Thank you for joining our innovative online DeFi learning platform. We at DeFi Skills with the website address https://defiskills.io, holded and controlled by Daniil Maslov, 16 Zaikina, Zelenodolsk, Russia (“DeFi Skills”, “we”, “us”, “our”) respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the DeFi Skills websites and/or related services (the “Services”). It also applies to prospective customers of our business and enterprise products.

By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

1.   What Data We Get

We collect certain data from you directly, like information you enter yourself, data about your consumption of content, and data from third-party platforms you connect with DeFi Skills. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.

1.1.   Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.

When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:

• Account Data: In order to use certain features (like accessing content), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, gender, verification photo, age, date of birth, and account settings and assign you a unique identifying number;
• Profile Data: You can also choose to provide profile information like a photo, headline, biography, language, website link, social media profiles, country, or other data. Your Profile Data will be publicly viewable by others;
• Shared Content: Parts of the Services let you interact with other users or share content publicly, including by posting reviews about content, asking or answering questions, sending messages, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted;
• Educational Content Data: When you access content, we collect certain data, including which courses, assignments, labs, workspaces, and quizzes you’ve started and completed; completion certificates; answers to questions, and other items submitted to satisfy course and related content requirements;
• Data About Your Accounts on Other Services:We may obtain certain information through your social media or other online accounts if they are connected to your DeFi Skills account. If you login to DeFi Skills via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday, and list of friends or contacts. Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
• Sweepstakes, Promotions, and Surveys:We may invite you to complete a survey or participate in a promotion (like a contest, sweepstakes, or challenge), either through the Services or a third-party platform. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, postal address, date of birth, or phone number. That data is subject to this Privacy Policy unless otherwise stated in the official rules of the promotion or in another privacy policy. The data collected will be used to administer the promotion or survey, including for notifying winners and distributing rewards. To receive a reward, you may be required to allow us to post some of your information publicly (like on a winner’s page). Where we use a third-party platform to administer a survey or promotion, the third party’s privacy policy will apply.
• Communications and Support:If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, messages, location, DeFi Skills user ID, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.

The data listed above is stored by us and associated with your account.

1.2.   Data We Collect Through Automated Means

When you access the Services (including browsing content), we collect certain data by automated means, including:

• System Data: Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types;
• Usage Data: Usage statistics about your interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services;
• Approximate Geographic Data: An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.

1.3.   Data Retention Period

We maintain your personal data exclusively within the time needed to follow prescribed herein legal or business purposes. When we no longer need your personal data, we securely delete or destroy it. Aggregated data, which cannot identify a device/browser (or individual) and are used for purposes of reporting and analysis, are maintained for as long as commercially necessary.

Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. Reasons we might retain some data for longer periods of time include:

• Security, fraud & abuse prevention.
• Financial record-keeping.
• Complying with legal or regulatory requirements.
• Ensuring the continuity of our Services.

1.4.   International Transfers

We are entitled to transfer your personal or non-personal data to third parties abroad for the purposes of the data processing. As personal data processors, they are obliged to protect data privacy to the same extent as we do. We choose the processors carefully to ensure compliance with applicable laws.

1.5.   Supervisor Authority Oversight

If you are a data subject whose data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states. Here you can find a list of data protection authorities in Europe.

2.   How We Get Data About You

We use tools like cookies, web beacons, and similar tracking technologies to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

2.1.   Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on DeFi Skills. They allow us to remember things about your visits to DeFi Skills, like your preferred language, and to make the site easier to use. To learn more about cookies, visit https://cookiepedia.co.uk/all-about-cookies.

DeFi Skills and service providers acting on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.

2.2.   Why We Use Data Collection Tools

DeFi Skills uses the following types of Data Collection Tools for the purposes described:

Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.

Functional:These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services (like your preferred language or volume level for video playback).

Performance:These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of DeFi Skills to see which features or content users prefer and determine which email messages are opened.

Advertising:These Data Collection Tools are used to deliver relevant ads (on the site and/or other sites) based on things we know about you like your Usage and System Data (as detailed in Section 1), and things that the ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.

Social Media:These Data Collection Tools enable social media functionality, like sharing content with friends and networks. These cookies may track a user or device across other sites and build a profile of user interests for targeted advertising purposes.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.2 (Your Choices About the Use of Your Data) below.

3.   What We Use Data For

We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity.

We use the data we collect through your use of the Services to:

• Provide and administer the Services, including to facilitate participation in educational content, issue completion certificates, display customized content, and facilitate communication with other users;
• Process your requests and orders for educational content, products, specific services, information, or features;
• Communicate with you about your account by:

- Responding to your questions and concerns;

- Sending you administrative messages and information; notifications about changes to our Service; and updates to our agreements;

- Sending you information, such as by email or text messages, about your progress in courses and related content, rewards programs, new services, new features, promotions, newsletters, and other available instructor-created content (which you can opt out of at any time);

- Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of the mobile app);

• Manage your account and account preferences;
• Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
• Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers;
• Identify unique users across devices;
• Tailor advertisements across devices;
• Improve our Services and develop new products, services, and features;
• Analyze trends and traffic, track purchases, and track usage data;
• Advertise the Services on third-party websites and applications;
• As required or permitted by law; or
• As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.

4.   Who We Share Your Data With

We share certain data about you with companies and persons who may provide educational programs which you joined on our platform, other students, companies performing services for us, DeFi Skills affiliates, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

• With Companies and Persons Who May Provide Educational Programs Which You Joined on Our Platform: We share data that we have about you with instructors or teaching assistants for educational content you access or request information about, so they can improve their content for you and other students. This data may include things like your browser language, operating system, device settings, the site that brought you to DeFi Skills, and your activities on DeFi Skills. If we collect additional data about you (like age or gender), we may share that too. We will not share your email address with instructors or teaching assistants.
• With Other Students and Program Providers: Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and instructors. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable.
• With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
• With DeFi Skills Affiliates: We may share your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services.
• With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics, we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 1), or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
• To Power Social Media Features: The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.
• To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
• For Advertising: If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising), and to undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioral advertising, see Section 6.2 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads.
• For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:

- Permitted or required by law;

- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;

- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;

- Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;

- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or

- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of DeFi Skills, our users, employees, members of the public, or our Services.

- We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.

• During a Change in Control: If DeFi Skills undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
• After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.
• With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy.

5.   Security

We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.

DeFi Skills takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and DeFi Skills, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact us with any concerns.

6.   Your Rights

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain third parties. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.

6.1.   Your GDPR Rights

Under certain circumstances, you may have a number of privacy rights concerning the use, storage, and processing of your personal data (e.g., the right to delete your data). Here is a list of privacy rights:

• right to be informed – we are publishing this Privacy Policy to keep you informed as to what we do with your personal data. You can ask us for information regarding any data of yours that we keep at any time. This information concerns, among other things, the data categories we process, for what purposes we process them, the origin of the data if we did not acquire them directly from you and, if applicable, the recipients to whom we have sent your data.
• right of access – you may ask us whether we process your personal data and you have the right to request a copy of the information we hold about you.
• right of rectification – you have the right to correct inaccurate or incomplete data about you.
• right to be forgotten – you can ask for the information that we hold about you to be erased from our system and we will comply with this request unless we will have a legitimate reason not to do so.
• right to restriction of processing – where certain conditions apply, you can ask us to ‘block’ the processing of your data.
• right to data portability – you have the right to have the data we hold about you transferred to another organization and to receive personal data in a structured, commonly used format. Please apply at contact@defiskills.io to find out whether we currently support the provision of the portable file containing personal data we process about you.
• right to object – you can object to the processing of your data at any time for reasons that arise from your special situation provided the data processing is based on your consent or our legitimate interest or that of a third party. In this case, we will no longer process your data. The latter does not apply if we are able to prove there are compelling, defensible reasons for the processing that outweigh your interests or we require your data to assert, exercise or defend against legal claims.
• right to withdraw consent – withdraw the consent you gave us with regard to the processing of your personal data for certain purposes.
• right to complain – we take your rights very seriously. However, if you are of the opinion that we have not dealt with your complaints adequately, you have the right to submit a complaint to the data privacy protection authorities responsible.

Please email at contact@defiskills.io with any questions about exercising any of the above rights. If you wish to learn more about the GDPR and your rights, the Information Commissioner’s Office website is a reliable source.

6.2.   Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

• To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
• The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
• To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page.
• To opt out of allowing Google Analytics to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on.
• Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings on that platform.

6.2.   Our Policy Concerning Children

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live (for example, 13 in the US or 16 in Ireland), may not set up an account, but may have a parent or guardian open an account and help them access appropriate content. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.

Parents who believe that DeFi Skills may have collected personal data from a child under those ages can submit a request that it be removed to contact@defiskills.io

7.   Jurisdiction-Specific Rules

If you live in California, you have certain rights related to accessing and deleting your data, as well as learning who we share your data with. If you live in Australia, you have the right to make a formal complaint with the appropriate government agency. Users outside of the United States should note that we transfer data to the US and other areas outside of the European Economic Area.

7.1.   Users in California

Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included in these rights are:

• “Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
• “Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
• “Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, DeFi Skills will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
• “Right to Opt-Out” - You have the right to opt out of the sale of your personal information.

CCPA has a specific definition of a “sale” and while DeFi Skills does not, in the traditional sense, sell your personal information or the personal information of any of our users, we do use cookies that make non-personally identifiable information available to select third-parties.

To exercise any of these rights under CCPA, please email contact@defiskills.io. CCPA allows you to designate an authorized agent to make these requests on your behalf. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify you and/or your agent’s identity before fulfilling your request.

Additionally, for more information about the personal information we collect and how we collect it, please see the sections above entitled “What Data We Get” and “How We Get Data About You.”

To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers who have access to your personal information, please see the sections above entitled “What We Use Your Data For” and “Who We Share Your Data With.”

Since there is no widely accepted standard for the browser-initiated Do Not Track signal, we do not currently recognize or respond to Do Not Track signals.

8.   Changes to this Privacy Policy

We reserve the exclusive right to make changes to this Privacy Policy from time to time, in our sole discretion. Your continued access to and use of the Services constitutes your agreement to be bound by specific terms of this Privacy Policy posted at such time. You acknowledge and agree that you accept this Privacy Policy (and any amendments hereto) each time you access the Services in any manner. Therefore, we encourage you to review this Privacy Policy regularly as you shall be bound by it.

If, within thirty (30) days of posting changes or amendments to this Privacy Policy, you decide that you do not agree to the updated terms of the Privacy Policy, you may provide us with written notice of your withdrawal from this Privacy Policy to the email address at contact@defiskills.io. Upon providing us with the written notice of the withdrawal of your acceptance to this Privacy Policy, you shall no longer be authorized to access or use the Interface, and you must immediately cease in doing so.