Last Updated: March 29, 2021
What Information Does Skills Fund Collect and How Does Skills Fund Collect that Information?
Personal Information and Sources
We collect Personal Information that you provide to us on the Online Services via forms, applications, surveys, and other fillable online fields. This “Personal Information” may include your name, address, date of birth, Social Security number, citizenship, military status, age, national origin, email address, telephone numbers, loan number, account number, driver’s license number, passport number, username (if different than your email), password, education information, housing information, professional (or employment) information, salary, income, financial information, and other identifying information.
If you choose to use the Online Services, we may also collect information from third parties, such as credit reports and employment information.
We also collect information about your use of the Online Services, such as your information relating to any loan application, transaction history, account balance and other account information, subscription status, and payment information.
We may also collect information through offline channels, which includes audio recordings through customer service calls and physical correspondence.
Information Collected Automatically
In addition to the Personal Information that we collect from you as described above, we may automatically collect certain information, including Personal Information, from your use of the Online Services. This information may include:
The information described above may be collected through cookies (defined below), pixel tags (defined below), clear gifs, or other technologies.
For What Purposes Do We Use Your Personal Information?
Skills Fund handles your Personal Information for the following purposes:
Who Do We Share Your Personal Information With?
We do not sell your personal information or the personal information of minors. We do not trade, or otherwise transfer your Personal Information to third parties without your consent, except as described in this paragraph. We may, without your consent, disclose your Personal Information:
We may also request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose.
How Do We Protect Your Personal Information?
We employ reasonable security measures, designed to maintain the confidentiality, integrity, and security of your Personal Information to protect against the loss, misuse, or alteration of information that we have collected from you through the Online Services. For example, Skills Fund employs policies and procedures to designed to protect Personal Information in accordance with applicable law, including but not limited to the Gramm-Leach-Bliley Act. Unfortunately, no security technology is completely secure, and you should remember that email and the Internet generally may not be a secure means of communication and/or transmitting Personal Information. Personal Information that you share via email is done so at your own risk.
Do We Track Our Visitors Online?
Some web browsers may transmit “do-not-track” or similar signals to the websites with which a user communicates. There currently is no industry standard for how websites must respond when they receive such a signal. The Online Services do not respond to do-not-track signals sent by web browsers.
Some of the content, advertisements, and functionality on the Online Services may be provided by third parties. We also use third-party service providers to provide us with analytics services so we can improve the Online Services. These third parties may collect information about your use of the Online Services through technologies such as cookies and web beacons, and this information may be collected over time and combined with information collected across different websites. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising. For example, some of these third parties may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”), which provide websites where you can opt out of certain types of data collection and use or out of receiving targeted ads from member companies. To opt out, please visit https://www.networkadvertising.org/managing/opt_out.asp or https://www.aboutads.info.
One of the third-party services that we use is Google Analytics, which is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of the Online Services and may share this data with other Google services. We have also enabled Google Analytics Advertising features, including Remarketing, so Google may use the data collected to contextualize and personalize the ads of its own advertising networks. The Online Services and third parties, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on past visits to the Online Services and report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Online Services. You can learn more about Google’s privacy practices by visiting their website at https://www.google.com/policies/privacy/partners/.
What is Plaid?
When you link a bank account in connection with an ISA, you authorize Skills Fund and Plaid to continue to collect data from the financial institution you specify for as long as your ISA remains outstanding. The frequency at which Skills Fund and Plaid will collect data during this period will vary. You can revoke this authorization by writing Skills Fund at [email protected]
What are Cookies?
The Online Services also use “cookies” (small data files stored on your device) and other tracking technologies to collect information about your use of the Online Services. The information that is captured about your use of the Online Services may be used in a variety of ways, such as to monitor and maintain information about your visits to the Online Services, to help us identify and address problems, to improve the Online Services, to analyze web traffic trends, and to help protect the security and integrity of the Online Services.
You may set your browser not to accept cookies or to notify you when you receive cookies, giving you the opportunity to decide whether to accept cookies. If you do not accept cookies, you may still use the Online Services, but your experience may be degraded.
What are Pixels?
We may also use pixel tags (also known as “clear gifs,” “Web beacons,” or “1-by-1 gifs”) on our site. These may be used in connection with certain pages of the Online Services or with email messages to measure the effectiveness of our communications and our marketing campaigns, to compile statistics about usage and response rates, to market to you, and to assist us in resolving issues that may arise on the Online Services.
What About Third Party Links in the Online Services?
Notice Regarding Social Media Use
Children’s Online Privacy Protection
We do not knowingly collect Personal Information from individuals under 13 years of age without parental consent. If we become aware that a child under 13 is attempting to submit Personal Information, we will inform the minor that he or she is ineligible to do so. We will then remove this information from our records. Our Online Services are not intended for children under 13 years of age.
If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information, including under the California Consumer Privacy Act of 2018 (“CCPA”).
CCPA Notice at Collection
Skills Fund, LLC (“Skills Fund,” “we,” or “us”) is providing you with this Notice at Collection (“Notice”) under the California Consumer Privacy Act of 2018 (“CCPA”) to provide you with timely notice, at or before the point of collection, about the categories of personal information to be collected from you and the purposes for which the personal information will be used.
Categories of Personal Information to be Collected
Skills Fund collects the following categories of personal information about you:
Business or Commercial Purpose(s) for which the Categories of Personal Information will be Used
Skills Fund will use the categories of personal information about you described above for the following business or commercial purposes:
Access to Specific Information and Data Portability Rights
Under the CCPA, you have the right to request Skills Fund disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Right to Deletion
Under the CCPA, you have the right to request the deletion of Personal Information. However, this right does not apply where we need to retain the Personal Information for any of the following purposes:
Carry out any actions for internal purposes that you or other consumers might reasonably expect.
Right to Deletion
We will not discriminate against you for exercising any of your rights under the CCPA. Discrimination under the CCPA includes but is not limited to:
How To Exercise Your Rights Under the CCPA
If you are a California resident and would like to exercise your access or and deletion rights under the CCPA, please submit a verifiable consumer request to us by either calling the Toll Free Number at +1 855-218-6733 or email us at [email protected] If you are making a request under CCPA, only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provide in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may designed an authorized agent to make a CCPA request on your behalf by writing to us at the contact information provided above. In addition to the requirement stated above that the agent must be registered with the California Secretary of State, we also require documentation confirming that the individual is authorized to submit the request on your behalf. This may include a signed letter from you or notarization of your request.
Do You Have Questions?