PRIVACY POLICY
Last updated: 16.10.2024
PLEASE CAREFULLY READ THIS PRIVACY POLICY (HEREINAFTER REFERRED TO AS "POLICY"), WHICH GOVERNS HOW LANCELOT DEVELOPMENT LTD, A COMPANY REGISTERED UNDER THE RELEVANT LAWS OF THE ST. VINCENT AND GRENADINES, WITH ADDRESS AT SUITE 305, GRIFFITH CORPORATE CENTRE, KINGSTOWN, ST. VINCENT & THE GRENADINES (HEREINAFTER REFERRED TO AS "COMPANY", "WE"), COLLECTS, USES AND DISCLOSES INFORMATION, WHEN YOU ACCESS OR USE A WEBSITE HTTPS://SKILLNETWORK.AI, SKILL NETWORK AI PARTNER TELEGRAM BOT HTTPS://T.ME/SKILLNETWORKAI_PARTNER_BOT AND/OR SKILL NETWORK AI TELEGRAM BOT HTTPS://T.ME/SKILL_NETWORK_AI_BOT (HEREINAFTER JOINTLY REFERRED TO AS THE "SERVICE") OR WHEN YOU OTHERWISE INTERACT WITH US.
1. Applicability and Acceptance of Policy
This Policy defines the Personal Data, explains how Personal Data is collected, used, processed, and disclosed.
This Policy shall come into effect at the moment you first access the Service. By accessing, browsing, using the Service, ticking a Consent box when visiting the website and/or clicking the button “Start” you unconditionally accept and adhere to provisions of this Policy without any exemptions, limitations and/or exclusions.
In the event you disagree with any provision of this Policy or would not like to provide your consent for processing of your Personal Data, you shall cease using the Service.
2. Information about the Data Controller
The data controller of the data collected through the Service is Lancelot Development Ltd, a company registered under the relevant laws of the St. Vincent and Grenadines, with address at Suite 305, Griffith Corporate Centre, Kingstown, St. Vincent & the Grenadines. Contact details: pm@skillnetwork.ai.
3. Legal Grounds for Personal Data Processing
We process your Personal Data on the basis that it is:
necessary for the performance of a contract, therefore, where we have a contract with you, we will process your Personal Data in order to fulfill that contract (in particular, to provide access to the Service under the Terms of Use).
authorized by your Consent, which you give us as it is set out in section 4 hereof.
necessary for compliance with our legal obligation, in particular, when we are obliged to respond to a court order or a regulator.
necessary for performance our legitimate interests.
permitted by applicable legislation.
4. Consent to Personal Data Processing
Including are an EU Person, to process your Personal Data we need to receive your consent, as it is prescribed by GDPR or other applicable law, we will process your Personal Data in the case we have received from you a freely given, specific, informed and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data ("Consent").
By accessing the Service, ticking a Consent box when visiting the website and/or clicking the button “Start”, you directly and voluntarily agree that you are clearly informed of the data's intended use, and you give us individual, explicit, active, informed Consent.
Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the Processing has multiple purposes, your Consent should be deemed given for all of them, unless otherwise provided by this Policy.
You have the right to withdraw your Consent at any time. You can submit such a request by sending us an email to pm@skillnetwork.ai. Your withdrawal of Consent shall not affect the lawfulness of your Personal Data processing based on Consent before its withdrawal.
Except as required or enabled by law we will not use or disclose your Personal Data for any purpose for which you refuse Consent or later withdraw your Consent. If you withdraw Consent, you agree that in spite of this withdrawal, we may continue to use those Personal Data previously provided to us to the extent that we are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation you may have towards the Company or in any other way permitted by law.
5. Collection of Personal Data
General Provisions
The type of Personal Data we collect depends on how you are interacting with us. In many cases, you can choose whether or not to provide us with Personal Data, but if you choose not to, you may not get full functionality of the Service. When you visit Service, you may provide us with the following types of Personal Data: (i) Personal Data that you voluntarily disclose that is collected on an individual basis; (ii) Personal Data collected automatically when you use the Service; and (iii) Personal Data which we collect from sources other than the Service.
The Service contains links to other third-party websites that may collect Personal Data about you, including through cookies or other technologies. If you use our links to visit other websites this Policy will not apply to your use of, and activity on those other websites. You should consult these other third parties' privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.
Personal Data You provide to Us
In order to fulfill our obligations under Terms of Use, we are entitled to ask you to provide us with your Personal Data, including (but not limited):
E-mail;
Name and surname;
Phone number;
Bio;
Marital status;
Professional experience;
Education;
Wallet address;
Telegram Username.
Personal Data hereof is collected only when voluntarily offered, and solely for purposes that are clearly identified on the Service or in this Policy.
The Company may collect the Personal Data from you in a variety of ways and circumstances, including, but not limited to subscription to a newsletter, filling out a form, providing us with feedback. The Company shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the Service with any other relevant available information.
any public information about you in the Telegram;
any information you send to the Telegram Bots;
any information you send to any AI bot chat on the website, including text, images, videos, voice. When you use our Services, we collect Biometric Information that is included in the images, videos, voice and other Biometric Information (as defined in the Biometric Information Privacy Notice) that you provide to create videos, avatars, and other forms of output, as well as metadata associated with the inputs. The information we use for this process is used to create and personalise photo shoots, avatars and provide other AI functionality. For more information about the Biometric Information processing, please see our Biometric Information Privacy Notice;
any information that you provide in the forms for using the artificial intelligence on the website;
device information, which may include (but is not limited to) information about the computer or mobile device you use to access the Service, including the hardware model, operating system and version, the web browser you use, and other device identifiers;
server log information, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, button clicks, input form changes (without the values being entered), Errors. your IP address, time spent at the Service and the websites you visit just before and just after the Service;
information collected by cookies and other tracking technologies. We and our Service providers use various technologies to collect information when you interact with the Service, including cookies and web beacons. ‘Cookies’ are small data files that are stored on your device when you visit the Service which enable us to collect information about your device identifiers, IP address, web browsers used to access the Service, pages or features viewed, time spent on pages and links clicked. Web beacons are graphic images that are placed on a Service or in an email that is used to monitor the behavior of the user visiting the Service or sending the email. They are often used in combination with cookies. The Company's policy regarding the cookies is specified in Cookies Notice;
to provide access to the Service;
to provide you with certain services through the Service (Opportunities), including providing AI functionality;
to handle your orders and requests, including requests for technical support and assistance;
to train our artificial intelligence in order to provide you with more personalized services;
to properly fulfill tax-related and accounting obligations imposed by applicable laws;
to detect, investigate, and prevent illegal activities or conduct that may violate the Terms of Use of the Service and this Privacy Policy;
personalize your experience with our Service;
contact you in relation to, and conduct, surveys or polls you choose to take part in and to analyse the data collected for market research purposes;
conduct internal research and development and to improve, test and enhance the features and functions of our Service;
provide you with marketing materials as permitted by law;
meet our internal and external audit requirements, including our information security obligations.
7. Disclosure of Personal Data
The Company treats Personal Data as confidential and may not pass on or use any such data without valid legal grounds.
We will only disclose your Personal Data in the following circumstances:
with your Consent or at your instruction;
with companies under common control or ownership with us or our offices internationally;
for everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations;
in connection with a merger or sale of our company assets, or if we do a financing or are involved in an acquisition, or any other situation where Personal Data may be disclosed or transferred as one of our business assets;
if we believe your actions are inconsistent with our terms of use of the Service or applicable legislation, or to protect the rights, property and safety of any assets of the Company or third parties;
The Company may without limitations share aggregated or de-identified information, which cannot reasonably be used to identify you.
If you have agreed to the terms of this Policy, as well as: filled out registration forms for Company events or other forms of the Company received from Partners (as this term is defined in the Marketing Affiliate Program Agreement), clicked on an Affiliate link or another unique link of Affiliate or entered an Affiliate Code, and then provided your Personal Data, we may disclose your Personal Data as Affiliate Lead to the relevant Affiliate and Affiliate's Personal Data who invited you as Affiliate Lead. We may disclose:
E-mail;
Name and surname;
Phone number;
Telegram Username.
If the Affiliates Leads of lower tier in the Affiliate Structure have agreed to the terms of this Policy, as well as performed actions described in Clause 7.4 and then provided your Personal Data, we may disclose their Personal Data to the relevant Affiliate who is at the head of the Affiliate Structure. We may disclose:
E-mail;
Affiliate Status;
Affiliate Generation;
Amount of purchases of the Affiliate Structure.
Each Affiliate, before sending their Affiliate Link or other his/her/their unique link, must warn the User that as a result of clicking on the link, entering the Affiliate Code and then providing Personal Data, he/she/they will gain access to his/her/their Personal Data. Each Affiliate who agrees to this Policy and the Marketing Affiliate Program Agreement guarantees the fulfillment of this requirement. THE FULFILLMENT OF THIS REQUIREMENT IS SOLELY THE RESPONSIBILITY OF THE AFFILIATE.
The Personal Data that we disclose to an Affiliate according to Clauses 7.4, 7.5 can only be used to contact you in order to tell you about our services personally and to create the community. The Affiliate guarantees that he/she/they will not disclose the Affiliate Lead's and Affiliate Lead's of lower tier Personal Data to third parties, make Personal Data public, carry out spam mailings, or otherwise use Personal Data for purposes not provided for in this clause.
You can at any time report the misuse of your Personal Data by the Affiliate and/or ask us to restrict the Affiliate's access to your Personal Data in accordance with this Policy and applicable law.
8. Transmission of Personal Data
The transmission of Personal Data or any other information (including communications by email) over the Internet or other publicly accessible networks is not one hundred percent secure. The Company is not liable for the security of any Personal Data or any other information you are transmitting over the Internet, or third-party content.
Information about you may be transferred to, and processed in countries other than the country in which you are a resident. We have taken appropriate safeguards to require that your information will remain protected in accordance with this Privacy Policy.
Personal Data of EU Persons transmitted to a recipient outside the European Economic Area may be processed by a staff member operating outside the European Economic Area (EEA) who works for us or for one of Digital Content developer or copyright owner. Such staff may be engaged in amongst other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
9. Protection of Personal Data. Security Measures
We take appropriate security, administrative and technical measures to protect any Personal Data you provide regarding the collection, storage and processing of Personal Data, as well as security measures to protect your Personal Data against unauthorized access, modification, disclosure or destruction.
Personal Data is safeguarded from unauthorised access and unlawful processing or disclosure, as well as accidental loss, modification or destruction, through state-of-the-art technical and organisational measures. These are adjusted and updated continuously in tandem with technical developments and organizational changes. Additionally, Personal Data protection audits and other controls are carried out on a regular basis. However, no computer security system is entirely foolproof and the Internet is not a secure method of transmitting information. As a result, we do not assume any responsibility for the Personal Data you submit to or receive from us through the Internet, or for any unauthorized access or use of that information, and we cannot and do not guarantee that information communicated by you to us or sent to you by us will be received, or that it will not be altered before or after its transmission to us. You agree to not hold the Company liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of information provided through the Service.
Each Affiliate to whom we disclose the Personal Data of other Users guarantees that he/she/they takes appropriate security, administrative and technical measures to protect any Personal Data you provide regarding the collection, storage and processing of Personal Data, as well as security measures to protect your Personal Data against unauthorized access, modification, disclosure or destruction.
10. Retention of Information
In accordance with applicable laws and as needed to fulfill our obligations, we may hold your Personal Data. This requirement is conditioned by a need to comply with legal obligations and resolve possible disputes.
The Company may retain your Personal Data until your Consent is not withdrawn or Terms of use are terminated. Provided however that we try not to store any of your personal data, specified in section 5.2. of Privacy Policy longer that it is necessary to provide you access to the Service or to respond to your inquiry.
11. Your Rights in relation to Personal Data
The Company is committed to making sure you can exercise your respective rights effectively and free of charge. The Company will ensure each request related to your Personal Data be reviewed in a timely fashion.
You have the following rights relating to your Personal Data in accordance with any applicable laws, including GDPR:
Right to withdraw data protection consent.
You have the right to withdraw your consent to processing of your personal data at any time.
Right to access.
You can request access to your Personal Data and obtain a copy of such Personal Data in a format acceptable to you (e.g. PDF, DOC, DOCX, etc.). You can submit such a request by email pm@skillnetwork.ai. After your request is received, our privacy team reviews the form and conducts the requestor's identity verification, without undue delay. Upon successful verification, you are provided with a copy of your Personal Data.
Right to restriction of processing.
You have the right to obtain from the Company restriction of processing where one of the following applies:
the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data.
the processing is unlawful and you oppose the erasure of the personal data and requests instead the restriction of their use instead.
we no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; and/o
you have objected to processing pursuant to applicable laws.
Right to data portability.
You have the right to receive the personal data concerning You, which you have provided to a Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Company.
Right to erasure ("Right to be forgotten") and right to rectification.
You have the right to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
You have the right to obtain from us the erasure of personal data concerning you as soon as possible, and we shall have the obligation to erase personal data without undue delay where required by the law, including when:
the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
there is no longer a legal ground for the processing;
you object to the processing and there are no overriding legitimate grounds for the processing;
the personal data has been unlawfully processed;
the personal data must be erased for compliance with a legal obligation in accordance with the applicable law to which we are subject.
Right to object.
You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you. We shall no longer process the personal data in the event of the objection, unless we can demonstrate reasonable grounds for the processing, which override the interests, rights and freedoms of you, or for the establishment, exercise or defense of legal claims.
Right to be informed.
If you are inquiring about Processing activities conducted with respect to your Personal Data, the Company, without undue delay, will provide information about: (i) purposes of Processing; (ii) categories and types of Personal Data; (iii) the recipients or categories of recipients to whom the personal data have been or will be disclosed to, in particular recipients in third party countries or international organizations (iii) retention period; (v) source of the relevant Personal Data; (vi) privacy rights and information on data portability; (vii) where the personal data are not collected from the data subject, any available information as to their source; (viii) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject; (ix) information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data in subject to, shall have the right to be informed of the appropriate safeguards relating to the transfer. However, all information about the categories of Personal Data and Processing operations conducted by the Company is available in this Policy.
Right to lodge a complaint with a supervisory authority.
Supervisory authority means an independent public authority, for example, which is established by an EU member state pursuant to Article 51 GDPR or any other applicable law.
12. Children's Privacy
The minimum age to use the Service is 18 years. The Company will not knowingly collect Personal Data from children under this age. Insofar as certain countries apply a higher age of consent for the collection of Personal Data, the Company requires parental consent before Personal Data associated with such a child is collected. The Company encourages parents to instruct their children to never give out personal information when online.
13. Alterations to Policy
We have the right, at our discretion, to update this Policy at any time. We recommend that you frequently check this Policy to find any changes and stay informed about how we help protect the Personal Data.
By using the Service, you will acknowledge and agree that it is your responsibility to periodically review this Policy and be aware of the changes.
The subsequent use of the Service after changes to this Policy will also be considered as your acceptance of these changes.
This Policy may from time to time be translated into other languages. To the extent that any discrepancy may exist between the English version of this Policy and its version in another language, the English version prevails.
14. Feedback
We welcome your questions and suggestions with respect to the implementation or amendment of this Policy. Please use this feedback for communicating with us: pm@skillnetwork.ai.