This GDPR privacy notice (this “GDPR Notice”) is included in our Privacy Policy and applies to the ‘personal data,’ as defined in the GDPR, of natural persons located in the European Economic Area (“EEA Individuals,” “you,” or “your”) processed by Soulskills™. 

Any capitalised terms or other terms not defined herein shall have the meaning ascribed to them in the Soulskills™ Privacy Policy or, if not defined herein or in the Privacy Policy, the GDPR. To the extent of any conflict between this GDPR Notice and any other provision of the Privacy Policy, this GDPR Notice shall control only with respect to EEA Individuals and their personal data.

If you are located elsewhere, please see our Privacy Policy. 

The term “European Economic Area” (or “EEA”) shall mean the then-current member states and member countries of the European Union and European Economic Area, respectively, Switzerland, and, upon its withdrawal from the European Union, the United Kingdom.

Controller Disclosure & Details: We are a data controller of personal data regarding the following categories of EEA Individuals: Visitors, Registered Users and Customers (collectively, “Users”) and affiliate partners and vendor contacts (collectively, “Business Contacts”) for the purposes and under the legal bases described in the policy below. 

Please note that, in some cases, the categories of data subjects above may overlap (e.g., Visitors, Registered Users and Customers using the Websites).

DATA SUBJECT CATEGORY: GENERAL (applies to all data subjects below)

Purpose & Legal Basis of Processing

Information Security: Our web servers will log your IP address and other information (e.g., browser information, operating system, request date/time, user agent string, referral and exiting URL) in order to maintain an audit log of activities performed. 

We use this information pursuant to Our legitimate interests in tracking usage of the Websites, combating DDOS or other attacks, and removing or defending against malicious visitors on the Websites. 

DATA SUBJECT CATEGORY: CUSTOMERS

Purpose & Legal Basis of Processing 

Direct Marketing: Generally-speaking, We will provide email marketing (e.g., our newsletter) pursuant to a Customer’s consent. In cases where a Customer buys, or enters into negotiation for the sale of a product or service, email marketing shall be sent to such Customer pursuant to Our legitimate interest in sending marketing communications to such Customers in the context of a sale.

Rewards and Promotions: Soulskills™, Our promotional and marketing partners (e.g., affiliate partners), and customers’ legitimate interest in administering Our rewards and promotional offerings. For example, after purchasing a Soulskills™ product or service, We may share your name and email address with the referring affiliate partner only to the extent such affiliate partners have offered you bonuses or rewards for following their referral link. 

Testimonials or Feedback: Our legitimate interest in using testimonials, feedback, or survey responses from Customers for marketing purposes, such as posting on the Websites or within sales decks, pitches, or other promotional content (e.g., email marketing and social media). 

Executing Contracts and other Legal Documentation: We will process all personal data as necessary for the performance of contracts to which Customers are a party (such as our Terms of Use or, Privacy Policy, or a purchase of our products or services) or to take requested steps to enter into such contracts.

General Business Development: Our legitimate interest in furthering business relationships (such as by storing Customer information within a CRM or other database/file), ensuring customer satisfaction, and answering inquiries. 

Audience Measurement and Retargeting: Pursuant to a Visitor’s consent, We use an assortment of marketing and analytics cookies for purposes of audience measurement, retargeting, and creating relevant Visitor experiences (such as based on their interaction with our Website).

DATA SUBJECT CATEGORY: BUSINESS CONTACTS 

Purpose & Legal Basis of Processing

Affiliate Partners: We will process all personal data as necessary for the performance of contracts to which Our affiliate partners are a party (e.g., our affiliate partner terms) or to take requested steps to enter into such contracts (e.g., completing our affiliate partner application). 

Vendor Contacts: When entering into vendor relationships, we will receive the personal information of contacts employed or otherwise associated with such vendors. We process such information in our legitimate interest in establishing and developing Our vendor relationships.

CONTROLLER'S EU REPRESENTATIVE: 

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Soulskills™ GDPR representative in the EU can be contacted as follows: 

(i) Email: [email protected] 

(ii) Submit request: https://www.soulskills.co/gdpr-data-request