Privacy Policy

Edtech Services LLC - 170 Commerce Way, Portsmouth, New Hampshire, 03801 Website Privacy Statement

Upskillist services, including (without limitation) our website and other interactive properties through which the services are delivered (collectively, the “Service”) are owned, operated and distributed by Edtech Services LLC - 170 Commerce Way, Portsmouth, New Hampshire, 03801 (referred to in this Privacy Statement as “Upskillist” or “we” and through similar words such as “us,” “our,” etc.).

Upskillist is committed to protecting your privacy and takes its responsibility regarding the security of customer information very seriously. Our website Privacy Statement sets out what information we collect, how we collect it, what we do with it and how we protect this information. This includes information collected through automated AI-powered features, such as Compass AI, which may process your queries or inputs to deliver educational support and recommendations. Any personal information is collected and processed in accordance with the data protection laws in the jurisdictions in which we operate (e.g. United States (“US”) and European Union (“EU”)).

Upskillist encourages our customers, visitors, business associates, and other interested parties to read this Privacy Statement, which applies to all users of the Service. By using our Service or submitting personal information to Upskillist by any other means, you acknowledge that you understand and agree to be bound by this Privacy Statement, and agree that Upskillist may collect, process, transfer, use, and disclose your personal information as described in this Statement. Further, by accessing any part of the Service, you are agreeing to THE TERMS AND CONDITIONS OF OUR TERMS OF USE (the “Terms of Use”). IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY STATEMENT OR OUR TERMS OF USE, PLEASE DO NOT USE ANY OF THE SERVICES.

COLLECTION OF PERSONAL INFORMATION

Personal information (also commonly known as personally identifiable information (PII) or personal data) is information that can be used to identify you, or any other individual to whom the information may relate. The categories of personal information that Upskillist may collect in the course of our relationship with you is described below.

Information you provide to us:In order to facilitate the provision of education, we collect personal details from you together with information we learn about you from your use of our website. These details may include (where applicable)

Name and contact information (e.g., address, telephone number, e-mail);
Billing information (e.g. credit/debit card, other payment details, billing contact information)
Account information (e.g. personal goals, account profile photos, ratings, webinar chat);
Information contained in posts you may make on the public forums and interactive features of the Service;
Other information that may be exchanged in the course of engaging with the Service. You will be aware of any subsequently collected information because it will come directly from you.

Information we collect automatically: We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service (such as smart TVs, gaming systems, smart speakers and mobile devices). We may also collect information you provide during interactions with our AI assistant, Compass AI, such as course-related queries, learning goals, or feedback. These interactions may be processed and stored to support personalized learning experiences, improve AI functionality, and assist with customer service. Conversation data may include your name, course selections, and progress, but will not be used to collect sensitive personal data such as health or government identification numbers. AI-based interactions are processed using third-party infrastructure and large language models, such as those provided by Botpress and OpenAI. Your inputs may be temporarily processed outside your home country (see “International Transfers” for more details), but will be handled under strict data protection safeguards. This information includes:

your activity on the Service, such as course selections and attendance/watch history;
your interactions with our email, webinar chat, push and text messaging;
details of your interactions with Customer Service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
IP address, device IDs, or other unique identifiers;
advertising identifiers, such as those on mobile devices, tablets, and streaming media devices that include such identifiers (see the “Cookies and Internet Advertising” section below for more information);
device and software characteristics (such as type and configuration), connection information, statistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information;
information collected via the use of cookies, web beacons and other technologies, including ad data (such as information on the availability and delivery of ads, the site URL, as well as the date and time). (See our “Cookies and Internet Advertising” section for more details.)

To provide location-based services we may collect, use, and share precise location data, including the real-time geographic location of your computer or device through GPS, Bluetooth, and your IP address, along with crowd-sourced Wi-Fi hotspot and cell tower locations. This location data is collected anonymously, unless you provide consent. You may withdraw consent to Upskillist and our partners’ collection, use, transmission, processing and maintenance of location and account data at any time by not using the location-based features and turning off the Location Services settings (as applicable) on your device and computer.

No mobile information obtained in the course of an opt-in to SMS marketing will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, including affiliate or business partners. The opt-in is not transferable to another party involved in the process

USE OF PERSONAL INFORMATION

Subject to the terms of this Privacy Statement, Upskillist uses the above described categories of personal information in several ways. Unless otherwise stated specifically, the above information may be used for any of the following purposes:

to administer the Service to you;
to respond to your requests;
to distribute communications relevant to your use of the Service, such as system updates, customer surveys, or information about your use of the Service;
as may be necessary to support the operation of the Service, such as for billing, account maintenance, and record-keeping purposes;
to send to you Upskillist solicitations, product announcements, and the like that we feel may be of interest to you (you may “opt out” of receiving these marketing materials);
to enhance and personalize our services and marketing efforts (e.g. statistical and marketing analysis)
in other manners after subsequent notice is provided to you and/or your consent is obtained, if necessary.
to provide personalized support and recommendations through AI-driven features such as Compass AI, and to derive insights that may inform internal marketing strategies and external advertising campaigns, where legally permitted;
to improve the quality and accuracy of AI services by analyzing usage patterns and user inputs, without using your data to train third-party models unless explicitly disclosed and consented to;

We follow strict security procedures in the storage and disclosure of student information.

We may disclose any of the described categories of personal information to Upskillist employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on our behalf in order to provide the Service to you. This may include sharing certain inputs or usage data with trusted third-party AI service providers (such as Botpress or OpenAI) when processing user interactions with Compass AI. These providers process data only as necessary to generate responses and do not retain user information beyond the duration of the interaction, unless configured otherwise. These subprocessors are bound by strict contractual terms, including data protection agreements consistent with GDPR and CCPA. For a current list of subprocessors used in relation to AI services, please refer to our Subprocessor Disclosure Appendix or contact us at support@upskillist.com. These disclosures may include trusted contracted companies who act as “data processors” on our behalf for the purposes set out in this Privacy Statement. In such circumstances, we require that these parties agree to protect the confidentiality of such information consistent with the terms of this Privacy Statement by executing transfer agreements with all entities to which we transfer data for processing. The agreements provide for specific and limited processing of user data in service of Upskillist’s operations and have been prepared so as to meet the requirements of the jurisdictions in which we operate (including the US and EU).

Where permitted by law, we may also pass your information (including relating to the stages of your training) to third parties with whom we have a contractual or other close relationship and where we believe they offer products or services that may enhance the training we provide to you, your ability to practice or gain additional skills or their offering may otherwise be of interest to you.

If you sign up for third-party email job alert services on our site, we will share your personal information with the third party to provide you with such services

In addition, we may release personal information

to the extent we have a good-faith belief that such action is necessary to comply with any applicable law;
to enforce any provision of the Terms of Use, protect ourselves against any liability, defend ourselves against any claims, protect the rights, property and personal safety of any user, or protect the public welfare;
when disclosure is required to maintain the security and integrity of the Service, or to protect any user’s security or the security of other persons, consistent with applicable laws;
to respond to a court order, government inquiry, subpoena, search warrant, or other legal process, to the extent permitted and as restricted by law; or
in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets.

Finally, you may be able to access third party social media services through our website or before coming to our website. When you are registered with your social service account, we will obtain the personal information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalize your use of our website. This may include a list of friends and reviews of other users in your network. We may also use social media plugins on our website. As a result, your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of these third-party social media providers to find out more about these practices.

UPSKILLIST STUDENT/MEMBERS AREA

All data collected upon registration in Upskillist will be processed in line with this Privacy Statement. In your personal Upskillist student area we store all your course information, so that you can access it whenever you wish.

We understand the importance of taking extra precautions to protect the privacy and safety of children. Accordingly, children under 16 will not be permitted to open a Upskillist account. We will take reasonable steps to delete any Upskillist account or information created by a child under 16, as soon as we learn about it.

All payment details are transmitted over a secure connection (Secure Socket Layer-SSL) across dedicated network infrastructure (Multiprotocol Label Switching-MPLS) and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).

You will have the option to stay signed-in into your Upskillist account by checking the “remember me” box. This option will only apply to the computer / device and the browser that you’re using when you select the box. If you do not wish to stay signed on a particular browser, simply sign out of your Upskillist account on that browser.

Interactions with Compass AI — including questions asked, support received, and guidance given — may be stored within your student profile or in temporary system logs for the purposes of enhancing your learning experience, enabling continuity across sessions, and supporting educational recommendations. These logs are not visible to other users and are handled with the same data protection and access restrictions as your core account data.

You may delete your Upskillist account by contacting Upskillist support here (Please see your Rights Section for more details).

Finally, we may invite you to post content on the Service, including your comments and any other information that you would like to be available on the Service, which may become public (“User Generated Content”). If you post User Generated Content, all of the information that you post will be available to authorized personnel of Upskillist and may be made publicly available. You expressly acknowledge and agree that we may access in real-time, record and store archives of any User Generated Content on our servers to make use of them in connection with the Service. If you submit a review, recommendation, endorsement, or other User Generated Content through the Service, or through other websites including Facebook, Instagram, Google, Yelp, and other similar channels, we may share that review, recommendation, endorsement or content publicly on the Service.

DIRECT MARKETING MATERIAL

From time to time we, our selected partners or those with whom we have a contractual relationship may contact you with information regarding course promotions and ancillary products via channels including but not limited to email, voice, text, push notifications, internet-based ads and otherwise as the company sees fit. However, you will be given the opportunity on every e-communication that we or our trusted partners send you to indicate that you no longer wish to receive our or their direct marketing material. Data collected via your interactions with Compass AI may be used to better tailor promotional messages, both on our platform and through third-party advertising networks (such as Meta, Google, and TikTok). We may create user segments based on stated interests, such as course topics or career goals, and use those segments to deliver relevant campaigns. This targeting is conducted in compliance with your stated preferences and applicable privacy laws.

While Upskillist is deliberate in the marketing communications it sends, the systems used to communicate with you may be considered “automated” under some law and regulations. By accepting this Privacy Notice, you are consenting to receive such automated messages. Please note that, despite being classified as automated in some jurisdictions, Upskillist sends marketing communication based on what a member of our staff has written and determined may be relevant to you. Further, we will only communicate with you via a phone number or communication channel you have provided to us.

YOUR CHOICES REGADING DIRECT MARKETING

Email and Text Messages: If you no longer want to receive certain communications from us via email or text message, simply click the “unsubscribe” link in the email or reply STOP (or as otherwise instructed) to the text message. Please note that you cannot unsubscribe from service-related correspondence from us, such as messages relating to your student account transactions or course lesson reminders or information directly relating to your course.

Push Notifications: You can choose to receive mobile push notifications from Upskillist. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device’s settings functionality to turn them off.

Interest-Based Ads: Interest-based ads are online ads that are tailored to your likely interests based on your use of various apps and websites across the Internet. If you are using a browser, then cookies and web beacons can be used to collect information to help determine your likely interests. If you are using a mobile device, tablet, or streaming media device that includes an advertising identifier, then that identifier can be used to help determine your likely interests. For your choices about interest-based ads from Upskillist, please see the “Cookies” section (below).

Compass AI: Compass AI is an in-platform learning support tool and does not initiate contact or send marketing communications outside of the Upskillist dashboard. Therefore, no separate opt-out is required for its functionality. However, AI-derived insights (e.g., inferred goals or course interests) may inform advertising strategies on third-party platforms such as Meta, Google, or TikTok. These activities fall under the same marketing preferences and opt-out rights as other direct marketing methods.

SITE TRACKING AND COOKIES

We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal passenger information.

We and our Service Providers use cookies and other technologies (such as web beacons), as well as advertising identifiers, for various reasons. For example, we use these technologies to make it easy to access our services by remembering you when you return, to provide and analyze our services. We also use cookies, as well as advertising identifiers, to learn more about our users and their likely interests, and to deliver and tailor marketing or advertising. We want you to be informed about our use of these technologies, so this section explains the types of technologies we use, what they do and your choices regarding their use. Some cookies or browser storage mechanisms may be used to persist your session with our AI assistant, Compass AI, especially during a single browsing session. These are used solely to maintain context for your conversation and are not used for marketing purposes unless explicitly consented to. For complete information regarding our use of cookies and similar technologies, please visit Upskillist’s Cookie Policy.

LINKS TO THIRD PARTY WEBSITES

This privacy statement only covers websites that we own and control. It does not cover links to other websites and accordingly any information collected by those parties that own and control those websites or their use of cookies set from their domains when you visit their websites. Please be aware that individual third-party organizations operate their own policies regarding the use and sale of personal information and the use of cookies. If you have a concern regarding the way your personal information will be used on other sites or on the type of cookies used and how they are being used then you are advised to read the relevant privacy statement and cookie policy or in the absence of such a statement and policy on the site, contact the company concerned. Any data stored by third party websites are stored completely separately by third party.

You hereby acknowledge and agree that Upskillist is not responsible for the privacy practices, data collection policies and procedures, or the content of such third-party sites, and you hereby release Upskillist from any and all claims arising out of or related to the privacy practices, data collection policies and procedures, and/or the content of such third-party sites

THIRD PARTY ADVERTISERS

We may allow other companies, called third-party ad servers or ad networks, to serve advertisements within the Service. These third-party ad servers or ad networks use technology to send, directly to your device, the advertisements and links that appear on the Service. They automatically receive your device ID and IP address when this happens. They may also use other technologies (such as cookies, JavaScript, or Web Beacons) to measure the effectiveness of their advertisements and to personalize the advertising content you see. You should consult the respective privacy policies of these third-party ad servers or ad networks for more information on their practices and for instructions on how to opt-out of certain practices. This Privacy Statement does not apply to them, and we cannot control their activities. We may allow other companies, such as third-party ad networks and platforms (including but not limited to Meta, Google, and TikTok), to deliver advertisements related to our services. While we do not share full Compass AI transcripts or sensitive personal data, we may use anonymized or derived insights — such as user interests or career goals — to build advertising segments. These segments may then be used to deliver targeted ads on third-party platforms. This is done in accordance with your data preferences and in compliance with relevant privacy laws.

INFORMATION SECURITY AND USER RESPONSIBILITY

We take great care to ensure the security of our website. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.

Users of the Service are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Service. In order to protect you and your information, we may suspend your use of any of the Service, without notice, pending an investigation, if any breach of security is suspected.

Interactions with Compass AI are transmitted securely and processed in accordance with our internal access control protocols. Access to Compass AI data, including chat transcripts or derived insights, is limited to authorized personnel only and handled under the same security policies that govern other personal data on our platform.

INTERNATIONAL DATA TRANSFER

If you are located outside the United States — particularly in jurisdictions like the European Economic Area (EEA), United Kingdom, or Switzerland — please be aware that your personal data may be transferred to and processed in countries where data protection standards may differ. Specifically, data submitted through Compass AI may be processed in the United States, where our AI service provider, Botpress, and its sub-processors (including cloud infrastructure and LLM partners like OpenAI) are based. These transfers are governed by Standard Contractual Clauses and other safeguards to ensure compliance with EU data protection law.

Canada Only, data might be transferred outside of Canada to a country where the data could be accessed by governmental, regulatory or law enforcement agencies etc

EUROPEAN UNION DATA PRIVACY RIGHTS

If you are located in EEA, the General Data Protection Regulation (“GDPR”) may grant you certain rights under the law. In particular, the right to access, correct, and delete the personal information we hold about you. Upskillist will retain your personal information for the length of time you engage with our services as described in the retention section of this Statement, unless you request deletion of such personal data.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the personal information we have on you.
The right of rectification. You have the right to have your personal information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your personal information.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the personal information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

You can most easily exercise your privacy right do this by visiting the “account” section within your Members Area, where you have the ability to access and update your contact information. You must be signed in to access the “account” section. You may also request that we delete personal information that we hold about you.

To make requests, or if you have any other question regarding our privacy practices, please contact our data protection officer/privacy office at link. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please also see the “your choices” section of this privacy statement for additional choices regarding your information.

You may also request access to, correction of, or deletion of data collected via interactions with Compass AI. If these chat-based interactions are tied to your user account, they will be handled in accordance with your broader data subject rights and processed within the same governance and response timelines.

If you have a comment, question, or complaint about how we are handling your personal information, we hope that you contact us as described in this Statement in order to allow us to resolve the matter. In addition, you may submit a complaint regarding the processing of your personal information to the EU data protection authorities (each a “DPA”). The following link may assist you in finding the appropriate DPA: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Our legal basis for collecting and using the personal information described in this Privacy Statement will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where

we need the personal information to perform a contract with you (for example, to provide our services to you);
where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences);
where we have your consent to do so (for example, for you to participate in certain consumer insights activities like specific surveys and focus groups); or
where we have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to prevent payment fraud or confirm your identity).
where AI-based support is provided via Compass AI, we may rely on our legitimate interest in enhancing the learning experience and platform usability, or on your consent where personalization or analytics go beyond core service delivery;

Where personal information is processed based on consent, EU residents have the right to withdraw such consent at any time. To do so, please contact us as described in this Statement. If there is a different legal basis that would permit us to continue processing your personal information after withdrawing consent, we will notify you of that legal basis at the time of your request. For questions about our use of your personal information (including legal bases and transfer mechanisms we rely on), cookies or similar technologies, please contact our Data Protection Officer/Privacy Office by email at link.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with certain rights with regard to your personal information under the California Consumer Privacy Act (“CCPA”). Throughout this Privacy Statement you will find information required by CCPA regarding the categories of personal information collected from you; the purposes for which we use personal information, and the categories of third parties your data may be shared with. This information is current as of the date of the Statement and is applicable in the 12 months preceding the effective date of the Statement.

As a California resident, the CCPA provides you the ability to make inquiries regarding to your personal information. Specifically, the degree to which the information is not already provided in this Privacy Statement, you have the right to request disclosure about the collection and use of your personal information over the past 12 months, including:

The categories of personal information collected about you.
The categories of sources for the personal information collected about you.
The business or commercial purpose for collecting your personal information.
The categories of third parties with whom your personal information was shared.
The specific pieces of personal information collected about you.
If your personal information was disclosed for a business purpose, the personal information categories disclosed and the categories of third parties to which the information was disclosed.
This includes any personal information derived from your interactions with Compass AI, such as questions asked, learning goals, or service feedback. These interactions may be used to personalize your experience, and you have the right to request access to, or deletion of, such data under CCPA.
If your personal information was sold in the past 12 months, the personal information categories sold and the categories of third parties to which the information was sold (Note: UPSKILLIST DOES NOT SELL THE PERSONAL INFORMATION OF CALIFORNIA RESIDENTS).

Please note that you may only make the above requests twice in a 12-month period. You also have the right to request that any of your personal information collected and retained be deleted, subject to certain exceptions. Finally, you have the right to not receive discriminatory treatment by Upskillist or any business for exercising any of the rights provided under CCPA.

You may most easily exercise some of your privacy rights by visiting the “account” section within your Members Area. You may also submit a request regarding your rights under CCPA by submitting a request to link or as described in the Contact Us section of this Statement.

If we receive a CCPA request from you, we will first make a determination regarding the applicability of the law, and we will then take steps to verify your identity prior to responding. The steps to verify your identity may vary based on our relationship with you, but, at a minimum, it will take the form of confirming and matching the information submitted in the request with information already held by Upskillist and/or contacting you through previously used channels to confirm that you submitted the request (i.e. confirming identity through contact information that we have on file, not the contact information submitted to make the request).

Your rights as stated here can also be exercised by an authorized agent on your behalf. Upskillist will follow the standards set by the Attorney General of California regarding designation of an authorized agent to exercise rights under CCPA. You may review information available through the Attorney General website (https://www.oag.ca.gov/privacy/ccpa) regarding how an individual can be designated as an authorized agent under CCPA.

In addition to CCPA, California Civil Code Section 1798.83 permits users of the Website who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as described here.

RETENTION OF DATA

Upskillist will retain your personal information only for as long as is necessary for the purposes set out in this Statement. We will retain and use personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Data collected through Compass AI interactions — including chat transcripts or derived engagement insights — is retained only as long as necessary to provide our services to you and fulfill legitimate business purposes, such as improving educational outcomes, maintaining service continuity, ensuring safety, and complying with legal obligations. The exact retention period may vary depending on the nature and purpose of the data. We regularly review and assess retention practices to ensure they align with applicable privacy laws and data minimization principles. Users may request deletion of such data at any time in accordance with their rights outlined in this Privacy Policy.

Upskillist will also retain usage data for internal analysis purposes as described in the this Statement and the Cookie Policy. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer periods.

CHILDREN’S PRIVACY

The Service is not intended for children under the age of 16, and Upskillist does not knowingly collect the personal information of children under the age of 16. Compass AI is not designed for use by children under the age of 16 and does not knowingly collect or process information from minors. If a user under this age engages with the AI assistant, and we become aware, we will take appropriate steps to delete the data and restrict access.

CHANGES TO PRIVACY STATEMENT

Our Privacy Statement may change from time to time and any changes to the statement will be posted on this page. Significant updates related to new technologies, including changes in our use of AI or data processors, will be clearly communicated through our platform or other reasonable means, in line with applicable legal requirements.