Credit/debit card details, PIX key, payment tool account details (e.g. PayPal, PagSeguro), etc. and other billing details depending on the payment tool used;
- (vii) Other personal data provided by the user at his/her sole discretion;
All data collected will be incorporated into the SKILLCORE database, which will be responsible for its storage.
2.2 Automatic Collection of Personal Data
SKILLCORE automatically collects data from you and your device when you use our services and/or access our platform. We collect this information to understand how you use our services and electronic devices, such as computers, smartphones, tablets and others. The data that may be collected in this way by SKILLCORE are:
- (i) IP address;
- (ii) Geolocation of the device;
- (iii) Attributes of the electronic device used by the user, such as operating system, browser type, among others;
- (iv) Usage-related data, such as: web registration data indicating entry and exit pages, the type of platform used, the number of clicks, domain names accessed, landing pages, pages viewed and the order in which they are viewed, the time the user spends on each page, the date and time of use of the services, the frequency of use of the services, error events and other similar information;
2.3 Cookies and Similar Technologies
SKILLCORE may use cookies or similar/related technologies (e.g., tracking pixels, web beacons) to store and collect information.
SKILLCORE also allows third parties to use cookies and similar technologies in connection with our services for the following purposes:
- (i) Analysis: SKILLCORE uses services such as Google Analytics and others, which use cookies to collect usage data for the purpose of understanding and improving the experience of users of our services. In these cases, data such as: pages visited, time spent browsing the pages, means by which the user reached the P2L Platform page, among others;
- (ii) Personalized Advertising: Third parties whose products and/or services are offered through the P2L Platform may use and read cookies to collect information in order to direct personalized advertisements based on information from previous visits to the P2L Platform and evaluate the performance of the advertisements served. Likewise, SKILLCORE also relies on third-party services, such as Google, which may promote personalized advertisements to users on other websites, based on the cookies captured when accessing our services. SKILLCORE, however, has no influence over the technologies used by these third parties, and this Privacy Policy does not apply to them.
2.4. Data collected from Third Parties
SKILLCORE may collect data about its users from other sources, such as:
- (i) Partners, researchers and others who are legally authorized to share your information with SKILLCORE (e.g. if you access our services through a third-party website/mobile application/API, they may provide us with your data);
- (ii) Users: some users may indicate personal data of third parties and other users when performing tasks on our platforms (e.g.: indicating colleagues/collaborators to participate in a certain training);
- (iii) Public data: publicly accessible data and data made manifestly public by the holder may be collected by SKILLCORE without the holder's prior consent, respecting the guiding principles of privacy protection;
3. Data Processing
As noted above, SKILLCORE collects and uses data from its users (only those that are minimally necessary) for a single, clear purpose: to provide an efficient, high-quality service that is constantly improving. In this sense, the following are examples of the purposes for which the collected data is used:
- (i) Provide the P2L Platform services and improve the AI tool used;
- (ii) Provide online payment methods for users of the P2L Platform;
- (iii) Improve the user experience when browsing the P2L Platform and using SKILLCORE services;
- (iv) Send advertisements about products and services that may be of interest to users via email, notification, SMS and other means of communication;
- (v) Choose and present personalized advertisements;
- (vi) Conduct sweepstakes and contests;
- (vii) Prepare statistics without identifying users;
- (viii) Develop new resources, services and products;
- (ix) Fix problems with our services;
- (x) Manage all SKILLCORE platforms and tools;
- (xi) Prevent, investigate and respond to: fraud, unauthorized access and use of our services, violations of our terms, policies and agreements and any other types of malicious and irregular behavior promoted on our platforms, including by inserting the user's personal data (name, email, CPF) in watermarks on the licensed content made available on the platform to prevent its undue exploitation;
- (xii) Establish, defend and/or exercise rights in the administrative and/or judicial sphere;
- (xiii) Comply with the relevant legal obligations applicable to SKILLCORE operations that require the storage of certain data for a certain period of time;
SKILLCORE may also adopt measures to remove and/or anonymize part of the data to avoid identification of the holder, to which this Privacy Policy does not apply.
3.1. Authorizing Hypotheses
SKILLCORE normally processes personal data (i) only when there is clear consent to do so, (ii) when we need the information to perform our functions related to the services contracted and accepted by users, (iii) when there are legal obligations that so require, or (iv) when the processing of such data is done on the basis of our legitimate interest and without this representing a violation of the rights of our users. In certain cases, however, we will have a legal obligation to collect and/or retain personal data to protect the vital interests of our users.
4. Data Sharing
SKILLCORE, in certain situations, may share the collected data. Below are these situations:
- (i) Third Party Suppliers: the personal data to which we have access may be shared with other companies that provide some type of support to SKILLCORE, such as: database technologies, advertising systems, authentication systems, payment systems, fraud detection services, customer support services, shipping services, among others. All our suppliers will be committed to protecting the personal data to which they have access, and may not use it for purposes other than those determined by SKILLCORE and known to the data subjects;
- (ii) Legal obligations: the personal data to which we have access may be shared in order to comply with legal obligations or by court order. SKILLCORE may occasionally share personal data when there is a threat to the physical safety of any person and/or violations of this Privacy Policy or other terms, contracts and policies of SKILLCORE, as well as to protect the rights of third parties, such as our users, employees and other individuals and/or legal entities;
- (iii) Corporate Transactions: we may share data collected during a corporate transaction such as a merger and/or acquisition, when there is a sale and/or evaluation of our assets. Any change in control of SKILLCORE will be notified to our users;
- (iv) Consent: we may share personal data in other ways if the data subject has asked us to do so or has given their express and unambiguous consent;
- (v) Public data: we may share publicly accessible personal data or those made manifestly public by the holder;
- (vi) Employers/Organizations: we may share collected data with employers and/or organization managers when the data subject registers as an employee, representative and/or member of a company and/or organization, using a corporate email (e.g.: nome@nomedaorganização.com.br);
5. Data Storage/Retention
SKILLCORE will store the collected personal data only for the period in which they are necessary for the purposes of their processing, which may vary depending on the processing carried out, or until the request for removal/deletion of data made by the holder, except for any legal requirements for the storage of information, such as, but not limited to, those provided for in Law No. 12,965/2014 (Marco Civil da Internet).
If there are technical limitations that prevent the deletion or anonymization of personal data, SKILLCORE will make every effort to protect such data and limit its access and use.
6. Owner Limitation/Change Options
The data subject who uses the licenses and services offered by SKILLCORE has options to change and limit the collection and use of their data, as per the examples below:
- (i) Profile: the holder does not need to provide data, other than that necessary for the desired services, to complete his/her registration on the P2L Platform. The holder may always review and change the data provided in his/her registration/profile;
- (ii) Advertisements: the holder may always choose not to receive messages and advertisements via email marketing, push notifications, messaging applications and/or SMS, an option that will be offered in the advertisements received;
- (iii) Cookies and similar technologies: the holder may reject the option of collecting cookies and similar technologies through his/her browser. The holder who chooses not to provide such data declares to be aware that he/she will not enjoy part of the benefits contained in our services;
- (iv) Information about devices and browsers: the holder can turn off the location sharing option on their devices, change the privacy settings on their devices and/or refuse to share the location in their browser;
- (v) Account closure: the holder may, whenever he wishes, close his account on the P2L Platform, an option available in the profile settings panel. If the holder has a transaction still pending on the P2L Platform, SKILLCORE may condition the full closure of such account upon the completion of the transaction;
- (vi) Complaints: the holder may make requests/complaints to SKILLCORE whenever he/she believes that any right is being affected, in accordance with the contact details of our privacy department mentioned below;
7. Other Rights of the Holder
In addition to the rights provided for in other topics of this Privacy Policy, data subjects will enjoy the following rights, which will be fully met by SKILLCORE within its operational and technical capabilities and within reasonably expected timeframes:
- (i) The holder may access and review personal data associated with his/her account at any time;
- (ii) The data subject may request the following information, to be provided in reports in electronic and/or printed formats: what are the forms of processing of your personal data, what are the purposes of processing your personal data, what are the categories of your personal data processed, who are the recipients of your personal data processed, how your personal data is received, for how long we use and/or store your personal data;
- (iii) The holder may request the correction of his/her personal data;
- (iv) The holder may request the deletion and/or cessation of use of his/her consented personal data;
- (v) The holder may prevent the export of his/her consented personal data;
- (vi) The data subject may, with regard to the consented personal data, refuse to give such consent or revoke consent already granted, without prejudice to the lawfulness of the processing carried out during the validity of the consent;
- (vii) The holder may request the portability of his/her personal data to send to other service providers, if there is technical compatibility;
- (viii) The data subject may request the review of decisions made by a natural person, when the decisions to be reviewed involved the analysis of personal data and were taken by automated systems and which, in some way, affected the legitimate interests of the data subject;
To exercise these and other rights, any interested party may contact SKILLCORE through its privacy department.
SKILLCORE may delay responding to requests made by users based on the above rights if there is any pending issue by the user that may result in losses to SKILLCORE and/or third parties.
8. Provision of personal data in P2L Platform inputs
Due to the characteristics of the AI tool made available by the P2L Platform, the user will be free to provide the inputs they deem necessary to obtain the desired outputs, which may include any personal data of themselves or third parties.
P2L suggests that the user does not provide personal data, especially of third parties, in the inputs formulated for the P2L Platform. If the user does so, he/she declares and guarantees that he/she has the necessary prerogatives to provide the personal data provided by him/her to the P2L Platform so that they can be processed by SKILLCORE, assuming full responsibility for any violation of this guarantee.
SKILLCORE may, if it deems it pertinent and following its operating guidelines, reject or adopt anonymization and similar techniques for the personal data listed in the inputs provided by its users, which may affect the results of the outputs generated by the P2L Platform.
9. Children's Data
The P2L platform was not developed for children. Therefore, SKILLCORE does not intentionally request or collect data from children, nor does it intentionally allow children to use its platform.
When registering holders, they will confirm that they have full legal capacity to assume commitments.
SKILLCORE will immediately delete any data it has access to that belongs to children. In this same sense, SKILLCORE encourages all its users to report situations that may involve children's data on our platform, forwarding the report to our privacy department, according to the account data below.
10. Security and Protection Measures
To keep our users' information secure, SKILLCORE uses physical tools (e.g. different storage environments), electronic tools (e.g. encryption, firewalls) and administrative tools (e.g. access hierarchy, access control).
The SKILLCORE team is fully aware of this Privacy Policy and only qualified and authorized personnel are allowed to access the personal data processed, under penalty of suffering disciplinary sanctions in the event of violation of the rules set forth herein.
In this same sense, SKILLCORE demands from its suppliers and partners the guarantee of data protection and privacy assured in this Privacy Policy when those who have, in any way, access to personal data processed by SKILLCORE.
However, despite adopting several protection and security mechanisms, the internet and our services are not 100% secure. For this reason, we cannot guarantee that the data we process will always be protected from unauthorized access and use.
SKILLCORE undertakes to, whenever a possible failure and consequent data leak is detected, notify the affected or potentially affected data subjects, explaining the nature of the event that occurred, the possible leaked data and explaining what measures will be taken in light of the reported situation, offering broad support to its users.
11. Amendment of this Privacy Policy
SKILLCORE may change this Privacy Policy to comply with any legal changes, as well as any changes to our organization, our services, our data processing practices and the technologies employed by SKILLCORE.
Any substantial changes to this Privacy Policy, which in any way affect the rights of holders of personal data processed by SKILLCORE, will be notified to holders by email and/or by another form of communication chosen by the holder.
12. SKILLCORE Trade Secret
SKILLCORE uses a series of methods, plans, plans, source codes, algorithms, structures, information and other knowledge developed and acquired throughout the establishment of its business that are true competitive differentiators. A large part of this set of assets, which are not public knowledge, form a business secret of SKILLCORE, which is kept completely confidential in SKILLCORE's operations, being fully known only to key people in the company who have signed secrecy and confidentiality agreements, which provide for severe penalties in the event of improper disclosure.
Therefore, it must be clear to the holders of personal data processed by SKILLCORE that some of their data are processed through tools comprising this trade secret, which must be respected when making any requests for disclosure and/or provision of information. For this reason, sometimes the information requested by the holder cannot be provided in full and/or in the desired format, without prejudice to the rights of the holder of personal data.
12. Contact – Privacy Department
SKILLCORE has a specific department to deal with any and all issues related to Privacy and Personal Data Protection. For questions, complaints or any other contact related to this topic, interested parties can contact our privacy department through the channels below:
14. General Provisions
Brazilian Law applies to any issue arising from this Privacy Policy and any issues related to the protection of personal data.
All those who, in any way, have an interest in demanding from SKILLCORE any rights related to the protection of personal data are subject to the Court of the District of Curitiba/PR.
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