Privacy Policy

This Privacy Policy (the “Privacy Policy”) serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use the website (the “Site”), services, software, content, and all other products and services (all of the foregoing collectively, the “Services”) owned, controlled or offered, directly or indirectly, by Skyll Inc. (together with its subsidiaries and affiliates, “Company”, “we,” “our” or “us”). Company believes that the privacy of its users is paramount and strives to use Personal Information (as defined below) only in ways outlined in this Privacy Policy. This Privacy Policy is incorporated by reference into our Terms of Service, currently available at https://skyll.us/terms (the “Terms of Service”). Any terms used herein and not defined will have the meanings given to them in the Terms of Service. By using the Services, you hereby warrant and represent that you have read, understand and agree to this Privacy Policy and the Terms of Service, and that you are a resident of the United States. If you are under 18 years of age, your parent, guardian, or school must agree to this Privacy Policy on your behalf. PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

1. Educational Use and Student Data Protection

   When Skyll provides services to schools, school districts, state education agencies, or youth organizations (each a “School” and collectively "Schools"):
   
   Our Services are intended for use in an educational setting. Accounts for children under the age of 13 must be created and managed by a school, school district, or authorized educational institution (collectively, “Schools”). By registering and permitting student use of the Services, you as an authorized agent of your School represent and warrant that your School has obtained all necessary authority to consent, on behalf of parents or guardians, to the collection and use of students’ personal information as described in the Agreement.
   
   

   • FERPA Compliance: We act as a school official with legitimate educational interest under the Family Educational Rights and Privacy Act (FERPA). Schools retain ownership and control of all student data.
   • Student Data Prohibitions: We do not sell student data. We do not use student data for advertising or marketing purposes. We do not create student profiles for non-educational purposes. We use student data solely for authorized educational purposes as directed by the School.
   • Compliance with State Laws: We comply with applicable state student data privacy laws. Student data ownership and control remains with the School or applicable education agency as required by law.
   • Parent Rights: Parents have the right to review, request deletion of, or refuse collection of their child's student data by contacting their School. The School will coordinate with us to fulfill such requests.
   
   
   

2. What We Mean by Personal Information

   For purposes of this Privacy Policy, “Personal Information” means any information from or about a person that either identifies that person directly or that makes that person identifiable when it is combined with other information from or about that person from any source.
   
   

3. Information We Collect

   Information You Provide To Us
   
   When you use the Services or otherwise communicate with us, we collect information that you provide to us directly. For example, we collect information in the following circumstances: you (i) use or visit the Site; (ii) register for the Services, or create an account or profile, or accept the creation of an account or profile on your behalf (an “Account”); (iii) access the Services through third party services; (iv) request technical support; (v) otherwise use our online Services where Personal Information is required for such use and/or participation; (vi) when you contact us via the Site or when you otherwise communicate with us. You can choose not to provide information that is requested of you by us; however, this may limit your ability to use or access the Services.
   
   The information you provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute Personal Information:
   
   

   • Information you provide in connection with registering for an Account or accessing the Services, including your name, e-mail, age, account security and authentication information, and any other information you decide to provide;
   • Information you provide via email, through the “Contact” section on the Site or by using the contact details listed on various parts of the Site, including your name, e-mail, age, account security, authentication information, inquiry, and any other information you decide to provide;
   • If you are one of our customers, suppliers or prospects, we may process limited Personal Information in the course of our business relation with you, for example when you place an order, request a demo or vice versa. Such Personal Information may include your name, company/school, title, e-mail address, and order details;
   • Any other information you may want to share with us.
   
   Moreover, if you contact us, a record of such correspondence may be kept.
   
   Additionally, if another user refers you to us by providing us with your e-mail address, we may send you a message. However, we will use your e-mail address only to send such other user’s message unless you otherwise affirmatively provide your information to us.
   
   Automatically Collected Information
   
   We do not collect information beyond what is required for educational use. Most of the data we collect in and through the Site and the Services is technical in nature and is collected and processed automatically through so-called application programming interfaces, software development kits, cookies and similar software-based technologies. Alone or in combination with other data, such automatically collected data may constitute Personal Information. The data we may collect by automated means may include, without limitation:
   
   
   • Device data: including, but not limited to, device type, operating system, and browser information.
   • Usage data: including, but not limited to, pages viewed, time spent on pages, and navigation patterns within the Services.
   • Network and internet information: including, but not limited to, Internet Protocol addresses and general network connectivity information for security and system operation purposes.
   • Information we collect on the use of the Site via cookies: please see the “How We Use Cookies and Other Technologies” section below for more information.
   
   By using cookies, we or our third party service providers collect and store data such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol address, and the type of operating system used in the devices used to access the Site.
   
   How We Use Cookies and Other Technologies
   
   Some of the features on the Site and the Services require the use of “cookies” - small text files that are stored on your device’s hard drive. We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve the Site to meet the needs of our visitors.
   
   The following sets out how we may use different categories of cookies and your options for managing cookie settings:

   Type of Cookies	Description	Managing Settings
   Required Cookies	Required cookies enable you to navigate the Site and use their features, such as accessing secure areas of the Site and using the Services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. These cookies allow us to uniquely identify you when you are logged into the Site and to process your online transactions and requests.	Because required cookies are essential to operate the Site, there is no option to opt out of these cookies.
   Performance Cookies	These cookies collect information about how you use our Sites, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. Information is only used to improve how the Site function and perform. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Site. We may also utilize Flash cookies for these purposes.	To learn how to opt out of performance cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.
   Functionality Cookies	Functionality cookies allow our Sites to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Site to personalize your visit.	To learn how to opt out of functionality cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.

   
   
   

4. Use of Collected Information

   We use the information you provide to us for the following purposes: (i) to further our legitimate interests in providing the Services solely for educational purposes authorized by the applicable School (as defined below); (ii) to administer your use of the Services and any Accounts you may have with us; (iii) to personalize your experience; (iv) to provide to you Service announcements or inform you of new releases and features; (v) to perform tasks on behalf of and according to instructions of a third party, such as payment processors; (vi) to enforce our Terms of Service; (vii) to resolve any disputes between users of the Site or between such users and us; (viii) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (ix) to further our legitimate interest in protecting our rights, property, or safety and the rights, property and safety of the Services, our users or the public; and (x) to contact you to obtain feedback from you regarding the Site and the Services.
   
   In addition to the purposes described above, we use the information collected automatically to: (i) further our legitimate interests in monitoring and analyzing the use of the Services and for the technical administration of the Site; (ii) improve the Site and the Services; (iii) generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users; and (iv) verify that users of the Services meet the criteria required to process their requests.
   
   

5. Third Parties We Share Personal Information With

   We use third-party service providers to help us operate and deliver the Services. These service providers act on our behalf and are contractually required to use information only as directed by us and to maintain appropriate security measures. Third-party service providers who require access to student data are bound by contractual obligations to maintain the confidentiality and security of such data and may use it only for the purposes we specify. We work with the following categories of service providers:
   
   

   • Service providers, such as web hosting, communications service providers, and data storage service providers helping us deliver and develop the Services; and
   • Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
   • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Site and/or the Services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.
   
   

6. Children’s Privacy

   We comply with the Children's Online Privacy Protection Act (COPPA). When our Services are provided through schools, school districts, state education agencies, or youth organizations (each a “School” and collectively "Schools"), the School provides consent on behalf of parents for the collection of information from children under 13 for educational purposes.
   
   Parents have the right to review their child's Personal Information, request deletion, or refuse further collection. To exercise these rights, parents should contact the School or organization through which the Services are provided. The School or organization may contact us at student-privacy@skyll.us to coordinate such requests.
   
   

7. Privacy Laws

   Applicable laws may require certain businesses that share customer Personal Information with third parties for the third parties’ direct marketing purposes to respond to requests from customers asking about the businesses’ practices related to such information-sharing. We currently do not share or disclose your Personal Information to third parties for the third parties’ direct marketing purposes. If we change our practices in the future, we will implement an opt-out policy as required under applicable laws.
   
   Furthermore, subject to certain exemptions, you may have the following rights with respect to Personal Information we may have collected about you. You may submit a request to know these rights via info@skyll.us. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.
   
   We do not sell, and have not in the prior 12 months sold, Personal Information. Therefore, we have not included a “Do Not Sell My Personal Info” link on our Site. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law. We do, however, disclose Personal Information for business purposes as described in the “Third Parties We Share Personal Information With” section above.
   
   Requests to Delete
   
   You have the right to request that we delete any Personal Information about you that we have collected. Upon receiving a verified request to delete Personal Information, we will do so unless otherwise required or authorized by law.
   
   For Student Data: Schools may request deletion of student data by contacting us at student-privacy@skyll.us. Parents may request deletion of their child's information by contacting their School, who will coordinate with us to fulfill the request.
   For Other Personal Information: Contact us at info@skyll.us to request deletion.
   
   Authorized Agents
   
   You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to W. Va. Code § 39B may submit a request on your behalf.
   
   Our Response to Requests
   
   We will acknowledge receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
   
   Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
   
   We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
   
   

8. Data Retention

   For Student Data (Educational Use):
   We retain student data collected through Schools only as long as necessary to provide the educational Services or as required by our agreement with the School. Upon termination of our agreement with a School or state education agency, or upon the School's written request, we will delete or return all student data within thirty (30) days, unless required by law to retain it.
   
   For Other Personal Information:
   We keep Personal Information related to your Account for as long as it is needed to fulfill the purposes for which it was collected, to provide our services, to deal with possible legal claims, to comply with our business interests and/or to abide by all applicable laws. Thereafter, we either delete Personal Information about you or de-identify it. Please note that even if you request the deletion of Personal Information about you, we may be required (by law or otherwise) to retain the Personal Information and not delete it. However, once those requirements are removed, we will delete Personal Information in accordance with your request.
   
   

9. Security

   We implement industry-standard security measures to protect Personal Information, including student data. These measures include data encryption both in transit using Transport Layer Security version 1.2 or higher and at rest in our databases. Access to student data is restricted to authorized personnel who require such access to perform their assigned duties, and all access is logged and monitored.
   
   All employees and contractors with access to student data receive training on privacy laws, security protocols, and incident response procedures. We follow secure coding practices and conduct regular security assessments of our platform. Third-party service providers with access to student data are contractually required to maintain equivalent security standards and use such data only for the purposes we specify.
   
   While we implement these safeguards, no security system is impenetrable. We cannot guarantee absolute security but commit to maintaining commercially reasonable protections and promptly addressing any security incidents as described in Section 10 of this Privacy Policy.
   
   

10. Data Security Breach Notification

    In the event of a suspected or confirmed security breach involving student data, we will notify the affected School or state education agency immediately upon discovery of the breach. The School or state education agency will notify parents as soon as possible after the suspected or confirmed breach, in accordance with applicable law. For non-school users (youth organizations, families), we will notify the account holder directly within seventy-two (72) hours of confirming the breach.
    
    Breach notifications will include the date of the breach, the types of information involved, the steps we are taking to address the breach, and recommended actions for affected individuals. We maintain incident response procedures and will cooperate fully with Schools and authorities in breach investigation and remediation.
    
    

11. Parent Rights and Complaint Process

    Parents have the right to (i) access and review their child's Personal Information collected through our Services, (ii) request correction of inaccurate information, (iii) request deletion of their child's Personal Information subject to legal retention requirements, and (iv) refuse further collection or use of their child's information.
    
    For students enrolled through Schools, parents should first contact their School to exercise these rights or file a privacy complaint. The School will work with us to investigate and resolve the issue. Parents may also contact us directly at student-privacy@skyll.us. For other users, parents may contact us directly at student-privacy@skyll.us with details of their request or privacy concern.
    
    We will respond to privacy complaints in a timely manner in accordance with applicable law. If parents are not satisfied with our response, they may file a complaint with their School's designated privacy official, their state department of education, or the U.S. Department of Education's Family Policy Compliance Office.
    
    

12. Do Not Track Signals and Similar Mechanisms

    Company does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
    
    

13. Links to Other Websites

    We frequently make content or services from other websites available to you from links located on the Site. We may present links in a format that enables us to keep track of whether these links have been followed. In addition, you may opt to link your Account to your other accounts, such as Google and Microsoft, in accordance with your Account settings (which you may change at any time) and respective policies of these third parties. This Privacy Policy applies only to the Site and the Services. We do not exercise control over third party services or other websites that provide information, or links from within the Site or the Services. Your interactions with these third party services are governed by the privacy policy of the company providing it. These other sites and services may place their own cookies or other files on your computer’s browser, collect data or solicit Personal Information from you. Other websites and services follow different rules regarding the use or disclosure of the Personal Information that you submit, and the collection and use of such information and access of any third party websites are subject to such third party’s privacy policy. We encourage you to read the privacy policies and other terms of such third parties before using their services.
    
    

14. International Transfers of Personal Information

    Company is based in the United States. As a result, Personal Information that we collect in and through the Services and on the Site may be transferred to our U.S. offices. In addition, we may work with third-party service providers in the U.S. to support our business activities. In all such instances, we use, transfer, and disclose Personal Information solely for the purposes described in this Privacy Notice and in compliance with applicable laws.
    
    

15. Changes to the Privacy Policy

    Our security and Privacy Policy are periodically reviewed and enhanced as necessary. This Privacy Policy might change as we update and expand the Services. You can tell when this Privacy Policy was last updated by reviewing the Last Updated legend on top of this page. We will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. We also encourage you to review this Privacy Policy periodically. If you do not understand any of the terms or conditions of any of our policies, you may inquire regarding the same via email at info@skyll.us. Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of such change.
    
    

16. Contacting Us

    If you have any concerns or questions about this Privacy Policy, please contact us at info@skyll.us. For student data privacy requests, Schools may contact student-privacy@skyll.us.