Privacy Policy (updated 9.9.2021)

 

Your privacy matters

Skolay's mission is to bring thoughtful people together to have mutually meaningful one-on-one conversations they otherwise cannot have. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used, and with whom it is shared.

This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described below.

Table of Contents

  1. Data We Collect

  2. How We Use Your Data

  3. How We Share Information

  4. Your Choices and Obligations

  5. Other Important Information

Introduction

Our registered users (“Peers”) share their intellectual affinities, engage with others in groups and networks, and exchange knowledge and insights through one-on-one conversation. Content and data on some of our Services is viewable to non-members (“Visitors”).

 

Change

Skolay (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

1. Data We Collect

1.1 Data You Provide To Us

You provide data to create an account with us.

 

Registration

To create an account you need to provide data including your name, email address, and a password. If you register as a Peer, you will need to provide payment (e.g., credit card) and billing information via Stripe, our third-party payment service. Skolay does not retain any of your payment information.

 

You create your Skolay profile (a complete profile helps you get the most from our Services).

 

Profile

You have complete control over the information on your profile, such as your education, interests, experiences, skills, photo, and city or area. You decide whether to make this information public or keep it private.

 

1.2 Service Use

We log usage data when you visit or otherwise use our Services, including our website and app, such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update our app. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.3 Cookies and Other Similar Technologies

Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our services.

1.4 Your Device and Location

When you visit or leave our Services, we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.5 Messages

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a conversation request, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement or Professional Community Policies from our Services.

1.6 Other

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services can be more relevant and useful to you and others.

2.1 Services

Stay Connected

Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other contacts. To do so, you can “connect” with the professionals who you choose, and who also wish to “connect” with you. Subject to your and their settings, when you connect with other Users and Peers, you will be able to search each others’ connections in order to exchange professional opportunities.

We use data about you (such as your profile and profiles you have viewed) to help others find your profile, suggest connections for you and others (e.g. Users who share your interests or background) and enable you to invite others to become a Peer and talk with you.

It is your choice whether to invite someone to our Services, send a request to talk, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your network and basic profile information (e.g., name, profile photo, job title, region). We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding topics you care about, and from individuals you respect. Our Services also allow you to improve your knowledge or learn more. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content and conversations on our Services. We use your content, activity and other data, including your name and photo, to provide notices to your network and others.

 

Career

Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for a job or a specific task) or be hired by you. We will use your data to recommend jobs or mentees, show you and others relevant professional contacts (e.g., who work at a company, in an industry, function or location or have certain skills and connections). You can signal that you are interested in changing jobs and share information with recruiters. We will use your data to recommend jobs to you and you to recruiters.

Productivity

Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to chat with and learn from. Our Services allow you to communicate with other Users and Peers.

2.2 Communications

We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.

We will contact you through email, notices posted on our app, messages to your Skolay inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, conversation suggestions and promotional messages. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

2.3 Marketing

In addition to advertising our Services, we use data and content for invitations and communications promoting membership and network growth.

2.4 Developing Services and Research

Service Development

We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect individuals with each other.

2.5 Customer Support

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

2.6 Insights That Do Not Identify You

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our users and their interests.

2.7 Security and Investigations

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our users, visitors or others.

3. How We Share Information

3.1 Our Services

Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services may be seen by others, consistent with your settings.

 

Profile

If you register as a Peer and opt in to be "public," your profile is fully visible to all users browsing on our app. As detailed in our Help Center, your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

3.2 Others’ Services

You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.

Subject to your settings, other services may look up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your LinkedIn contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.

Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user limited profile data of the person they are meeting or messaging, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

3.3 Service Providers

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.4 Change in Control or Sale

We can share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1 Data Retention

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your profile. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you, you can:

  • Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).

  • Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

  • Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

  • Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

4.3 Account Closure

If you choose to close your Skolay account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Terms and Conditions, enforce our User Agreement, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.

 

Information you have shared with others (e.g., through messages) will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

5. Other Important Information

5.1. Security

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2. Cross-Border Data Transfers

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.

5.3 Lawful Bases for Processing

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Skolay Services you have requested) and “legitimate interests.”

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

5.4. Direct Marketing and Do Not Track Signals

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

5.5. Contact Information

If you have questions or complaints regarding this Policy, please first contact Skolay online. You can also reach us by physical mail.

 

Revisions to the Privacy Policy

We may change this Privacy Policy from time to time. But when we do, we’ll let you know one way or another. Sometimes, we’ll let you know by revising the date at the top of the Privacy Policy that’s available on our website and mobile application. Other times, we may provide you with additional notice (such as adding a statement to our websites’ homepages or providing you with an in-app notification).