This “Privacy Policy” describes the privacy practices of Say it Skillfully and our subsidiaries and affiliates (collectively, “Say it Skillfully,” “we”, “us”, or “our”) when you interact with or use our websites, including
but not limited to https://www.sayitskillfully.com/ (the “Sites”), when you become a participant of Say it Skillfully (“Participant”), when you interact with or use our social media pages, public forums or events,
sales marketing or other online and offline activities, and generally any other services offered and made available by us via our Sites or during your participation (collectively we refer to any combination of the above as the “Service”), and the rights and choices available with respect to your personal information.
When you access or use our Services, you acknowledge that you have read this Privacy Policy and understand its contents. Your use of our Services and any dispute over privacy is subject to this Privacy
Policy and any applicable service terms.
Table of Contents
1. Personal Information We Collect
2. How We Use Your Personal Information
3. How We Share Your Personal Information
4. Your Rights and Choices
5. Third Party Sites and Services
6. Security Practices
7. International Data Transfers
8. Storage and Retention
9. Children’s Privacy
10. Changes to this Privacy Policy
11. How to Contact Us
12. Information for California Residents
13. Personal Information We Collect
1. Personal Information We Collect
Information you provide to us. When you use our Services we may collect the following personal
information.
● Business contact data, such as your first and last name, email and mailing addresses (including
email address for any person assisting with your scheduling) and phone number.
● Profile data, such as your username and password that you may set to establish an online
account with us, your interests and preferences, your date of birth, and any content uploaded to
the Service (such as text, images, audio, and video, along with the metadata associated with the
files you upload).
● Registration data, such as information that may be related to a service, application information for
participating or an account or an event you register for, including, but not limited to, the following:
● Personal and professional goals, such as what you are passionate about, how you look
to grow personally and professionally, how powerful you consider your professional
network, how satisfied you are with your current career accomplishments and how you
rank your personal well-being.
● Participation goals, such as why you joined Say it Skillfully, what you want to get most out of it (i.e., strengthen network, connect on deeper level with like-minded people, sharpen leadership skills, partake in interesting events and programming, access to space outside your office to meet people), what you want to make the biggest priority of participating, and what you would love to learn more about.
● Protected classification characteristics, such as your ethnicity, sexual orientation, gender identity, relationship status and family overview. If you choose to provide any such protected classification characteristics, you consent to our processing in accordance with
this Privacy Policy.
● Sponsorship information, such as whether you requested and/or received sponsorship
from your company for participating.
● Communications, such as information you provide when you contact us with questions, feedback,
or otherwise correspond with us online.
● Marketing data, such as your preferences for receiving communications about our activities,
events, and publications, and details about how you engage with our communications.
● Professional and employment data, including, but not limited to, the following:
● Company information, such as your company’s name, industry, type of company and size
of company.
● Role information, such as your professional title, function, and any professional
credentials (e.g., professional level and level you report into) and skills (e.g., whether you manage a P&L, sales or marketing budget or have raised or been involved in raising capital for a business).
● Other information of the type that may be included on a resume or curriculum vitae, such as whether you currently sit on a board at your company and/or outside of your company.
● Financial data, such as the credit card or other payment card details that you use to pay for the
Service, and your Service-related billing information and transaction history.
● Other information, including information we may collect that is not specifically listed here, but
which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of
collection. Third party sources. We may combine personal information we receive from you with personal information
we obtain from other sources such as:
● Public sources, such as social media platforms. When you visit or interact with our social media
pages on those platforms, the platform provider’s privacy policy will apply to your interactions and
their collection, use and processing of your personal information. You or the platforms may
provide us with information through the third party platform, and we will treat such information in
accordance with this Privacy Policy.
● Other users, such as the facilitators or coaches that provide you mentorship and coaching
through our Services and that may provide information to us in accordance with professional,
legal, or ethical obligations.
● Marketing partners, such as joint marketing partners and event co-sponsors.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our Services:
● Device data, such as your computer or mobile device operating system type and version number,
manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the
website you visited before browsing to our Sites, and general or inferred location information such
as city, state or geographic area from your IP address.
● Online activity data, such as pages or screens you viewed, how long you spent on a page or
screen, navigation paths between pages or screens, information about your activity on a page or
screen, access times, and duration of access.
Cookies and similar technologies. Like many online services, we use common information gathering tools such as cookies, web beacons and similar technologies to automatically collect certain information from your computer or mobile device as you navigate our Sites, our Services or interact with emails we have sent as further described above:
● Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the
visitor’s browser or to store information or settings in the browser for the purpose of helping you
navigate between pages efficiently, remembering your preferences, enabling functionality and
helping us understand user activity and patterns. Cookies can be “persistent” or “session”
cookies. Persistent cookies remain on your personal computer or mobile device when you go
offline, while session cookies are deleted as soon as you close your web browser.
● Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a
webpage or email was accessed or opened, or that certain content was viewed or clicked.
More information regarding cookies we use:
How Say It Skillfully uses cookies
When you use and access the Service, we may place a number of cookies files in your web
browser.
We use cookies for the following purposes:
• To enable certain functions of the Service
• To provide analytics
• To store your preferences
We may use both session and persistent cookies on the Service and use different types of
cookies to run the Service:
• Essential cookies. We may use cookies to remember information that changes the way
the Service behaves or looks, such as a user’s language preference on the Service.
• Accounts-related cookies. We may use accounts-related cookies to authenticate users
and prevent fraudulent use of user accounts. We may use these cookies to remember
information that changes the way the Service behaves or looks, such as the “remember
me” functionality.
• Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our usersreact to them.
Third-party cookies
In addition to our own cookies, we may also use various third-parties cookies to report usage
statistics of the Service, deliver advertisements on and through the Service, and so on.
What are your choices regarding cookies
If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of
our pages might not display properly.
• For the Chrome web browser, please visit this page from Google:
https://support.google.com/accounts/answer/32050
• For the Internet Explorer web browser, please visit this page from
Microsoft: http://support.microsoft.com/kb/278835
• For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
• For the Safari web browser, please visit this page from
Apple: https://support.apple.com/kb/PH21411?locale=en_US
• For any other web browser, please visit your web browser’s official web pages.
Where can you find more information about cookies
You can learn more about cookies and the following third-party websites:
• AllAboutCookies: http://www.allaboutcookies.org/
• Network Advertising Initiative: http://www.networkadvertising.org/
2. How We Use Your Personal Information
We use your personal information for the following purposes and in reliance on the legal bases described
in this Privacy Policy:
Service delivery. We use your personal information to:
● provide and operate the Services and;
● provide information to inform our products and Services;
● establish and maintain your profile;
● communicate with you, including by sending you announcements, updates, security alerts, and
support and administrative messages;
● communicate with you about events or groups in which you participate, including introductions to
other participants and groups;
● provide support and maintenance; and
● to respond to your requests, questions and feedback.
We process your personal information in reliance on our contract with you. Where we have not entered
into a contract with you, we process your personal information in reliance on our legitimate interests in
operating and improving our internal operations, systems and Services, and to provide you with the
content, products or Services you access and request (e.g., to download content from our Sites).
Research and development / Improving and developing the Services. We use your personal information
for research and development purposes, including to analyze and improve the Service and our business.
We use data to analyze trends to identify future opportunities for the development, promotion, and improvement of our Services, in reliance on our legitimate interests in developing and improving our
Services, or where required, with your consent. For example, we use data, often in a de-identified form,
to develop new features, capabilities, or products, improve the user experience, assess capability
requirements, and identify opportunities.
Marketing. We may collect and use your personal information for marketing purposes:
● Direct marketing. We may send you Say it Skillfully-related or other direct marketing
communications in accordance with your marketing preferences as necessary for our legitimate
interest in conducting direct marketing, or to the extent you have provided your prior consent. You
may opt-out of our marketing communications as described in the “Your Rights and Choices”
section below.
Compliance and protection. We may use your personal information to comply with our legal obligations
under applicable laws, including to:
● protect our, your or others’ rights, privacy, safety or property (including by making and defending
legal claims);
● audit our internal processes for compliance with legal and contractual requirements and internal
policies;
● enforce the terms and conditions that govern our Service;
● protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal
activity, including cyberattacks and identity theft; and
● comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas
or requests from government authorities.
Processing job applications. We process your personal information if you apply for a job with Say it
Skillfully, to evaluate your application and make hiring decisions, communicate with you and inform you of
current and future career opportunities (unless you tell us that you do not want us to keep your details for
such purposes), manage and improve our recruiting and hiring processes, or to conduct reference and
background checks where required or permitted by applicable local law. We perform this processing to
the extent that it is necessary to comply with our legal obligations, for our legitimate interest in assessing
the suitability of our candidates and managing our recruiting process, or, where required by applicable
law, with your consent.
For our business purposes. We may use data for other legitimate business purposes in reliance on our
legitimate interests, such as to update, expand, and analyze our records, identify new customers, data
analysis, to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, developing
new products, enhancing, improving or modifying our Services, identifying usage trends, determining the
effectiveness of our promotional campaigns, as well as operating and expanding our business activities.
Other purposes with your consent. In some cases, we will ask for your consent to collect, use or share
your personal information for other purposes. For example, we may ask for your consent to send you
marketing emails where required by law or to post your testimonial or endorsement.
3. How We Share Your Personal Information
We do not share your personal information with third parties without your consent, except in the following
circumstances or as described in this Privacy Policy:
● Affiliates. We may share your personal information within the Say it Skillfully corporate group of
companies, for purposes consistent with this Privacy Policy.
● Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Services (such as customer
support, hosting, analytics, email delivery, marketing, and database management services).
These third parties may use your personal information only as directed or authorized by us and in
a manner consistent with this Privacy Policy and are prohibited from using or disclosing your
information for any other purpose.
● Partners and sponsors. We may share your personal information with partners. For example, if
we co-host an event with a third party, we may share your information to the extent related to such event. If required by applicable law, you can consent to such sharing via the registration
form. In these circumstances, your information will be subject to the sponsors' privacy statements. If you do not want your information shared, you can choose to not opt in upon
registration, or you can opt out according to the "Your Rights and Choices" section below.
● Coaches. As part of participating, Say it Skillfully provides mentorship and coaching. Therefore, if
you are a participant, we may disclose your personal information to our coaches and experts in
order to provide these Services to you.
● Payment processors. Any payment card information you use to make a purchase on the Service
is collected and processed directly by our payment processor, Stripe, and we never physically
receive or store your full payment card information. Stripe commits to complying with the
Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security.
Stripe may use your Payment Information in accordance with its own Privacy Policy here:
https://stripe.com/privacy.
● Other users and the public. Other parties may be able to view your content when you provide
such content through your public user profile or voluntarily disclose it in a manner that other users
or the public can view it. In addition, your username will be displayed to other users through the
Service, and other users may be able to contact you through the Service. Content that you post
publicly on, through or in connection with the Service, including on third party services such as a
social media platform, may also be public. We do not control how other users, or third parties use
any personal information that you make available to them. Please be aware that any information
you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g.,
search engines) before you have a chance to edit or remove it.
● Professional advisors. We may disclose your personal information to professional advisors, such
as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional
services they render to us.
● Compliance and protection. We may disclose your personal information as we believe
appropriate to government or law enforcement officials or private parties (a) for the compliance
and protection purposes described above; (b) as required by law, lawful requests or legal
process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal
claims.
● Business transferees. We may sell, transfer or otherwise share some or all of our business or
assets, including your personal information, in connection with a business transaction (or
potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition,
reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we
will make reasonable efforts to require the recipient to honor this Privacy Policy.
We may also share aggregated or de-identified usage data with third parties to help us perform analysis and make improvements. Additionally, we may share anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show
trends in the use of our Services.
For further information on the recipients of your personal information, please contact us (see the "How to
Contact Us" section below).
4. Your Rights and Choices
A. All users
In this section, we describe the rights and choices available to all users.
● Access or update your information. If you have registered for an account with us, you may review
and update certain personal information in your account profile by logging into the account.
● Opt out of marketing communications. You may opt out of marketing-related emails by following
the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected]. You may continue to receive service-related and other non-marketing
emails.
● Cookies. We may allow service providers and other third parties to use cookies and similar
technologies to track your browsing activity over time and across the Service and third party
websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in
your browser settings. Many browsers accept cookies by default until you change your settings.
Please note that if you set your browser to disable cookies, the Service may not work properly.
For more information about cookies, see above 1. Personal Information We Collect.
● Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the
online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To
find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
● Linked third-party calendars. If you choose to connect the Service through your third-party
calendar, you may be able to use your settings in your account with that platform to limit the
information we receive from it. If you revoke our ability to access information from a third-party
calendar or platform, that choice will not apply to information that we have already received from
that third party.
● Choosing not to share your personal information. Where we are required by law to collect your
personal information, or where we need your personal information in order to provide the Service
to you, if you do not provide this information when requested (or you later ask to delete it), we
may not be able to provide you with our services. We will tell you what information you must
provide to receive the Service by designating it as required at the time of collection or through
other appropriate means.
B. Individuals located in the UK
In the section below, we describe the rights and choices available to individuals located in the UK
● You can request deletion of your personal information.
● You can access, correct or update your personal information.
● You can object to processing of your personal information, ask us to restrict processing of your
personal information or request portability of your personal information.
● If we have collected and processed your personal information with your consent, then you can
withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
● You have the right to complain to a data protection authority about our collection and use of your
personal information. For more information, please contact your local data protection authority.
Contact details for data protection authorities in the UK are available here.
C. Individuals located in California
If you are a resident of California, please see the “Information for California Residents” section below
for more information about additional rights you may have regarding your personal information.
D. How to exercise your rights
If you would like to exercise your rights (for which we reserve the right to charge you a fee, where
permitted by applicable law), please contact us (see the "How to Contact Us" section below). We will
review and process your request in accordance with our obligations under applicable law.
5. Third Party Sites and Services
The Service may contain links to other websites and other online services operated by third parties.
These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us.
We do not control third party websites or online services, and we are not responsible for their actions.
Other websites and services follow different rules regarding the collection, use and sharing of your
personal information. We encourage you to read the privacy policies of the other websites and online
services you use.
6. Security Practices
The security of your personal information is important to us. We take a number of organizational,
technical and physical measures designed to protect the personal information we collect, both during
transmission and once we receive it. However, no security safeguards are 100% secure and we cannot
guarantee the security of your personal information.
7. International Data Transfers
Personal information we collect may be stored and processed in your region, in the United States or in
any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We
maintain primary data centers in the United States.
Therefore, we may transfer personal information from the UK to other countries that may not have the same level of data protection that applies in your jurisdiction.
8. Storage and Retention
We may retain your personal information for as long as necessary for the purposes it was collected, or for
other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing
our agreements. Because these needs can vary for different data types in the context of different
services, actual retention periods can vary significantly. We determine the appropriate retention period for personal information based on the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as applicable legal
requirements (such as applicable statutes of limitation).
After expiration of the applicable retention periods, your personal information will be deleted. If there is
any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in
place appropriate measures to prevent any further use of that data.
For further information on applicable data retention periods, please contact us (see "How to Contact Us" section below).
9. Children's Privacy
The Service is not directed at, and Say it Skillfully does not knowingly acquire or receive personal
information from, children under the age of 18. If we learn that any user of the Service is under the age of
18, we will take appropriate steps to delete that individual’s personal information and restrict that
individual from future access to the Services unless and until they reach the age of majority in the
jurisdiction where they reside. If you are a parent or guardian and you learn that your children under 18
have provided us with personal information, please contact us (see "How to Contact Us" section below).
10. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy from time to time. If we make any changes to this
Privacy Policy, we will post an amended version and update the "Last Updated" date above. We may also
provide notification of changes in another way that we believe is reasonably likely to reach you, such as
by posting a conspicuous notice on our Sites or via e-mail (if you have an account where we have your
contact information) or another manner through the Services.
Please review this Privacy Policy periodically. Any modifications to this Privacy Policy will be effective
upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the
posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy
Policy.
11. How to Contact Us
If you have any questions about this Privacy Policy, or if you wish to lodge a complaint about our privacy
practices, please email: [email protected] or contact via mail at:
In the United States, by registered mail:
555 Fayetteville Street, Suite 300 Raleigh NC 27601
0504-+1 (919) 576
12. Information for California Residents
This section applies only to users who are domiciled in California. It describes how we collect, use and
share Personal Information of California residents in operating our business, and their rights with respect
to that Personal Information. For purposes of this section, “Personal Information” has the meaning given
in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from
the scope of the CCPA.
Your California privacy rights. As a California resident, you have the rights listed below. However, these
rights are not absolute, and in certain cases we may decline your request as permitted by law.
● Information. You can request the following information about how we have collected and used
your Personal Information during the past 12 months:
● The categories of Personal Information that we have collected.
● The categories of sources from which we collected Personal Information.
● The business or commercial purpose for collecting and/or selling Personal Information.
● The categories of third parties with whom we share Personal Information.
● Whether we have disclosed your Personal Information for a business purpose, and if so,
the categories of Personal Information received by each category of third party recipient.
● Whether we’ve sold your Personal Information, and if so, the categories of Personal
Information received by each category of third party recipient.
● Access. You can request a copy of the Personal Information that we have collected about you
during the past 12 months.
● Deletion. You can ask us to delete the Personal Information that we have collected from you.
● Nondiscrimination. You are entitled to exercise the rights described above free from
discrimination in the form of legally prohibited increases in the price or decreases in the quality of
our Service.
How to exercise your rights
You may exercise your California privacy rights described above as follows:
● Right to information, access and deletion. You can request to exercise your information, access
and deletion rights by emailing us at [email protected]. We reserve the right to confirm
your California residence to process your requests and will need to confirm your identity to
process your requests to exercise your information, access or deletion rights. As part of this
process, government identification may be required. Consistent with California law, you may
designate an authorized agent to make a request on your behalf. In order to designate an
authorized agent to make a request on your behalf, you must provide a valid power of attorney,
the requester’s valid government-issued identification, and the authorized agent’s valid
government issued identification. We cannot process your request if you do not provide us with
sufficient detail to allow us to understand and respond to it.
● We do not sell your personal information. Based on our understanding of the term “sell” under the
CCPA, we do not “sell” your Personal Information and have not sold it to third parties for a
business or commercial purpose in the 12 months preceding the effective date of this Privacy
Policy.
Personal information that we collect, use and share
We are required to explain the categories of Personal Information we collect by reference to the
categories specified by the CCPA (in bold), as defined here, which are described in the list below. For
each category, we list the type of data we collect, and the source of that data as described in the section
above entitled “Personal Information We Collect.” We have not sold your personal information in the
preceding 12 months.
● Identifiers
● What we collect: Business contact data, profile data, registration data, communications
● Sources: You, business partners, nominations
● Commercial Information
● What we collect: Business contact data, profile data, registration data, online activity data
● Sources: You, business partners, automatic collection
● Financial Information
● What we collect: Financial data
● Sources: You
● Geolocation Data
● What we collect: Device data, precise geolocation data
● Sources: Automatic collection
● Online Identifiers
● What we collect: Business contact data, profile data, online activity data, device data
● Sources: You, automatic collection
● Internet or Network Information
● What we collect: Device data, online activity data
● Sources: Automatic collection
● Inferences drawn from any of the above information to create a profile reflecting your
preferences, characteristics, and behavior.
● May be derived from: Profile data, registration data, device data, online activity data
● Professional or Employment Information
● What we collect: Business contact data, profile data, registration data, professional and
employment data
● Sources: You
● Protected Classification Characteristics,
● What we collect: Registration data, may also be revealed in other data we collect
● Sources: You
The business/commercial purposes for which we use each category of Personal Information above are
described in the section above entitled “How We Use Your Personal Information.” The categories of third
parties to which we disclose each category of Personal Information above of Personal Information for
business purposes are described in the section above entitled “How We Share Your Personal
Information.”
The above summary of how we collect, use, share Personal Information describes our practices for the 12 months preceding the effective date at the bottom of this Privacy Policy. Information that you choose
to provide to us may include other categories of information
Shine the Light Law
Under California’s “Shine the Light” law (California Civil Code Section § 1798.83), California residents
who provide personal information in obtaining products or services for personal, family or household use
are entitled to request and obtain from us once a calendar year information about the customer
information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this
information would include the categories of customer information and the names and addresses of those
businesses with which we shared customer information for the immediately prior calendar year. To obtain
this information, please send an email message to [email protected] with “Request for California
Privacy Information” on the subject line and in the body of your message (see "How to Contact Us"
section below).
Effective Date: August 3, 2023