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Category
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Description
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Source
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Marketing data
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Your email address, telephone number, postal address and other contact data collected from you for marketing purposes, along with data relating to the marketing communications that we send to you.
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You, although metadata regarding marketing communications will be generated by our digital marketing software systems
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Account and profile data
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The Skillbox account and profile data may include your account identifier, name, email address, country of residence, nationality, birthplace, date of birth, business name, business details, account creation and modification dates, website settings, contract acceptance information, consent information and marketing preferences.
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You, although some of this data – such as account creation and modification dates – will be generated by our website
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Marketplace service data
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Personal data that are incorporated into buyer job postings and seller skills package listings, insurance policy documents, qualification and certification documents, chat communications and other communications between users, and materials delivered by buyers to sellers or by sellers to buyers.
This category also includes personal data included in invoices, statements and other records of transactions entered into by buyers and sellers through our marketplace, such as party identities, transaction dates, transaction subject matter, transaction amounts and transaction taxes.
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You, relevant other Skillbox user(s), and/or our payment services provider, MangoPay SA
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Payments data
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Information in invoices and statements that we produce, and other information relating to payments that you make or are due to make to us, including payments of commission due to us with respect to marketplace transactions, fees for bolt-on services, payment processing fees, and KYC / KYB fees; this information may include your name, your contact details, transaction dates, transaction subject matter, transaction amounts and transaction taxes.
Note that full credit and debit card details will be handled exclusively by our payment services provider, MangoPay SA; we do not collect or store full card details.
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You and/or our payment services provider, MangoPay SA
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General communications data
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Information contained in or relating to any service messages that we send to you, and any other communications that you send to us or that we send to you; the information may include the communication content and metadata associated with the communication.
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You, although our website will generate the metadata associated with communications made using the website contact forms
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Analytics data
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Data about your use of our website and services; this may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
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Our analytics tracking systems: see below for more details
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Purpose
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Data categories and details of processing
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Legal basis of processing
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Operations
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Your personal data: operating our website, the management of user accounts (including viewing user account information and editing user data from the user's perspective through an "impersonate user" function), the carrying out of KYC and KYB checks on sellers, the facilitation of communications, transactions and service delivery between users of our marketplace, the processing of payments for sellers, the processing of payments by buyers and sellers to us, generating invoices, bills and other payment-related documentation, credit control, and the provision of our services generally.
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Our legitimate interests, namely the proper administration of our website, marketplace, other services and business generally
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Publications
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Your account and profile data and marketplace service data: publishing such data on our website and elsewhere in order to provide our services, in accordance with the instructions you give to us and/or the licences you grant to us.
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Our legitimate interests, namely the publication of content in the ordinary course of our operations
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Relationships and communications
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Your account and profile data and general communications data: managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling.
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Our legitimate interests, namely communications with our website visitors, buyers and sellers and the proper administration of our website, marketplace, other services and business generally
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Personalisation
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Your account and profile data, marketplace service data and analytics data: personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you; where appropriate, highlighting your activity on the website to other users, including in "top seller" listings and when highlighting relevant seller profiles to buyers.
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Our legitimate interests, namely offering the best possible experience for our website visitors and service users
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Direct marketing
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Your marketing data and account and profile data: creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes.
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In some cases, we will ask for your express consent to this processing, in which case the legal basis of the processing will, of course, be consent; in all other cases, the legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and marketplace service users
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Research and analysis
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Your marketplace service data and analytics data: researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business; creating aggregated data sets (that may not incorporate personal data).
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Our legitimate interests, namely monitoring, supporting, improving and securing our website, marketplace, other services and business generally
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Record keeping
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Your personal data: creating and maintaining our databases, back-up copies of our databases and our business records generally, and restoring data from back-up copies.
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Our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy
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Security
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Your personal data: security and the prevention of fraud and other criminal activity.
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Our legitimate interests, namely the protection of our website, services and business, and the protection of others
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Insurance and risk management
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Your personal data: obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice.
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Our legitimate interests, namely the proper protection of our business against risks
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Legal claims
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Your personal data: the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
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Our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others
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Legal compliance and vital interests
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Your personal data: compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
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Legal compliance / vital interests
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Category
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Retention period
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Marketing data
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Between 6 and 18 months following the later of: (a) date of the most recent contact between you and us; and (b) the date of removal of applicable contact information from any suppression list that we maintain from time to time
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Account and profile data
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A minimum period of 6 years following the date of closure of the relevant account, and for a maximum period of 7 years following that date
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Marketplace service data
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A minimum period of 6 years following the date of termination of the relevant contract, and for a maximum period of 7 years following that date
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Payments data
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A minimum period of 6 years and a maximum of 12 years following the date of the relevant transaction, subject to applicable law
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General communications data
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A minimum period of 6 years following the date of the communication in question, and for a maximum period of 7 years following that date
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Analytics data
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36 months following the date of collection
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the right to access - you can ask for copies of your personal data;
the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
the right to erasure - you can ask us to erase your personal data;
the right to restrict processing - you can ask us to restrict the processing of your personal data;
the right to object to processing - you can object to the processing of your personal data;
the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
authentication and status - we use cookies to identify administrative users when they visit our website, to identify you as you navigate our website, and to help us determine if you are logged into our website;
marketplace transactions - we use cookies to enable you to transact with other users via the website and use other website functionality;
personalisation - we use cookies to store information about your preferences and to personalise our website for you;
security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
analysis - we use cookies to help us to analyse the use and performance of our website and services; and
cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
https://help.opera.com/en/latest/security-and-privacy/ (Opera);
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari); and
by post, to the postal address given above;
using our website contact form; or
by email, using the email address published on our website.
Privacy Policy updated: December 2023