Updated: December 2021

Skale Education Inc. d.b.a. Upduo (“Upduo”, “we”, "us", and “our") believes in protecting the privacy of our users. This Privacy Policy describes how your information is collected, used and shared when you use Upduo (including the Upduo app, upduo.com and its subdomains, and all products and services of Skale Education Inc.).

Upduo is intended for use by organizations and in accordance with their instructions. Your Organization has the right to (i) control and administer your Upduo account and (ii) access and process any data we collect through your use of Upduo, including video recordings of your Upduo training sessions. Please contact your Organization with any privacy inquiries about policies it has in place regarding your use of Upduo.

Collection of Information

We may collect and store the following data:

Personal Registration Information

Contact information, such as name and work email address;
Work title, employment start date, employment location, and other information related to your work or Organization;
Information other people provide about you, including Organization administrators; and
Authentication information if you connect to Upduo using credentials from a Third Party Application (e.g., Gmail), such as your username and encrypted access credentials.

Information from Use of Our Products

All training session content, including video recordings of Upduo app training sessions and the details of each training session (such as skill, partner, ratings and duration);
User communications, feedback, suggestions, and ideas sent to us;
Information you provide us when you or your Organization contact or engage us for support regarding our services;
General usage information, such as usage date/time, IP address, device information;
Feedback actively provided by you in the form of reviews, comments, and suggestions or recommendations for modifications, improvements or changes to our services; and
Analytics regarding how you interact with our products.

Use of Information

Upduo will use information we collect to provide, develop, and improve our products on your Organization’s behalf. Examples of such use include:

Communicate with users and administrators regarding their use of our products;
Personalize your and your Organization’s experiences;
Develop new tools, products, or services; and
Conduct data and system analytics, including research to improve Upduo’s products.

Upduo will not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a consumer's personal information by the business to another business or a third party for monetary or other valuable consideration.

Disclosure of Information

We may disclose the information that we collect in the following circumstances:

To your Organization, network administrators, and other users authorized by your Organization to access the requested information;
To other Upduo users within your organization as needed to facilitate training sessions. For example, a user’s full name will be available to another Upduo user when they are matched for a training session;
In connection with a substantial corporate transaction, such as an acquisition, merger, consolidation, asset sale, or in the unlikely event of bankruptcy or insolvency;
To Upduo employees or contracted entities ("contractors"). These entities, for the purposes of the Upduo Privacy Policy, are considered to be a part of Skale Education Inc. and therefore are subject to the Upduo Privacy Policy under the same terms as Skale Education Inc. itself;
To comply with local, state, federal, international, or other applicable laws or respond to a court order, subpoena, warrant, or administrative request;
As otherwise directed or authorized by your Organization.

Upduo Notice on the California Consumer Privacy Act

Upduo acts in accordance with the California Consumer Privacy Act of 2018. California residents can exercise the rights below:

Right to know what personal information is being collected, for what purposes, and with whom it is shared.
- See the above Collection of Information, Use of Information, and Disclosure of Information sections for details on Categories collected. If a customer requests specific pieces of information, that customer has the right to receive the information, twice a year, free of charge, delivered by mail or electronically. If provided electronically, it shall be in a portable and, to the extent technically feasible, readily usable format that allows the California resident to relatively easily transmit this information to another entity.
Right to know whether your personal information is being sold, to whom, and the right to say no for said sale.
- Upduo does not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a consumer's personal information by the business to another business or a third party for monetary or other valuable consideration; therefore, the notification and opt-out requirements do not apply to Upduo.
Right to non-discrimination of service or price if you exercise your privacy rights.
- The CCPA prohibits businesses from discriminating against a California resident for exercising any of their rights under the CCPA, including by
  - denying goods or services;
  - charging different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties;
  - providing a different level or quality of goods or services; or
  - suggesting that the person exercising their rights will receive a different price or rate for goods or services or a different level or quality of goods or services.
Right to deletion.
- California residents have the right to request that a business delete any of their personal information that the business collected from them, subject of CCPA §1798.105.

Account Closure

If you would like to stop using the Services, you should contact your Organization. Similarly, if you stop working for or with the Organization, the Organization may suspend your account and/or delete any information associated with your account.

It typically takes about 90 days to delete an account on behalf of your Organization after account closure, but some information may remain in backup copies for a reasonable period of time as directed by your Organization. Please note, content you create on Upduo is owned by your Organization and may remain on Upduo and be accessible even if your Organization deactivates or terminates your account.

Changes to this Privacy Policy

Skale Education Inc. d.b.a. Upduo may update this privacy policy at its discretion. When we make material changes to the Privacy Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the app or by sending you an email. In some cases, we will notify you in advance, and your continued use of the Upduo after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using Upduo under the new version of the Privacy Policy, you may terminate your account by contactingcontact@upduo.com.

If you have any questions or comments about this privacy policy or your personal information, please send an email tocontact@upduo.com.