Legal

Skillztrail Privacy Policy

Effective Date: May 2026 | Last Updated: May 2026

1. Introduction

This Privacy Policy explains how Skillztrail collects, uses, stores, and protects your personal information when you use our platform. We are committed to safeguarding your privacy and ensuring transparency in how we handle your data.

By using Skillztrail, you consent to the data practices described in this Privacy Policy. If you do not agree with these practices, please do not use the Platform.

2. Who We Are

Skillztrail is owned and operated by Guiding Star Communications and Consulting Inc., a corporation incorporated in the Province of Ontario, Canada. For privacy-related inquiries, you may contact us at privacy@skillztrail.com.

3. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable provincial privacy legislation. We are committed to complying with all applicable Canadian privacy laws and regulations.

4. Information We Collect

We collect information in several categories to provide and improve our services:

A. Account and Registration Information

• Full name
• Email address
• Password (stored in encrypted form)
• Organization name (if applicable)
• Role or job title (if provided)
• Profile information you choose to add

B. Developmental Reflection Data

• Self-reflection responses and narratives
• Capability self-assessments
• Developmental goals and progress notes
• Reflection history and patterns

C. Capability and Engagement Data

• Capability map configurations
• Engagement metrics (frequency of use, features accessed)
• Progress indicators and developmental milestones
• Shared capability summaries (when you choose to share)

D. Payment and Subscription Information

• Billing name and address
• Payment method details (processed securely through third-party payment processors)
• Subscription plan and billing history
• Invoice records

E. Technical and Usage Information

• IP address
• Browser type and version
• Device type and operating system
• Pages visited and features used
• Time and date of access
• Referring URLs
• Cookies and similar tracking technologies

5. How We Use Information

We use the information we collect to:

• Provide, maintain, and improve the Platform
• Create and manage your account
• Process subscriptions and payments
• Deliver personalized developmental insights and AI-powered features
• Generate aggregated and anonymized reports for organizational accounts
• Communicate with you about your account, updates, and new features
• Respond to support requests and inquiries
• Ensure Platform security and prevent fraud
• Comply with legal obligations
• Conduct research and analysis to improve our services (using anonymized data)

6. Organizational Visibility and Reporting

When you use Skillztrail through an organizational subscription, certain information may be visible to your organization:

Individual Reflection Privacy

• Your individual reflection content, narratives, and detailed self-assessments are private by default
• Specific reflection details are not shared with managers or organizational administrators unless you explicitly choose to share them
• You control what developmental information is visible to others

Manager and Organizational Reporting

• Organizations may access aggregated engagement data (e.g., participation rates, general usage patterns)
• Managers may view team-level capability trends and developmental themes (not individual reflection content)
• Organizational reports use anonymized and aggregated data to protect individual privacy
• The specific visibility settings are configured by the organization and communicated to users

7. Artificial Intelligence Processing

Our AI features process your data as follows:

• AI processes your reflection inputs to generate developmental insights and suggestions
• AI-generated outputs are based on your inputs and general developmental frameworks
• We may use anonymized and aggregated data to train and improve AI models
• Individual reflection content is not used to train AI models in identifiable form without explicit consent
• AI processing occurs on secure servers with appropriate data protection measures
• You may opt out of certain AI features while retaining access to core Platform functionality

8. Consent

By using the Platform, you consent to the collection, use, and processing of your information as described in this Privacy Policy. Where required by law, we will obtain your explicit consent before:

• Collecting sensitive personal information
• Using your information for purposes not described in this Privacy Policy
• Sharing your information with third parties for their own purposes
• Using your identifiable data for AI model training

You may withdraw your consent at any time by contacting us or adjusting your account settings, though this may affect your ability to use certain Platform features.

9. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

• Account information is retained while your account is active and for a reasonable period after account closure
• Reflection and developmental data is retained while your account is active and may be exported by you before account closure
• Payment records are retained as required by applicable tax and financial regulations
• Technical logs are retained for a limited period for security and troubleshooting purposes
• Anonymized and aggregated data may be retained indefinitely for research and improvement purposes

Upon account deletion, we will remove or anonymize your personal information within a reasonable timeframe, subject to legal retention requirements.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Secure authentication and access controls
• Regular security assessments and monitoring
• Employee training on data protection practices
• Incident response procedures for potential data breaches
• Secure data backup and recovery processes

While we take reasonable measures to protect your information, no method of transmission or storage is completely secure. We cannot guarantee absolute security of your data.

11. Third-Party Services

We may share your information with third-party service providers who assist us in operating the Platform. These include:

• Cloud hosting and infrastructure providers
• Payment processing services
• Email and communication services
• Analytics and monitoring tools
• Customer support platforms
• AI and machine learning service providers

We require all third-party service providers to handle your information in accordance with applicable privacy laws and to use it only for the purposes for which it was shared. We do not sell your personal information to third parties.

12. Cookies and Analytics

We use cookies and similar technologies to enhance your experience on the Platform. For detailed information about our use of cookies, please refer to our Cookies Policy. In summary:

• We use essential cookies to enable core Platform functionality
• We use analytics cookies to understand usage patterns and improve the Platform
• We may use functional cookies to remember your preferences
• You can manage cookie preferences through your browser settings

13. User Rights

Under applicable Canadian privacy law, you have the following rights regarding your personal information:

• Access: You may request access to the personal information we hold about you
• Correction: You may request correction of inaccurate or incomplete personal information
• Deletion: You may request deletion of your personal information, subject to legal retention requirements
• Data Portability: You may request a copy of your data in a commonly used, machine-readable format
• Withdrawal of Consent: You may withdraw your consent to processing at any time
• Complaint: You may file a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated

To exercise any of these rights, please contact us at privacy@skillztrail.com. We will respond to your request within the timeframe required by applicable law.

14. Children and Minors

Skillztrail is not intended for use by individuals under the age of 18 or the age of majority in their jurisdiction. We do not knowingly collect personal information from children or minors. If we become aware that we have collected personal information from a minor, we will take steps to delete that information promptly.

If you believe a minor has provided us with personal information, please contact us at privacy@skillztrail.com.

15. International Data Processing

Skillztrail is operated from Canada. If you access the Platform from outside Canada, your information may be transferred to, stored, and processed in Canada. By using the Platform, you consent to the transfer of your information to Canada and acknowledge that your information will be subject to Canadian privacy laws.

We ensure that any international transfers of personal information are conducted in compliance with applicable data protection laws and with appropriate safeguards in place.

16. Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes:

• We will update the “Last Updated” date at the top of this policy
• We will notify you of material changes through the Platform or via email
• We will provide reasonable notice before changes take effect
• Your continued use of the Platform after changes take effect constitutes acceptance of the updated policy

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

17. Important Clarification Regarding Developmental Use

Skillztrail is a developmental platform, not an assessment or evaluation tool. This distinction is important for how we handle your data:

• Your reflection data is treated as private developmental content, not performance evaluation material
• We do not provide your individual reflection data to employers for evaluation purposes
• Organizational reports focus on engagement trends and capability development themes, not individual performance assessments
• AI-generated insights are developmental in nature and should not be interpreted as formal evaluations
• We design our data practices to support a psychologically safe environment for honest self-reflection

18. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at privacy@skillztrail.com.