Privacy Policy

1. Controller

The controller within the meaning of Article 4(7) of the General Data Protection Regulation (GDPR) is:

Email: dataprotection@skillties.com

Skillties GmbH is established in Germany and operates the platform in accordance with German and European data protection law.

2. Scope of this Privacy Policy

This Privacy Policy applies to the Skillties software platform ("Platform"), including:

• public access to the Platform without registration ("logged-out use"),
• use of the Platform by registered users ("logged-in use"),
• use of domain-based and claimed workspaces.

Skillties does not operate a separate marketing website. All publicly accessible pages are part of the Platform.

The Platform is intended exclusively for adults. Use by persons under the age of 18 is not permitted.

3. Structure of the Platform and Data Visibility

The Platform consists of public areas and non-public areas.
Whether personal data is visible depends on how and where it is used within the Platform.

3.1 Public areas

The following content may be publicly accessible without registration and may be indexed by search engines unless explicitly marked otherwise (e.g. legal pages):

• skills,
• skill profiles,
• public comments,
• attribution of public content to users (real name and profile image).

Public visibility occurs only when users actively create or publish such content.

3.2 Non-public areas

The following data is not publicly accessible:

• personal skill mappings,
• individual skill levels,
• learning progress and history,
• private notes,
• workspace-internal content.

4. Registration and User Accounts

To actively use the Platform, users must register and create an account.

During registration and use of the account, Skillties processes the following personal data:

• full real name (mandatory),
• email address,
• authentication data (password or single sign-on identifier),
• workspace association (if applicable).

Accounts are personal and must not be shared with third parties.

5. Domain-Based Workspaces

5.1 Automatic workspace assignment

When a user registers with an email address associated with a specific domain (for example @siemens.com), Skillties automatically assigns the user to a shared, domain-based workspace associated with that domain.

This assignment is based solely on the email domain. Skillties does not verify organizational affiliation beyond the domain.

The purpose of this assignment is to enable domain-based collaboration and visibility of certain skill-related data among users associated with the same domain.

There is no opt-out from this assignment. If a user does not agree, registration with that email address is not possible.

5.2 Unclaimed (free) domain-based workspaces

Domain-based workspaces may initially exist without a workspace administrator ("unclaimed workspaces").

In unclaimed workspaces:

• certain personal skill-related data of workspace members is visible to other members of the same workspace,
• this may include skill mappings, enrolled skill profiles, and calculated match levels,
• visibility is limited strictly to the workspace and is not public.

Skillties acts as the controller for the processing of personal data within unclaimed workspaces.

5.3 Claimed (paid) workspaces and administrator role

A domain-based workspace may be claimed by a user. Upon claiming the workspace, the claiming user becomes a workspace administrator.

Claimed workspaces may be subject to additional features, settings, or paid plans.

Workspace administrators may:

• manage workspace members,
• configure workspace settings,
• control the visibility of certain data within the workspace.

Workspace administrators cannot:

• make personal data publicly accessible,
• influence which content is public on the Platform,
• override the Platform's public visibility rules.

Public visibility of content is determined exclusively by the Platform's functionality and by the actions of individual users when creating public content.

Depending on the contractual setup, Skillties may process certain data in claimed workspaces on behalf of the organization operating the workspace. Further details may be governed by a separate data processing agreement.

6. User Accounts, Profiles and Identity Visibility

Skillties does not operate a publicly searchable or browsable user directory and is not designed as a social network.

Creating an account does not make a user publicly visible.

A user's real name and profile image become visible only in context, in particular when the user:

• creates or edits a skill,
• creates or edits a skill profile,
• posts a public comment.

Such visibility serves solely to attribute the respective content.

Within a workspace, a user's identity and skill-related data may be visible to other workspace members, depending on the workspace type and configuration. This visibility is limited to the workspace context and does not result in public accessibility.

Use of a real name is mandatory. Display names or pseudonyms are not supported.

7. Skill-Based Calculations and Profiling

The Platform performs automated calculations based on user-provided skill data. These include, in particular:

• average skill levels,
• the number of required skills per skill profile,
• match levels between users and skill profiles.

These calculations are based on personal skill mappings and therefore constitute personal performance-related data.

They are used exclusively for purposes of orientation, comparison, and self-assessment.

Skillties does not use these calculations to make automated decisions with legal or similarly significant effects within the meaning of Article 22 GDPR.

8. Invitations and Identity Providers

Users may invite other persons to join the Platform or a specific workspace.

In this context, Skillties processes:

• the email address of the invited person,
• information about the inviting user,
• the invitation status.

Where available, identity providers or single sign-on solutions may be used to facilitate authentication.

9. Emails and Communications

Skillties uses email communication for the following purposes:

• registration and login,
• workspace invitations,
• system notifications,
• product and feature updates,
• marketing communications (newsletter).

Newsletters are sent using Brevo and are only sent on the basis of the user's consent. Users may unsubscribe at any time.

10. Cookies and Tracking Technologies

The Platform uses cookies and similar technologies.

Essential cookies

Session cookies are used to ensure authentication, security, and basic functionality of the Platform.

Analytics and marketing technologies (subject to consent)

With user consent, the Platform may use analytics and marketing services, including:

• PostHog,
• Google Analytics,
• HubSpot,
• Google marketing services,
• Meta (Facebook),
• Microsoft Bing Ads (Universal Event Tracking).

These technologies help analyze usage of the Platform and measure the effectiveness of communication and outreach.

11. Hosting and Processors

Skillties uses Google Cloud Platform with EU-only hosting.

Personal data is processed exclusively within the European Union.

Skillties works with carefully selected processors under data processing agreements in accordance with Article 28 GDPR. These may include providers for hosting, analytics, marketing, and email delivery.

No intentional data transfers outside the European Union take place.

12. Deletion and Anonymization

Users may delete their account at any time.

Upon account deletion:

• personal identifiers are anonymized,
• public content remains available in anonymized form,
• ownership of skills or skill profiles may be transferred where applicable.

Statutory retention obligations remain unaffected.

13. Rights of Data Subjects

Users have the right to:

• access their personal data,
• request rectification or erasure,
• request restriction of processing,
• receive their data in a portable format,
• object to certain processing activities.

Requests can be submitted to dataprotection@skillties.com.

Users also have the right to lodge a complaint with a competent supervisory authority.

14. Changes to this Privacy Policy

This Privacy Policy may be updated from time to time.
The current version is always available on the Platform.