Skill Deck LTDA ("Skill Deck," "SD," "we," "our," or "us") values your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, and safeguard information about you when you:

• Visit our websites, including skilldeck.ai (the "Sites");
• Use our products and services, including our platform, applications, integrations, and chatbot (collectively, the "Services");
• Interact with us in other ways, such as through customer support channels, email communications, or social media pages.

This Privacy Policy does not apply to:

• Products or services that link to a different privacy policy;
• Any third-party applications, software, or integrations (such as Slack, Microsoft, or Google services) that connect with our Services.

We are not responsible for the privacy practices of these third parties, and their information practices are not covered by this Privacy Policy. For details on how third-party providers handle your data, please review their respective privacy policies.

We may update this Privacy Policy from time to time. When changes occur, we will revise the "Last Updated" date at the top of this page. If we make material changes, we will provide additional notice, such as posting an announcement within our Services or contacting you directly. We encourage you to review this Privacy Policy regularly to stay informed about our practices and your privacy rights.

The information we collect depends on how you interact with Skill Deck and use our Services. Because our platform is designed to analyze real workplace interactions (e.g., meetings, messages, and collaboration tools), the categories of data we collect may include both personal data and work-related behavioral evidence.

• Account Information: name, email address, password, organization (if applicable), and subscription details (free or paid plan).
• Communication Data: voice, video, and text collected during meetings, messages, or collaborative interactions when you integrate tools such as Slack, Microsoft Teams, Google Workspace, or email.
• Transcriptions and Analytical Data: transcripts of recorded meetings, chat messages, and metadata (timestamps, participants, frequency of participation, etc.) used for generating competence insights.
• Profile Information: optional details you provide, such as job title, role, department, or skills you choose to share in your public profile.
• Usage Data: information about how you access and use our Services, including log data, device identifiers, browser type, IP address, pages visited, features used, and session duration.
• Support Interactions: when you contact us (e.g., via support or feedback channels), we collect the information you provide and any related correspondence.
• Payment Information (for paid plans): billing name, payment method, transaction history, and subscription details. Payment processing is managed by third-party providers; we do not store full payment card details.

We collect information from the following sources:

• You directly: when you create an account, upload or integrate data, or interact with our Services.
• Third-party integrations: such as Slack, Google, or Microsoft, when you connect these services to Skill Deck.
• Automatically, through analytics tools: Skill Deck uses Fathom Analytics, a privacy-focused service that does not use cookies or collect personally identifiable information. Fathom helps us understand website traffic, user engagement, and marketing campaign performance in an anonymous and aggregated way.
• We also collect limited technical and diagnostic information through error tracking tools, such as Sentry, which help us identify and resolve issues affecting system stability and performance. These tools collect anonymous event and error data only, without storing personal identifiers.

We do not collect sensitive categories of personal information (such as biometric data, health data, political opinions, or children's data).

We collect information that you provide directly when you interact with Skill Deck. This may include, for example:

• Creating an account or updating your profile;
• Participating in meetings or using other integrated services (e.g., Google Calendar, Microsoft Outlook and Teams, Slack, Zoom);
• Communicating through our in-app chat, email invitation, or calendar integration features;
• Completing Activity Sessions, where you respond to scenarios about workplace situations;
• Providing feedback or engaging with surveys;
• Making a purchase or upgrading to a paid plan;
• Communicating with us on third-party platforms (LinkedIn, Twitter, Facebook, Instagram);
• Requesting customer support or otherwise contacting us.

• Identification and Account Information: name, username, email address, phone number, postal address, login credentials, profile photo;
• Communication Data: your image, voice, chat messages, user presentations, and meeting participation details;
• Payment Information: hashed payment card values, billing address, and other payment-related information (full card details are not stored by us);
• Social Media Identifiers: such as your LinkedIn, Twitter, or other profile IDs;
• Any other information you choose to share with us.

When you access or use our Services, we automatically collect certain information, either directly or on behalf of our customers. This may include:

Meeting Information

When you integrate conferencing tools, Skill Deck may collect meeting details such as:

• Names and email addresses of invitees and participants (including those without a Skill Deck account);
• Meeting subject, description, and scheduling information;
• Meeting audio and video (from user's input and output);
• Meeting location, meeting ID, and access details;
• Chat transcripts and reactions (if available).

We always notify meeting participants that a meeting is being recorded and analyzed, provide details about why, and offer an opportunity to opt out—except in cases where the conferencing platform does not support in-meeting notifications.

Transactional Information

If you purchase Services, we collect details such as the product or subscription purchased, transaction date, payment method, and billing details.

Activity Sessions

We collect responses from your participation in Activity Sessions—structured assessments where you answer questions about how you would react in workplace scenarios. These responses are processed to generate a behavioral profile that informs your personalized competence analysis.

Activity, Device, and Usage Information

We collect technical and usage data, including:

• Device and network data (hardware model, operating system version, mobile network, IP address, browser type, app version, device identifiers, hashed email);
• Usage data (access times, pages viewed, links clicked, features used, referring pages).

Location Information

We infer approximate location information from calendar invitations, meeting metadata, and IP addresses.

Users may choose to create a public profile page on Skill Deck, with a custom URL (for example, skilldeck.ai/u/yourname). This profile displays limited information, including the user's overall skill map, competency scores, designated "superpower," and up to four highlights. The creation and activation of this public profile require explicit user consent, and users can share the link with others at their discretion. Users can edit or deactivate their public profile at any time through their account settings.

Skill Deck does not use cookies for analytics or tracking purposes. Instead, we rely solely on Fathom Analytics, which operates without cookies and processes only anonymized and aggregated data.

If, in the future, we adopt limited cookies (for example, to store user login preferences), we will update this policy and provide clear opt-out options.

If you choose to connect your Google account to Skill Deck, we may collect, via Google Workspace APIs:

• Google account information (name, email address);
• Google Calendar data (event titles, descriptions, dates/times, attendees);
• Gmail data (subject, body, recipients, senders, metadata);
• Google Docs data (e.g., notes added in Skill Deck–generated documents);
• Google Drive files (Docs, Slides, or other files you link to Skill Deck);
• Google Chat messages and metadata.

We may transfer user data collected via Google Workspace APIs to certain third-party AI tools strictly for providing Skill Deck's Services. Importantly:

• We do not allow third-party AI tools to use this data to train generalized or non-personalized AI/ML models;
• We do not sell user data collected via Google Workspace APIs to any third party.

We may obtain additional information about you from:

• Integrated video conferencing or collaboration platforms;
• Data providers who supply structured audio/visual datasets;
• Other Skill Deck users (e.g., if someone refers you to our Services);
• Third parties who integrate our Services into their products.

Using the data we collect, we may generate or infer insights about you, such as:

• Behavioral Analytics: using voice, video, and text inputs to assess affect, engagement, and competencies, producing highlights and suggestions for improvement;
• Demographics: inferred characteristics such as language, region, or approximate role within a meeting;
• Company Affiliation: inferred from email domains and participant lists to provide organizational-level insights;
• Meeting Characteristics: identifying meeting type (e.g., internal, client-facing) or purpose;
• Location Inference: using IP address to approximate geographic region.

We use the information we collect for the following purposes:

• To provide, operate, and maintain our Services, including account registration, authentication, and user support;
• To enable integrations with Google, Microsoft, Slack, Zoom, and other platforms as chosen by the user;
• To synchronize with your calendar (Google or Microsoft), store event details (title, timing, attendees, conferencing links), and automatically include the Skill Deck dashboard in relevant events;
• To process transactions, manage billing, and send confirmations, receipts, invoices, and related financial communications.

• To analyze user participation in meetings, emails, chats, and simulated Activity Sessions;
• To monitor, score, and generate reports on user engagement, communication, and decision-making behaviors;
• To create competence maps identifying strengths, development areas, and tailored recommendations for learning or training;
• To generate individual and organizational-level insights (e.g., participation metrics, behavioral benchmarks);
• To provide monthly development reports, highlights, and personalized feedback.

• To customize analytics and reporting dashboards based on user preferences and meeting context;
• To deliver tailored communications, including Advisor Picks episodes, skill-building suggestions, and development insights;
• To remember your settings and preferences across sessions.

• To monitor and analyze usage trends and activities in connection with our Services;
• Skill Deck may improve its algorithms using synthetic or non-Google data sources, but Google user data is used solely to provide or improve user-facing features within the application. We do not use any Google user data (including data obtained via Google Workspace APIs such as Gmail, Calendar, Drive, or Docs) to train AI or machine learning models.
• To debug and repair errors, enhance system security, and ensure service reliability;
• To conduct research and development for new features and product improvements.

• To detect, investigate, and prevent fraudulent, malicious, deceptive, or illegal activity;
• To protect the rights, property, and safety of Skill Deck, our users, and third parties;
• To comply with applicable laws and regulations, including GDPR and CCPA requirements;
• To respond to lawful requests from regulatory or governmental authorities.

• To respond to comments, requests, and questions, and provide customer service;
• To send you technical notices, security alerts, and administrative updates;
• To communicate with you about products, features, services, offers, promotions, and events that we believe may interest you (subject to your opt-out choices);
• To distribute surveys and collect feedback to enhance user experience.

• For any other purpose disclosed to you at the time of collection;
• With your explicit consent for specific additional processing activities.

In certain circumstances, we disclose (or permit others to directly collect) information about you. We disclose personal information as otherwise described in this Privacy Policy and in the following ways:

We disclose information with other users, including sharing your real-time reporting and analytics with other meeting participants, as well as additional post-meeting reporting. In some cases, this may include competency mapping and development suggestions generated by our Services.

Vendors, service providers, and consultants may access data only as necessary to provide services for Skill Deck, and this applies solely to non-Google user data. This includes companies assisting us with web hosting, data storage, data analytics, payment processing, fraud prevention, customer service, AI-assisted tools, and marketing and advertising.

If you provide a review, testimonial, or feedback about our Services, or post content in another public area of our Services, the public and/or other users may be able to see this information. We may also publish such content (with your consent where required) to promote Skill Deck.

We may disclose information in response to a lawful request if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process. This includes lawful requests by public authorities to meet national security or law enforcement requirements.

We may disclose information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Skill Deck, our users, the public, or others.

We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

We may disclose personal information in connection with, or during negotiations of, certain corporate transactions, including any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

We make your personal information available to third parties when we have your explicit consent or when you intentionally direct us to do so (for example, by linking your calendar or Slack workspace to our Services).

We may disclose aggregated or de-identified information that cannot reasonably be used to identify you. We will not attempt to re-identify such information, except as permitted by law, and we may use this type of data for benchmarking, product improvement, and research purposes.

If you choose to activate your public profile, the information contained therein will be visible to anyone who has access to the URL. Skill Deck does not make this profile public without your explicit consent, and we are not responsible for how third parties may use information you voluntarily share through your public profile. You can modify or deactivate your public profile at any time.

Unlike many platforms, Skill Deck does not use cookies, device identifiers, or cross-site behavioral profiling for advertising.

Depending on where you reside, you may opt out of any disclosure for advertising purposes by filling out our web form or contacting us directly.

Please note: we do not share Meeting Information for advertising unless you explicitly consent.

Skill Deck is a Brazilian company but processes and stores all the data in the United States. Therefore, we, and those that perform work for us, may transfer your information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We provide adequate safeguards for the transfer of information in accordance with applicable law, such as by obtaining your consent, relying on the adequacy decisions from relevant regulatory bodies, or executing Standard Contractual Clauses. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at [email protected].

We store information we collect for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Analytical results derived from this information, such as competency scores, highlights, and skill maps, are stored indefinitely to provide users with ongoing access to their insights. Users may request deletion of these analytical results at any time.

During a meeting, you (as a host or meeting participant) can remove Skill Deck from the meeting by typing "opt out" into the meeting chat, and you can remove the Skill Deck from the meeting in the same way you would remove any other meeting participant from the meeting. If the meeting chat is disabled or unavailable, the host can still remove the Skill Deck from the meeting at any time in settings.

You may update and correct certain account information at any time by logging into your account or emailing us at [email protected]. If you wish to delete your account, review the "How to Delete My Account" instructions or email us at [email protected] with your account information, but note that we may retain certain information as required by law or for our legitimate business purposes.

Skill Deck uses Fathom Analytics to collect anonymous, aggregate usage data about our Services. Fathom does not use cookies, does not collect personal information, and does not track individual users. The purpose of this analytics is solely to understand general usage trends and improve our Services while preserving privacy.

Because Fathom does not rely on cookies or personal identifiers, no opt-out for cookies or ad tracking is necessary for this analytics. Users' personal data or behavior is never collected or stored by Fathom.

You may opt out of receiving promotional emails from Skill Deck by following the instructions in those communications. Non-promotional emails about your account or our ongoing business relations may still be sent.

Numerous states, including California, Colorado, Connecticut, Utah, and Virginia, have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures ("State Privacy Laws"). If you are a resident of one of these states and to the extent Skill Deck is subject to the State Privacy Laws, this section applies to you.

Our Privacy Policy explains how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices. Below is a description of our data practices in accordance with the State Privacy Laws, covering both current practices and the past twelve months.

Skill Deck collects a variety of personal information, including identifiers (such as your name, contact information, and device identifiers), demographic information (such as age or gender), commercial information (such as transaction details), internet or other electronic network activity information (such as browsing behavior), employment information (such as your company and role), audio, electronic, and visual information (such as recordings of your video and audio input/output), approximate location (such as the location of your meeting based on your IP address), and inferences drawn from other personal information (such as sentiment and engagement levels).

We may disclose this information to vendors and service providers, corporate affiliates, law enforcement authorities or other individuals involved in legal proceedings, professional advisors, and in connection with corporate transactions. Additionally, we may disclose information with your consent or at your direction.

The information we collect is used to provide, maintain, and improve our Services; personalize your experience with Skill Deck; process transactions and send related information; send technical notices, security alerts, and support messages; respond to your comments and questions and provide customer service; identify and repair errors in our Services; communicate with you about Skill Deck products and services and provide news and information we think will interest you; monitor and analyze trends, usage, and activities in connection with our Services; make inferences and derive insights about users and their organizations; detect, investigate, and help prevent security incidents and malicious activity; comply with our legal and financial obligations; and carry out other purposes described to you at the time the information was collected.

Skill Deck does not share, sell, or use personal information for targeted advertising. Our analytics are performed exclusively through Fathom Analytics, which collects only anonymous, aggregate usage data and does not track individual users, cookies, IP addresses, or other personal identifiers.

As a result, Skill Deck does not disclose any personal information to marketing or advertising partners for advertising purposes. All insights derived from usage data are aggregated and anonymized and used solely to improve our Services and understand general user engagement trends.

Skill Deck collects personal information directly from you (for example, when you create an account or place an order), automatically when you access or use our Services, and from third-party sources, as described in detail in the Collection of Information section above.

We do not collect information considered "sensitive" under State Privacy Laws and we do not use or disclose sensitive personal information to infer characteristics about you. We also do not knowingly sell personal information about consumers under the age of 16.

Opting Out of Sales, Sharing, and Targeted Advertising

Skill Deck does not sell, share, or use personal information for targeted advertising. We do not track individual users, cookies, or other personal identifiers for advertising purposes. All analytics are conducted exclusively via Fathom Analytics, which collects anonymous, aggregate data to improve our Services and understand general usage trends.

As a result, there is no personal information to opt out from regarding sales, sharing, or targeted advertising.

Access, Deletion, and Correction

Depending on your state of residence, you may have the right to request access to, deletion of, or correction of your personal information. You can make such requests by logging into your account and performing the desired updates or deletions. If you do not have an account or were only a meeting participant, please contact the meeting host to request deletion of a meeting report. For additional questions or assistance, please email us at [email protected].

Appeals

If Skill Deck denies your request, you may have the right to appeal our decision by contacting [email protected]. If you have concerns about the outcome of an appeal, you may contact the attorney general in your state of residence.

Authorized Agents

If you are submitting a request as an authorized agent, you must provide proof of your authorization, such as a valid power of attorney or written permission from the individual who is the subject of the request.

Nondiscrimination

Skill Deck will not discriminate against you for exercising any of your privacy rights.

Where relevant, transfers of personal data outside the European Economic Area (EEA), Switzerland, or the UK are safeguarded using the EU Standard Contractual Clauses (SCCs). The text of the SCCs is publicly available at the European Commission's website.

You may also contact us at [email protected] if you would like more information about these safeguards.

You may have the right to access, correct, or delete your personal data, object to certain processing, or request restriction of processing. To exercise these rights, email your request to [email protected].

If you have concerns about our processing that cannot be resolved, you have the right to lodge a complaint with the Data Protection Authority in your jurisdiction:

• EEA: https://edpb.europa.eu/about-edpb/board/members_en
• UK: https://ico.org.uk/global/contact-us/
• Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Skill Deck is not intended for use by individuals under 16 years of age. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us immediately at [email protected].

For any questions about this Privacy Policy, please contact us at:

[email protected]