Skillapido

Privacy Policy

Effective Date: 27 March 2026

Last Updated: 26 March 2026

Operator: Skillapido (Sole Proprietorship)

Principal Place of Business: Not Applicable. As of 27 March 2026, we operate as a fully online platform. This will be updated if we decide to adopt a Hybrid Model in the future.

 

1. Introduction & Commitment to Privacy

 

Skillapido (“we,” “us,” “our,” or “Company”) is committed to protecting your privacy and ensuring transparency in how we collect, process, use, and safeguard your personal data. This Privacy Policy explains our data practices when you visit our website (https://skillapido.com), use our platform, purchase Rapid Action Micro-Guide (RAM) learning materials, or interact with our services.

 

We are a Data Fiduciary under India’s Digital Personal Data Protection Act, 2023 (hereinafter “DPDP Act”). We comply with the DPDP Act, its Rules (2025), and other applicable data protection laws, including GDPR, where applicable to international users.

 

Your privacy matters. We’ve designed this policy to be clear, transparent, and user-centric. If you have questions or concerns, please contact us (see Section 14).

 

2. Scope & Applicability

 

This Privacy Policy applies to:

 

  • Our website and all web-based services accessible through https://skillapido.com
  • Our mobile application (planned launch 2027)
  • Payment and transaction processing
  • Email communications and customer support
  • All personal data collected directly from you

Not covered by this policy:

 

  • Third-party websites linked from our platform (we are not responsible for their privacy practices)
  • Content you create or share on third-party platforms (e.g., social media), even if linking to Skillapido

Geographic scope: This policy complies with:

 

  • India (Primary): Digital Personal Data Protection Act, 2023 & Rules, 2025
  • EU/EEA (if applicable): General Data Protection Regulation (GDPR)
  • Other jurisdictions: Applicable local data protection laws 

3. Information We Collect

 

3.1 Categories of Personal Data

 

We collect only personal data that is necessary, lawful, and aligned with our stated purposes. Personal data includes any information that identifies you or can be used to identify you.

 

A. Identity & Account Information

 
 
 
Data Type
Purpose
Legal Basis
Full name
Account creation, RAM delivery, and customer support
Consent + Legitimate Use
Email address
Communication, notifications, and account recovery
Consent + Legitimate Use
Phone number (optional)
Support, account recovery, SMS notifications
Consent
Date of birth (if applicable)
Age verification (especially for users under 18)
Consent + Legal Compliance
Postal address (optional)
Delivery of physical materials, tax compliance
Consent

B. Authentication & Account Access

 
 
 
Data Type
Purpose
Legal Basis
Username & password (hashed)
Secure account access, authentication
Legitimate Use + Security
IP address
Account security, fraud prevention, and login tracking
Legitimate Use + Security
Device information (device ID, browser type, OS)
Security, platform compatibility testing
Legitimate Use + Security
Login timestamps & patterns
Fraud detection, unusual activity alerts
Legitimate Use + Security

C. Payment & Transaction Information

Data Type
Purpose
Legal Basis
Payment method (card type, last 4 digits)
Processing purchases, invoicing
Consent + Legal Compliance
Transaction history (date, amount, RAM purchased)
Billing records, refund processing, analytics
Consent + Legal Compliance
Billing address
Tax compliance, fraud prevention
Legal Compliance
Financial information (GST ID if applicable)
Tax compliance, invoicing
Legal Compliance

Note: We do NOT store full credit card numbers. Payment processing is handled by PCI-DSS compliant third-party processors (detailed in Section 5).

 

D. Learning & Usage Data

Data Type
Purpose
Legal Basis
RAMs purchased & download history
Service delivery, personalized recommendations
Consent + Legitimate Use
Learning progress (quiz scores, completion status)
Service improvement, personalized learning paths
Consent
Content preferences & browsing behavior
Analytics, content recommendations
Consent
Time spent on each RAM format
Platform optimization, UX improvement
Consent
Device access logs (which formats accessed, when)
Security, usage analytics
Legitimate Use

E. Communication & Support Data

 
 
 
Data Type
Purpose
Legal Basis
Support tickets & chat transcripts
Customer service, complaint resolution
Consent + Legitimate Use
Email communications
Support tracking, issue resolution
Consent + Legitimate Use
Feedback, surveys, & user reviews
Product improvement, content enhancement
Consent
Grievance & complaint records
Grievance redressal, regulatory compliance
Legal Compliance

F. Marketing & Preference Data

 
 
 
Data Type
Purpose
Legal Basis
Marketing consent status
Email marketing, promotional offers
Explicit Consent (Opt-in)
Newsletter subscription
Regular updates, new RAM releases
Explicit Consent (Opt-in)
Preferred communication channels
Tailored outreach (email, SMS, in-app)
Consent
Content interests & learning goals
Personalized recommendations
Consent

G. Technical & Analytics Data

 
 
 
Data Type
Purpose
Legal Basis
Website cookies & tracking pixels
Analytics, user behavior, platform improvement
Consent (with opt-out option)
Analytics data (Google Analytics, similar tools)
Traffic patterns, feature usage, engagement
Consent + Legitimate Use
Error logs & crash reports
Platform stability, bug fixes
Legitimate Use
Referral source (how you found Skillapido)
Marketing effectiveness, attribution
Legitimate Use

H. Special Category Data (If Applicable)

 

We do NOT intentionally collect special category data (health, religion, caste, sexual orientation, biometric data) except where necessary and with explicit consent. If you share this data in feedback or support, we’ll handle it with heightened security and use it only to address your specific concern.

 

3.2 Data Collection Methods

 

Direct Collection:

 

  • User registration and account creation
  • Purchase transactions
  • Support requests and feedback
  • Survey responses
  • Newsletter subscriptions

Automated Collection:

 

  • Cookies, web beacons, and similar tracking technologies (see Section 8)
  • Server logs and IP addresses
  • Device and browser information
  • Usage analytics

From Third Parties:

 

  • Payment processors (transaction confirmation only)
  • Email service providers (for delivery confirmation)
  • Analytics platforms (anonymised, aggregated data only)

3.3 Information You Are NOT Required to Provide

 

Certain data fields are optional. Declining to provide optional information will not prevent you from using the platform, though it may limit some features (e.g., without a phone number, SMS notifications won’t be available).

 

Mandatory data (required for account creation and transactions):

 

  • Full name
  • Email address
  • Payment information (if purchasing)

All other data is optional and collected only with your explicit consent.

 

4. Purpose Limitation: How We Use Your Data

 

We use your personal data ONLY for the following lawful purposes:

 

4.1 Service Delivery (Primary Purpose)

 

  • Creating and managing your user account
  • Delivering RAM learning materials in all 6 formats (PDF, video, slides, audio, infographic, quiz)
  • Processing purchases and issuing invoices
  • Sending order confirmations and download links
  • Managing subscriptions and bundles
  • Providing customer support and technical assistance
  • Tracking your learning progress (if you opt-in)

4.2 Security & Fraud Prevention

 

  • Detecting and preventing fraudulent transactions
  • Monitoring for unauthorised account access
  • Protecting against malicious activity (DDoS, hacking attempts)
  • Enforcing our Terms of Service
  • Complying with legal obligations (court orders, law enforcement requests)

4.3 Platform Improvement & Analytics

 

  • Analysing user behaviour to improve platform design and functionality
  • Identifying popular RAMs and engagement patterns
  • Testing new features (beta testing with explicit consent)
  • Fixing bugs and improving performance
  • Personalising learning recommendations based on your interests
  • Conducting satisfaction surveys and gathering user feedback

4.4 Communication & Marketing (With Consent Only)

 

  • Sending newsletter updates about new RAMs and skill releases
  • Promotional emails and special offers (only if you’ve opted in)
  • Important account notifications (password resets, security alerts)
  • Responses to your inquiries and support requests
  • Occasionally inviting you to participate in product research or beta features

You have full control over marketing communications. See Section 11 for opt-out options.

 

4.5 Legal & Compliance Obligations

 

  • Complying with the DPDP Act, Rules, and other applicable laws
  • Responding to legal process (court orders, government requests)
  • Tax and financial reporting
  • Record-keeping for regulatory audits
  • Enforcing contracts and resolving disputes

4.6 Business Intelligence & Product Development

 

  • Aggregated analytics (anonymised, non-identifiable) to understand market trends
  • Identifying which skills are in demand
  • Planning new RAM categories and content
  • Benchmarking platform performance against industry standards

We will NOT use your data for any purpose outside this list without obtaining your additional explicit consent.

 

5. Data Sharing & Third Parties

 

We are committed to data minimisation—we share your data only when necessary and with strict contractual protections.

 

5.1 Service Providers & Data Processors

 

We engage third-party vendors who process your data on our behalf and under our instructions. They are contractually bound to maintain confidentiality and use data only for the purposes we specify.

 
 
 
 
Service Type
Examples
Data Shared
Legal Basis
Payment Processing
Razorpay, PayU, Stripe
Transaction amount, card last 4 digits (tokenised), billing address
Contractual obligation + PCI-DSS compliance
Email Delivery
SendGrid, AWS SES
Email address, name, RAM download link
Service delivery
Analytics
Google Analytics, Mixpanel
Anonymised usage data, referral source (no PII)
Analytics for improvement
Customer Support
Zendesk, Freshdesk
Support ticket content (excluding sensitive data)
Service delivery + Legitimate use
Cloud Hosting
AWS, Google Cloud
Account data, learning records (encrypted)
Service delivery
Legal/Tax
Chartered accountants, law firms
Aggregated transaction data, GST compliance
Legal compliance

All processors are bound by Data Processing Agreements (DPAs) that enforce:

 

  • DPDP Act compliance
  • Confidentiality obligations
  • Security standards (encryption, access controls)
  • Limited retention periods
  • Sub-processor restrictions

5.2 Educational Institutions & Corporate Partners [Planned Feature]

 

If you purchase a corporate license or if your educational institution uses Skillapido RAMs, we may share aggregated learning analytics with your institution’s administrator (e.g., completion rates, most-used RAMs) only with your explicit consent or your institution’s authorisation. We will NOT share individual assessment data without your consent.

 

5.3 Legal Disclosures

 

We may disclose your personal data when legally required:

 

  • Court orders or subpoenas: If compelled by a court of law
  • Law enforcement requests: To comply with police investigations, DPDP Board notices
  • Government authorities: To fulfil statutory obligations (tax, financial regulations)
  • Business transfers: In the event of a merger, acquisition, or sale (with advance notice to you)

We will resist unreasonable requests and notify you of legal demands unless prohibited by law.

 

5.4 NO SALE OF PERSONAL DATA

 

We explicitly do NOT sell, rent, or trade your personal data to marketing firms, data brokers, or advertisers. Your data is not a commodity.

 

5.5 User-Generated Content & Public Sharing

 

If you choose to post reviews, testimonials, or feedback on our platform, that content may be publicly visible. We will identify you only as your registered name (or anonymously if you prefer). You control what you share publicly.

 

6. Data Retention: How Long We Keep Your Data

 

We retain personal data only as long as necessary for the purposes outlined in Section 4. Here’s our retention schedule:

 
 
 
Data Category
Retention Period
Justification
Account information (name, email, address)
Until account deletion + 1 year
Legal obligation under the DPDP Act, for dispute resolution
Password & login credentials
Until account deletion
Account security
Payment & transaction records
7 years
Indian tax law (GST, Income Tax); invoice records
Learning progress & RAM history
Until account deletion + 1 year
Service improvement, user rights (access to data)
Support tickets & grievance records
2 years after resolution
Regulatory compliance: evidence for disputes
Marketing communication logs
Until consent withdrawn + 6 months
Spam prevention, demonstrating consent
Technical logs (IP, login timestamps)
30 days
Security, fraud prevention
Analytics data (anonymised)
Indefinite
No PII, cannot identify individuals
Cookies & tracking data
Per your settings, max 1 year
User analytics, personalisation

6.1 Early Deletion

 

You may request deletion of your data at any time (see Section 12 for the Right to Erasure). Upon deletion:

 

  • We remove all personal identifiers and link them to a generic reference code
  • Account data is retained only as required by law (e.g., for tax audits)
  • Learning records are anonymised and retained for product improvement

6.2 Tamper-Proof Logs

 

Under the DPDP Act, we maintain one-year tamper-proof logs of all data access, processing, and sharing events for audit and compliance purposes. These logs are encrypted and accessible only to authorised personnel.

 

7. Data Security: How We Protect Your Information

 

We implement appropriate technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction.

 

7.1 Encryption

 

  • Data in Transit: All data transmitted between your device and our servers is encrypted using TLS 1.3 (industry standard)
  • Data at Rest: Sensitive data (passwords, payment info, learning records) is encrypted using AES-256 encryption
  • Database encryption: All databases are encrypted with encryption keys managed separately from the database itself

7.2 Access Controls

 

  • Role-Based Access Control (RBAC): Only authorised employees can access personal data, and only the data necessary for their role
  • Multi-factor authentication (MFA): Employees use MFA for system access
  • Principle of least privilege: No employee has access to all data; access is strictly limited
  • Admin accounts: Monitored separately with additional security protocols

7.3 Infrastructure Security

 

  • Firewalls & intrusion detection: Network-level monitoring to prevent unauthorised access
  • DDoS protection: Distributed denial-of-service attack mitigation
  • Regular penetration testing: Third-party security audits to identify vulnerabilities
  • Secure servers: Hosted on PCI-DSS compliant cloud infrastructure (AWS, Google Cloud)
  • Automatic backups: Encrypted backups stored in geographically separate locations for disaster recovery

7.4 Employee & Vendor Security

 

  • Data protection training: All employees complete privacy and security training
  • Confidentiality agreements: All staff sign NDAs
  • Vendor audit: Third-party vendors undergo security assessments before onboarding
  • Vendor contracts: All contracts include strict data security and confidentiality clauses

7.5 Secure Password Practices

 

  • Password storage: User passwords are hashed using bcrypt (one-way hashing; we cannot even see your password)
  • No password retrieval: We cannot recover your password; you can reset it via email
  • Session management: Login sessions expire after inactivity; you’re logged out for your protection

7.6 Limitations

 

While we implement robust security, no system is 100% secure. We cannot guarantee absolute protection against sophisticated cyberattacks. However, we are committed to responding rapidly to breaches (see Section 9).

 

8. Cookies & Tracking Technologies

 

8.1 What Are Cookies?

 

Cookies are small text files stored on your device when you visit our website. They help us remember your preferences, keep you logged in, and improve your experience.

 

8.2 Types of Cookies We Use

 
 
 
 
Cookie Type
Purpose
Duration
Your Control
Essential Cookies
Account login, session management, and CSRF protection
Session or 1 year
Cannot disable (required for platform function)
Performance Cookies
Analytics (page load times, error tracking)
1-2 years
Can opt out via browser or our settings
Preference Cookies
Remembering your language, theme (dark/light mode), learning format preferences
1 year
Can manage in account settings
Marketing Cookies
Tracking which pages you visit (if you consent to marketing)and 
1-2 years
Opt-out in account settings or cookie banner
Third-Party Cookies
Google Analytics, Facebook Pixel (if enabled)
Per service terms
Disable in-browser privacy settings

8.3 Your Cookie Choices

 

On Your First Visit: A cookie consent banner appears. You can:

 

  • Accept All: All cookies enabled (recommended for full feature access)
  • Essential Only: Only essential cookies; analytics and marketing disabled
  • Customise: Pick and choose which categories to enable

After Initial Consent: You can change your cookie preferences at any time in your account settings (Account → Privacy Settings → Cookie Preferences).

 

Browser-Level Controls:

 

  • Most browsers allow you to block or delete cookies
  • Disabling cookies may limit platform functionality (e.g., you may need to log in repeatedly)
  • See your browser’s help documentation for specific instructions

8.4 Do Not Track (DNT)

 

If your browser sends a “Do Not Track” signal, we respect it. However, third-party analytics services may not. You can control their data collection via their privacy settings.

 

8.5 Tracking Pixels & Web Beacons

 

We may use tracking pixels (invisible 1×1 images) in emails and on our website to:

 

  • Track email open rates (to improve email communication)
  • Measure conversion funnels (did you purchase after clicking an email link?)
  • Monitor webpage engagement

You can disable pixel tracking by:

 

  • Disabling images in your email client
  • Using email privacy plugins
  • Opting out of marketing communications

9. Data Breach Notification & Incident Response

 

9.1 Our Breach Response Protocol

 

A breach is any unauthorised access, disclosure, alteration, or destruction of personal data. We take breaches very seriously.

 

If a breach occurs, we will:

 

  • Immediate Response (within 24 hours):
  • Contain the breach (shut down compromised systems, revoke access)
  • Preserve evidence for investigation
  • Notify senior management and our Data Protection Officer
  • Investigation (within 72 hours):
  • Determine which data was compromised
  • Identify affected users
  • Assess the risk and impact to individuals
  • Document the incident comprehensively
  • Regulatory Notification (within 72 hours of discovery):
  • Notify the Data Protection Board of India (DPBI) as mandated by Section 8 of the DPDP Act
  • Provide incident details, data affected, and remedial measures taken
  • User Notification (within 7 days):
  • Send written notice to affected individuals via email (at minimum)
  • Clearly describe what happened, which data was compromised, and the risks
  • Provide mitigation steps (change password, monitor account, etc.)
  • Include our contact details for questions

9.2 Incident Report Contents

 

Breach notifications will include:

 

  • What happened: Clear description of the incident (hacking, data loss, employee negligence, etc.)
  • When it occurred: Date and time of discovery
  • Which data was affected: Specific types of data compromised (email, password, payment info, etc.)
  • How many people: Number of affected data principals
  • Risk assessment: What could happen if data is misused?
  • Remedial steps: What are we doing to prevent recurrence?
  • Your actions: Steps you should take to protect yourself
  • Contact information: How to reach us with questions or concerns

9.3 No Unnecessary Alarm

 

We distinguish between actual breaches and potential vulnerabilities:

 

  • A breach requires notification (unauthorised access actually occurred)
  • A vulnerability (e.g., a security researcher finds a potential flaw) is addressed, but may not trigger mandatory notification if no data was actually accessed

9.4 Insurance & Liability

 

Skillapido maintains cyber liability insurance to cover damages in case of a breach. If you suffer verifiable harm as a result of our negligence, we are committed to working toward a fair resolution.

 

10. Legal Bases for Processing (DPDP Act & GDPR)

 

We process your personal data under the following legal bases:

 

10.1 Consent

 

Where you explicitly opt-in:

 

  • Creating a user account
  • Subscribing to newsletters
  • Marketing emails and promotional offers
  • Optional analytics and personalisation features

You can withdraw your consent at any time (see Section 11).

 

10.2 Contractual Necessity

 

Where processing is necessary to fulfil a contract with you:

 

  • Processing your purchase and delivering RAMs
  • Sending order confirmations and invoices
  • Providing customer support
  • Managing your subscription

10.3 Legal Compliance

 

Where we’re required by law:

 

  • Tax and financial record-keeping (GST, Income Tax)
  • Responding to court orders or government requests
  • Anti-money laundering (AML) compliance
  • Fraud prevention and investigation

10.4 Legitimate Interest

 

Where we have a justified business interest that doesn’t override your rights:

 

  • Platform security and fraud prevention
  • Analytics and product improvement
  • Troubleshooting technical issues
  • Defending against legal claims

10.5 Special Provisions for Children’s Data (DPDP Act Section 9)

 

Our platform is intended for users aged 18 and above.

 

If you are under 18:

 

  • We require verifiable parental consent before processing your data
  • We will not use your data for marketing or behavioural profiling
  • Your parent/guardian has the right to request access, correction, or deletion
  • We conduct no harm assessment before collecting data from minors

How we verify age:

 

  • Self-declared age at registration
  • Government ID verification (for sensitive operations)
  • Virtual tokens or Digi Locker verification (if available)

If a minor’s data is collected without parental consent, we delete it immediately upon discovery.

 

11. Your Rights as a Data Principal (DPDP Act & GDPR)

 

The DPDP Act and GDPR grant you seven fundamental rights regarding your personal data:

 

11.1 Right to Access (Section 12 of DPDP Act)

 

You have the right to know what data we hold about you.

 

How to exercise:

 

  • Email us at privacy@skillapido.com with subject line “Data Access Request”
  • We will provide your data in a machine-readable format (JSON or CSV) within 30 days

What you’ll receive:

 

  • All personal data we hold about you
  • Categories of data and purposes for processing
  • Recipients of your data
  • Retention periods

11.2 Right to Correction (Section 13 of DPDP Act)

 

You have the right to correct inaccurate or incomplete data.

 

How to exercise:

 

  • Log into your account → Profile → Edit Details
  • Or email us at privacy@skillapido.com with the corrections you request
  • We will update your data and confirm within 7 days

Example: If your email address is misspelt, you can correct it.

 

11.3 Right to Erasure (“Right to Be Forgotten”)

 

You have the right to request deletion of your personal data.

 

How to exercise:

 

  • Email us at privacy@skillapido.com with subject line “Data Deletion Request”
  • We will confirm receipt and begin deletion within 7 days

Important exceptions (data we may retain despite deletion requests):

 

  • Tax/financial records: We retain for 7 years (legal requirement)
  • Legal proceedings: If you’re involved in a dispute, we retain as evidence
  • Fraud investigation: If you’re suspected of misusing the platform
  • Aggregated/anonymised data: Cannot identify you, so continues to be used

After deletion:

 

  • Your account is permanently closed
  • You lose access to purchased RAMs (though you may retain downloaded files)
  • We cannot reactivate your account

11.4 Right to Withdraw Consent

 

You can withdraw consent for any processing at any time.

 

How to exercise:

 

  • Email us at privacy@skillapido.com stating which consents to withdraw
  • Use the “Unsubscribe” link at the bottom of any marketing email

Effect of withdrawal:

 

  • Marketing emails stop immediately
  • Preference data collection stops
  • Some platform features may be unavailable (e.g., personalised recommendations)
  • Withdrawal does NOT affect past processing (already lawful)

11.5 Right to Data Portability

 

You have the right to receive your data in a portable, machine-readable format and transfer it to another service.

 

How to exercise:

 

  • Email privacy@skillapido.com with subject “Data Portability Request”
  • We’ll provide data in CSV, JSON, or other structured format within 30 days

Included data:

 

  • Account information
  • Learning progress and quiz scores
  • Purchase history
  • Preferences and settings

Data NOT portable: Third-party analytics data (anonymised, cannot be linked to you)

 

11.6 Right to Grievance Redressal (Section 14 of DPDP Act)

 

If you have a privacy concern or feel your rights have been violated, you have the right to lodge a grievance.

 

How to exercise:

 

  • Email us at grievance@skillapido.com with a detailed description
  • We will acknowledge receipt within 7 days and investigate within 30 days

Escalation: If you’re unsatisfied with our response, you can escalate to the Data Protection Board of India (DPBI) after we’ve had 60 days to respond.

 

11.7 Right to Nominate

 

Under the DPDP Act, you can nominate someone (e.g., a family member or lawyer) to exercise your rights after you pass away.

 

How to exercise:

 

  • Email us at privacy@skillapido.com with your nominee’s details and a legal document (will, power of attorney, etc.)
  • Your nominee can then request access, correction, or deletion after your passing

12. Consent Management

 

12.1 How We Obtain Consent

 

Consent is only valid if it is:

 

  • Specific: Clearly describing what data will be processed and why
  • Informed: You understand the purpose and consequences
  • Freely given: No pressure, conditions, or false choices
  • Granular: We don’t require consent for unrelated purposes (e.g., analytics consent doesn’t include marketing)
  • Affirmative: Requires your positive action (clicking “I agree”), not pre-checked boxes

12.2 Consent for Different Purposes

 

You can independently control:

 
 
 
Purpose
Default
How to Manage
Service Delivery
Mandatory (to use the platform)
N/A – required
Essential Analytics
On
Settings → Analytics
Personalisation
On (optional)
Settings → Personalisation
Marketing Emails
Off (opt-in only)
Email unsubscribe or Settings → Marketing
SMS Notifications
Off (opt-in only)
Settings → SMS Preferences
Cookies
Per your choice
Cookie banner

12.3 Pre-Checked Boxes & Dark Patterns

 

We strictly prohibit:

 

  • Pre-checked consent boxes (you must actively check to consent)
  • Conditional consent (e.g., “accept all cookies or we won’t let you use the site”)
  • Unclear default settings
  • Buried consent in long terms

What you’ll see: Clear, simple language with obvious “Accept” and “Reject” buttons of equal prominence.

 

12.4 Record of Consent

 

We maintain a digitally signed record of your consent, including:

 

  • Date and time you consented
  • Exact text you consented to
  • IP address and device type
  • Which consents you gave/refused

This protects both you (proof of what you agreed to) and us (evidence of compliance).

 

13. Cross-Border Data Transfers

 

Skillapido is based in India. However, we may transfer your data internationally in the following scenarios:

 

13.1 Where Data May Be Transferred

 

  • Cloud hosting: Your data is stored on India-based servers. However, when we expand internationally, your data may be stored on servers in the US, EU, or Singapore (AWS, Google Cloud)
  • Third-party processors: Email services, analytics tools, and payment processors may be located outside India
  • International users: If you’re accessing from outside India, data is processed globally

13.2 Legal Basis for Transfers

 

Under the DPDP Act, we may transfer data outside India if:

 

  • You explicitly consent to international transfer, OR
  • The receiving country has been notified by the government as having adequate data protection, OR
  • We implement “appropriate safeguards” (e.g., Standard Contractual Clauses under GDPR)

13.3 Receiving Countries’ Laws

 

Important: Data transferred outside India may be subject to different privacy laws. The US, for example, has weaker data protection than India’s Data Protection and Privacy Policy Act. However, we ensure:

 

  • Data is encrypted in transit and at rest
  • Data processors are contractually bound to the DPDP Act standards
  • You can request that data not be transferred (though this may limit services)

13.4 Your Right to Restrict Transfers

 

If you don’t want your data transferred outside India, email privacy@skillapido.com.

 

14. Contact Information & Grievance Redressal

 

14.1 Privacy Officer & Data Protection Officer

 

Data Protection Officer (DPO): Appointed under the DPDP Act to oversee compliance

 

Contact: privacy@skillapido.com

 

Privacy Officer: Responsible for day-to-day privacy matters

 

Contact: privacy@skillapido.com

 

14.2 How to Reach Us

 

Email Queries:

 

Postal Address:

 

Not Applicable. As of 27 March 2026, we operate as a fully online platform. This will be updated if we decide to adopt a Hybrid Model in the future.

 

Response Times:

 

  • Privacy inquiries: Within 5 business days
  • Grievances: Acknowledged within 7 days; investigated within 30 days
  • Data Subject Rights: Within 30 days (extendable to 60 days if complex)

14.3 Escalation to Regulatory Authorities

 

If we don’t satisfactorily resolve your concern, you can escalate to:

 

Data Protection Board of India (DPBI):

 

  • Established under the DPDP Act, 2023
  • Investigates complaints against Data Fiduciaries
  • Can impose penalties up to ₹250 crore for violations
  • Website: https://www.dpbi.gov.in (Note: DPBI establishment timeline may vary)

European Data Protection Authorities (if you’re in the EU):

 

  • You have the right to lodge a complaint with your national data protection authority
  • Example: Ireland’s Data Protection Commission (if accessing from the EU)

15. Data Protection Impact Assessment (DPIA)

 

Skillapido processes learning data at scale. We conduct Data Protection Impact Assessments (DPIAs) for high-risk processing:

 

15.1 When We Conduct DPIAs

 

  • Introduction of new data collection (e.g., biometric authentication)
  • Changes to learning analytics (e.g., behavioural profiling)
  • New third-party integrations
  • Use of automated decision-making (algorithmic recommendations)

15.2 DPIA Contents

 

Our DPIAs examine:

 

  • Purpose and necessity of data collection
  • Risk to individuals’ rights and freedoms
  • Safeguards and risk mitigation measures
  • Stakeholder consultation (user feedback)

15.3 Your Right to Know

 

You can request a summary of our DPIA for any processing that may affect you. Email privacy@skillapido.com with “DPIA Request” in the subject line.

 

16. Algorithmic Decision-Making & Automated Processing

 

Skillapido uses automated processes in limited cases:

 

16.1 How We Use Automation

 

  • RAM Recommendations: Suggesting skills based on your purchase history and learning profile
  • Fraud Detection: Flagging suspicious purchases or login patterns
  • Quiz Scoring: Automated grading of knowledge checks

16.2 Your Rights

 

You have the right to:

 

  • Understand the logic: How the algorithm works (general explanation)
  • Contest the decision: If automated fraud flagging locks your account, you can appeal
  • Opt-out: Request manual review instead of automated processing (may incur delay)

16.3 No Purely Automated Decisions with Legal Effect

 

We do NOT use algorithms to make decisions that have legal or significant effects (e.g., permanently banning your account) without human review.

 

17. Compliance with Additional Laws

 

17.1 GDPR Compliance (For EU Users)

 

If you’re located in the EU/EEA:

 

  • Additional GDPR rights apply (e.g., Right to Restrict Processing)
  • We conduct impact assessments for international transfers
  • You can lodge complaints with your national data protection authority

17.2 CCPA Compliance (For California Users)

 

If you’re located in California:

 

  • You have rights to know, delete, and opt out of sale (though we don’t sell data)
  • We provide a “Do Not Sell My Personal Information” link

17.3 COPPA Compliance (For Minors Under 13)

 

  • We do NOT knowingly collect data from users under 13
  • If discovered, we immediately delete and notify authorities/parents/guardians

18. Cookies: Additional Details (See Cookie Policy page for details)

 

18.1 Essential Cookies

 
 
 
Cookie Name
Purpose
Duration
session_id
Keeps you logged in
Session (or 30 days with “Remember Me”)
csrf_token
Prevents cross-site attacks
Session
preferences
Saves your language, theme
1 year

18.2 Third-Party Services

 

Google Analytics:

 

Payment Processors (Razorpay, PayU):

 

  • Store tokenised payment data
  • We never see full card numbers
  • Policy: Check respective processor privacy policies

19. Changes to This Privacy Policy

 

Skillapido may update this Privacy Policy to reflect changes in law, technology, or our practices.

 

19.1 How We Notify You

 

  • Material changes: We’ll email you at least 30 days before changes take effect
  • Minor changes: Updates to links, formatting, or clarifications may be posted without notice
  • Continued use: Using the platform after notification means you accept the changes

19.2 What Constitutes “Material Changes.”

 

Material changes include:

 

  • New data collection practices
  • Expanded sharing with third parties
  • Reduced retention periods
  • Weakening of security measures
  • New purposes for using your data

Non-material changes (can update without notice):

 

  • Contact information updates
  • Clarifications of existing practices
  • Legal name changes
  • Link corrections

19.3 Your Version Control

 

We maintain a change log showing all modifications since the policy’s inception. Email privacy@skillapido.com to request the full history.

 

20. Summary of Key Rights & Actions

 

Quick reference for your privacy rights:

 
 
 
Right
How to Exercise
Timeline
Access your data
30 days
Correct errors
Account → Edit Profile, or email corrections
7 days
Delete your account
Email privacy@skillapido.com
7 days to start process
Withdraw consent
Email or click Unsubscribe
Immediate
Export data
Email privacy@skillapido.com
30 days
Lodge a grievance
30 days investigation
Opt-out of marketing
Click unsubscribe link or Settings → Marketing
Immediate
Change cookie settings
Account → Privacy Settings → Cookies
Immediate

21. Glossary of Terms

 
 
Term
Definition
Data Fiduciary
Organisation that determines the purpose and means of data processing (Skillapido)
Data Principal
You, the individual whose data is being processed
Personal Data
Information that identifies you or can be used to identify you
Processing
Any action taken with personal data (collection, storage, use, sharing, deletion)
Consent
Your explicit, informed, freely given permission for a specific purpose
Breach
Unauthorised access, disclosure, or loss of personal data
DPIA
Data Protection Impact Assessment: evaluates risks of high-risk processing
DPO
Data Protection Officer; oversees DPDP Act compliance
Anonymised Data
Data that cannot be linked back to you (no longer personal data)
Pseudonymised Data
Data linked to you via a code can be re-identified with additional info

22. Acknowledgement & Acceptance

 

By using the Skillapido platform, you acknowledge that:

 

  • You have read and understood this Privacy Policy
  • You consent to our collection and processing of your personal data as described
  • You understand your rights and how to exercise them
  • You agree to our data practices and security measures

If you DO NOT agree, please DO NOT use Skillapido. Contact us at hello@skillapido.com with the subject “I Do Not Agree” if you have concerns.

 

23. Final Note: Your Privacy Matters

 

At Skillapido, your privacy isn’t an afterthought—it’s foundational to who we are. We’re committed to:

 

  • Transparency: Clear, honest communication about our practices
  • User control: You decide what data we collect and how we use it
  • Security: Protecting your data with industry-leading safeguards
  • Compliance: Adhering to DPDP Act, GDPR, and all applicable laws
  • Accountability: Taking responsibility for privacy breaches and user harm

 

If you have questions, suggestions, or concerns about our privacy practices, we want to hear from you. Contact our Privacy Officer at privacy@skillapido.com.