In order to comply with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties, its Regulations and applicable Guidelines (the "Law"), Skills for Industry, S.A.P.I. de C.V., its affiliates and/or subsidiaries, and/or its related parties ("Skills Tech"), located at Kiel No. 2917, Col Narvarte, Monterrey, Nuevo León, (the "Address"), holder of the rights to the software called Skills.Tech (the "Software") and SkillsAI (“Services”) for use through the digital platform at https://www.chat.skills.tech/ (the "Platform") and other present and future digital platforms and web and/or mobile applications owned by it, and with contact email hola@skills.tech (the "Email"), makes available this:
PRIVACY NOTICE
In order to legitimately, controlledly and informedly process your personal data, which you currently provide us or in the future and which is in our databases, or that has been collected by cookies, or any other web tracking technology, as well as to guarantee your privacy and your right to informative self-determination by providing said data to us, with Skills Tech being responsible for the use and protection of your personal data which will be processed based on the principles of lawfulness, consent, information, quality, purpose, loyalty, proportionality and responsibility provided for in the Law.
USE OF INFORMATION
The information that you provide us through accessing, registering and creating a User profile on the Platform, and/or email, and/or filling out physical or electronic forms or surveys, in real time or historical, will be processed and sorted, so that it generates data indicators, which Skills Tech may use to make business decisions relevant to its business. All information collected will be used for statistical purposes, generically and not personalized, and is associated with the growth, maintenance and administration of Skills Tech, while always respecting your privacy. These uses include our internal operations and administration, communication with you and compliance with service requests and/or products provided by Skills Tech, as well as to improve, develop, perfect and provide Skills Tech services, through its related parties, affiliates, or authorized providers and/or business partners, establishing adequate measures in order to limit the use of the information collected from you, solely for legal purposes and authorized in accordance with this Notice, as well as with due confidentiality and security measures. Skills Tech may also collect your IP address (Internet Protocol) to help diagnose problems with the Skills Tech server and administer the Platform. An IP address is a number assigned to your computer when you use the Internet. Your IP address is also used to help identify you within a particular session and to collect general demographic information. Skills Tech may use "push" technology through the application that Skills Tech uses to send notifications with the User's prior authorization. This means of communication has no access to any other functions or information on the device used to connect to the Platform. The information may include the URL from which they come (whether or not on the Platform), which URL they access next (whether or not on the Platform), which browser they are using, as well as the pages visited, searches made, posts, commercial preferences, messages, etc.
USE OF COOKIES
Skills Tech informs you that, through the use of cookies and similar technologies, it seeks to ensure the best possible experience on the Platform, by providing you with personalized information, remembering your service and marketing preferences and helping you obtain adequate information. If you require more information regarding the use of cookies and similar technologies, Skills Tech makes the Cookie Use Policy available to you.
USE OF THIRD PARTY PLATFORMS AS A MEANS OF OBTAINING DATA
Personal Data may be collected by manually integrating the information requested on the Platform or by authorizing the use of data contained in the Typeform, Airtable, Retool, Webflow, and Zendesk Platforms, by having the User registered an email account on said platform. The request for the User's data is made through the link from the Platform to the API (abbreviated as Application Programming Interfaces) integrated into the Typeform, Airtable, Supabase, MongoDB, Retool, Webflow, Wized, and Zendesk Platforms. Likewise, your entry as a user to the Platform's Services may also be subject to initial identity verification through validation of the cell phone number provided for this purpose, by direct SMS message (Short Message Service).
1. PERSONAL DATA REQUESTED
Skills Tech, and/or its controlling companies and/or affiliated companies and/or subsidiaries and/or related parties (the "Related Third Parties") and/or those third parties that, due to their commercial relationship with Skills Tech have contracted the use of the Platform for the use of the Services provided and to complement their business proposal and need to process and/or use your personal data (the "Client"), and/or due to the nature of their work or functions need to process and/or use your personal data, as suppliers or business partners of Skills Tech ("Business Partners"), request and obtain personal data in general, as well as personal data considered sensitive by Law (hereinafter "General Personal Data" and "Sensitive Personal Data", respectively; and jointly referred to as "Personal Data") from the people described below. Sensitive Personal Data may be requested by electronic or physical means, with the understanding that all information provided physically will be considered and treated as if it had been provided and authorized on the Platform, and therefore will be governed by this document. In all cases, the collection of Personal Data by Skills Tech is carried out in good faith and for the purposes set forth herein; For this reason, it is presumed that the data provided by its owners is truthful and complete, so they are the responsibility of the owner who provides them.
CLIENTS, AS USERS OF THE PLATFORM.
The Personal Data that will be collected from Clients using the Platform are necessary to document the commercial and legal relationship that exists or may exist with each of them, and to be able to carry out the purpose of the contracted services. The Personal Data that you voluntarily and freely provide on your own, consist of information that is included or may be included in contracts, letters, forms, listings, databases or other physical and/or electronic media, as applicable, so that Skills Tech can document the relationship between the parties, the process of use and selection that it performs or will perform of the Modules that make up the Services of the Platform; can keep an adequate record of the commercial relationship with its business partners; as well as to fully comply with the internal policies, procedures and other legal obligations applicable to Skills Tech. The Personal Data that will be requested from you are the following:General full name;fixed and/or mobile phone number;email;address;date of birth;education level;
B) BUSINESS PARTNERS OF THE CLIENT, AS USERS OF THE PLATFORM.
The Personal Data that will be collected from the Business Partners through the Platform consists of information that is included or may be included in contracts, letters, forms, listings, databases or other physical and/or electronic media arranged in each of the Modules of the Platform, as applicable, in order to document the process of use and selection that it performs or will perform of the Service Modules that make up the Platform; an adequate record of the commercial relationship with the Business Partners that make use of the Platform can be kept; as well as to fully comply with the internal policies, procedures and other legal obligations applicable to Skills Tech. The Personal Data that is collected for integration as part of the Platform Services for Business Partners are: name of the individual or company name;company address;Federal Taxpayer Registry number (RFC);landline and/or mobile phone number; name and position of the person acting as main contact;corporate telephone and/or mobile number of the person acting as main contact; andcorporate email of the person acting as main contact;bank details for the deposit or electronic transfer of services provided to the Client; andthose specific to process purchase orders to Business Partners or any documents required in the modules provided on the Platform. All Personal Data is processed by Skills Tech and placed in a repository for processing and transfer to the Client, in order to comply with the purpose of the Services acquired by the Client. AS THE PLATFORM IS A DATA PROCESSING TOOL MADE AVAILABLE TO THE CLIENT, WHICH ALLOWS MONITORING AND CENTRALIZING ALL INFORMATION FROM ITS END USERS AND/OR BUSINESS PARTNERS, Skills Tech HAS NO INFLUENCE OVER THE TRANSFER AND PURPOSE OF USE BY THE CLIENT, SO THESE ACTIVITIES ARE GOVERNED BY THE PRIVACY NOTICE THAT EACH CLIENT HAS FOR THIS PURPOSE.
2. PURPOSES FOR PROCESSING PERSONAL DATA
The Personal Data provided to Skills Tech through the Platform will be used as mentioned above, in order to: - perform data processing to create a register of Clients and Modules of the Services they use, manage or administer through the Platform, as a linking tool with Business Partners, - process the service request made through the Platform; - provide the necessary advice and monitoring of contracted Services; - get to know the Client's profile in detail to provide the contracted Services correctly; - for the Client to be able to manage, operate, administer and monitor the business relationship with the Business Partners; - promotion and marketing activities for new products and/or services available on the Platform; and - process bank details to pay purchase orders and/or any business transaction with its Business Partners, through payment engines provided by Clients. Once the purposes of processing your Personal Data have been fulfilled, and when there is no legal provision that establishes otherwise, Skills Tech at its sole discretion and under the authorization of the Data Owner, may make use of the data collected solely for generic and non-personalized statistical purposes associated with the growth, maintenance and administration of Skills Tech, while always respecting the privacy of the owner of the Personal Data.The treatment that the Client as the payment engines provided by Skills Tech and/or the Client, grant to the Personal Data collected, will be subject to the terms and conditions of the Client's Privacy Notice as well as those contained on the website of the third party providing the payment engine services.
3. TRANSFER
TRANSFER OF PERSONAL DATA AND INFORMATION.
The Personal Data referred to in this Privacy Notice may be transferred to: (i) related and/or business partners, in order to enhance the value proposition of Skills Tech, as well as offer you, based on your needs, other products and services; (ii) judicial authorities, Mexican and foreign, in order to comply with the Law, legislation, notifications, requirements or legal notices; (iii) internet service providers on which the Skills Tech technological infrastructure is mounted; and/or (iv) Platform technical support providers. In the event of any transfer of your Personal Data, where your express consent is required, we will inform you in order to obtain it. In all cases, Skills Tech will communicate this Privacy Notice to these third parties and will ensure through the signing of agreements and/or the adoption of other binding documents, that said third parties maintain the necessary administrative, technical and physical security measures to safeguard your Personal Data, as well as that said third parties only use your Personal Data for the purposes for which they were collected. Likewise, both the Client as the party responsible for collecting Personal Data and Skills Tech that facilitates the collection and processing of them through the Platform, as well as any other person related to Skills Tech that has access to the information contained in this Privacy Notice, will be obligated to safeguard it under the same security and confidentiality standards, and not to disclose it or misuse it, otherwise they will be responsible in accordance with applicable laws. Notwithstanding the foregoing, Skills Tech will not transfer your Personal Data to third parties unrelated to Skills Tech, except in the cases cited above and those provided for in the Law, without your prior consent.
4. MEANS AND PROCEDURES FOR EXERCISING ARCO RIGHTS
You, as the holder of the Personal Data provided to Skills Tech, may request at any time, the exercise of your rights of access, rectification, cancellation or opposition (the "ARCO Rights") to the processing of your Personal Data, consisting of: (i) accessing your Personal Data and details of their processing; (ii) rectifying your Personal Data in case it is inaccurate or incomplete; (iii) canceling your Personal Data when you consider that it is not required for any of the purposes indicated in this Privacy Notice, is being used for unauthorized purposes or your contractual or service relationship or other with Skills Tech has ended; and (iv) oppose the processing of your Personal Data for specific purposes. To this end, you must follow the process of submitting your petition in writing to Skills Tech, or send your request to the Email, as applicable, which must contain at least the following information: (a) your full name and address, or other suitable means to communicate the response to your request; (b) documents accrediting your identity or, where appropriate, that of your legal representative; (c) clear and precise description of the Personal Data in respect of which you seek to exercise any of the aforementioned rights; and (d) any other element or information that facilitates the location of the Personal Data, as well as any other document required by the current regulation at the time of submitting the request. You can also request more information about the procedure to exercise your ARCO Rights from the Email. The response to your request will be made known to you by Skills Tech under the terms and deadlines established by Law. However, you can obtain more information about the status of your request and the response period by contacting Skills Tech or sending your request to the Email, where they can also address any clarification or doubt you may have regarding the processing of your Personal Data and the exercise of your ARCO Rights.
5. REVOCATION OF CONSENT; LIMITATION OF USE AND DISCLOSURE OF PERSONAL DATA
You may also revoke, at any time, the consent you have given to Skills Tech for the processing of your Personal Data, as well as request that the use and disclosure thereof be limited, provided that it is not prevented by a legal provision. To this end, you must submit your request in writing to Skills Tech, or send your request to the Email, as applicable. Said request must comply with the same requirements mentioned in Section 4 above. The response to your request will be made known to you by Skills Tech under the terms and deadlines established by Law. However, you can obtain more information about the status of your request and the response period by contacting Skills Tech or sending your request to the Email, where they can also address any clarification or doubt you may have regarding the treatment and these rights corresponding to you regarding your Personal Data. In the event that your Personal Data had been previously sent prior to the date of revocation of consent, and are still being processed by Skills Tech agents, Skills Tech will make known to the latter said revocation, so that they proceed accordingly.
6. CHANGES TO THE PRIVACY NOTICE
Skills Tech reserves the right to modify and/or update this Privacy Notice, in whole or in part, at its sole discretion, in which case it will communicate it here through the Platform; and, depending on the specific case of each owner, through its internal networks, or by means of a notice that will be placed in Skills Tech's usual means (physical or electronic) of communication and in a visible place at the Address, or by means of a written notice addressed to your email, as legally required.
7. DIGITAL, ELECTRONIC OR ONLINE FORM
The Parties agree that the way to perfect the agreement of wills between them may be the Digital, Electronic or Online format, where it will suffice to express their will by means of their acceptance, as well as provide personal data, on the Skills Tech Platform without requiring to affix a signature on any document.
Date of first issue: May 23, 2022
Date of last modification: November 12, 2023