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Privacy Policy

Welcome to our privacy policy! Here at Skealed, we value transparency about data handling. While we encourage you to review our policy thoroughly to fully understand our data practices, here are the essential highlights:

  • We store messages, their timestamps, and related Topics. This information is kept private and only shared with third parties when legally obligated.
  • You have the right to request a download, modification, or deletion of your personal data at any time.
  • Your data is protected on secure, restricted access database servers. We use encryption to safeguard your data during transmission, although please note that encryption is not available in China.
  • Skealed operates globally, which means your data may be stored on servers located outside of your home country.
  • We may restrict access to Skealed in cases of misconduct to maintain a safe, welcoming community. Reports of abuse are taken seriously, reviewed by human moderators, and may result in exclusion from our platform. Reports to moderators are kept confidential unless otherwise chosen by you.

Privacy Policy Overview

This document outlines our commitment to protecting the personal data of those who use our mobile apps or website. Skealed is committed to high European data protection standards, reflecting our base in Germany within the European Union.

Contact Information

Skealed, represented by Guillaume Besson, is located at Schöneweider Strasse 3, 12055 Berlin, Germany. You can contact us via email at contact@skealed.com.

External Data Protection Officer

For secure communication regarding your data, please contact our privacy team and data protection officer at contact@skealed.com. For sensitive matters, we recommend postal correspondence.

Personal Data Processed

We collect and process various types of personal data, which include:

  • Contact details (your first and last names, address, email, and location, noting that last names are not shared with other members).
  • Profile information (age, gender, city, personal photos).
  • Message content (images, voice messages, comments, corrections, topics).
  • Your interactions with us and logs of your visits to our apps and websites.
  • Identifiers like cookie IDs and IP addresses.
  • Awards and activity records on our apps and websites.
  1. Purposes of Use

We collect personal data primarily for the purposes for which you have provided it, such as creating an account. Below are the ways we use and store your personal data at Skealed:

  • Profile Creation: We establish a user profile to facilitate interactions within the Skealed community.
  • Community Management: We ensure a secure community environment by verifying profile pictures and other provided information to prevent and detect fraud. This may involve comparing encrypted profile images against known fraudulent images to maintain community safety.
  • Communication: We send notifications relevant to your use of our services, including updates on membership changes, messages, and follower activity, through emails or push notifications.
  • Advertising and Promotions: Personal data is used to target ads within the app (optionally disabled in settings), send newsletters, and inform you of promotions like contests and events.
  • Local Connectivity: We use data to help you find and connect with nearby learning partners.
  • Service Optimization: We analyze how members use Skealed to enhance functionality and user experience.
  • Safety and Security: We maintain a safe and accountable environment across various chat formats and community interactions by promoting authentic exchanges.
  • Contractual Processes: Your data aids in processing agreements and contracts with you.
  • Member Interaction: We help you connect with language exchange partners through a carefully curated profile visible only to verified members, ensuring that sensitive information like your email or exact location remains private unless you choose to share it.

Your personal data will not be shared with third parties unless you explicitly consent or are legally required to do so, such as by court order or governmental directive. We also collect data for functional, analytical, and marketing purposes.

  1. Legal Basis

The processing of your data is grounded in the following legal frameworks:

  • Consent: Art. 6(1)(a) of the GDPR, where you consent to cookie settings or advertisements.
  • Contractual Necessity: Art. 6(1)(b) of the GDPR, necessary for the performance of a contract, such as joining the community.
  • Legal Obligation: Art. 6(1)(c) of the GDPR, for compliance with legal obligations.
  • Legitimate Interests: Art. 6(1)(f) of the GDPR, covering the processing of data shared in personal chats and for statistical purposes, aimed at enhancing service quality and securing the community.

Legitimate Interests

In processing your data, we are driven by the need to:

  • Improve and provide our services efficiently.
  • Protect the community from misuse.
  • Conduct analytics and statistical assessments to enhance service functionality.
  • Uphold the integrity and credibility of our community.

This framework ensures that we handle your personal data responsibly and in alignment with legal standards and community expectations.

  1. Data Sources

We primarily collect data directly from you, including through the devices you use to access our services.

  1. Data Transfer to Third Countries

Personal data may be transferred outside the European Economic Area (EEA). We ensure these transfers comply with legal standards by only moving data to countries recognized by the EU Commission as having adequate protection, or through robust safeguards like standard contractual clauses or certifications, ensuring secure and lawful handling of the data. Notable examples include:

  • USA: Data transfers supported by Adequacy Decisions or Standard Contractual Clauses.
  • India: Transfers are safeguarded by Standard Contractual Clauses.
  • China: Protected by Standard Contractual Clauses.
  1. Retention Period

We retain personal data under the following conditions:

  • Consent: Data is retained until you withdraw your consent (e.g., by deleting your account).
  • Contractual Necessity: Data needed for fulfilling a contract is kept until the end of the contractual relationship or until legal retention periods expire.
  • Legitimate Interests: Data processed on this basis is retained until your overriding interest mandates its deletion or anonymization.
  • Account Deletion: Deleting your account results in the deletion of your personal information but not messages sent to Skealed Partners. Your email address and Skealed ID are retained to handle future inquiries or deletion requests.
  • Community Rules: To maintain community integrity, we may retain anonymized identifiers for up to 24 months to manage access and enforce community standards.
  • Membership Applications: Applications are stored for at least seven days, after which you can delete your personal data permanently from Skealed via the app’s “Delete my application” feature.
  1. Our Policy on Children’s Information

Skealed is not available to children under 16. In the EEA, users must be over the age that allows them to consent to data processing according to local laws, or we must have verifiable parental consent. Parents who discover that their child has been using Skealed without consent can contact us at contact@skealed.com to address the issue.

This detailed explanation ensures users are fully informed of how their data is managed, transferred, and retained, complying with legal standards and safeguarding user privacy.

  1. Cookies and Similar Technologies

Cookies are small text files or pieces of code that may include a unique identifier. When you access our website or mobile app, we may store these files on your device if permitted. Cookies help us with several important functions:

  • Remembering Information: They prevent you from having to re-enter information during your visit or on subsequent visits.
  • Customization: Cookies enable personalized content and information delivery.
  • Service Effectiveness: They help us monitor and optimize the effectiveness of Skealed.
  • Metrics and Analytics: We track overall visitor numbers, traffic, and demographic trends.
  • Technical Troubleshooting: Cookies aid in diagnosing and resolving technology issues.
  • Efficient Access: They facilitate efficient access to your information after you sign in.
  • Session Management: Cookies are crucial for keeping you logged in and maintaining security within the Skealed community.

To manage or revoke your consent for cookies, you can use the “Change your cookie consent” button found at the bottom of our website pages.

  1. Data Recipients

We use your personal data within Skealed and share it only with partners involved in fulfilling the services you engage with us or for enhancing those services. Key recipients include:

  • Analytics Services: Google Analytics and Firebase Analytics receive pseudonymous and some personal data to help us understand and improve how Skealed is used.
  • Communication Services: Iterable and Sparkpost manage our email and push notification services. Details such as names, device IDs, and email addresses are shared with them. You can customize your message settings or opt out of certain notifications directly within these messages or through your device settings.
  • Advertising: With your explicit consent, anonymized data such as age, gender, and device identifiers may be shared with advertising networks like Admob by Google, MoPub, and Facebook Audience Network to personalize ads. You can limit ad tracking on iOS or opt out of personalized ads on Android through your device settings.

9.1 Registration and Authentication

By registering or authenticating, you enable Skealed to provide secure access to our services. We may use third-party services for registration and authentication if you consent to it:

  • Facebook Authentication (Meta, Inc.): Connected to the Facebook network, collects various data as per their privacy policy.
  • Firebase Authentication (Google Inc.): Simplifies sign-up and sign-in processes, storing email addresses on Google’s platform.
  • Google OAuth (Google Inc.): Linked to the Google network, collects various data types according to their privacy policy.
  • Weibo (Sina.com): Connected to the Sina Weibo social network, collects data as outlined in their privacy policy.
  • WeChat Auth (Tencent Inc.): Operates through the WeChat network, processing data in Canada and Hong Kong as specified in their privacy policy.
  • Sign in with Apple (Apple Inc.): Offers privacy-enhanced sign-in with Apple ID, using a private relay email address to protect users’ real emails.

Each of these services processes data primarily in the location indicated in their respective privacy policies. This section ensures that users are aware of where and how their data is being used for authentication purposes, reinforcing our commitment to transparency and data protection.

9.2 Hosting and Backend Infrastructure

Skealed relies on several key service providers to host data and run our platform, which include:

  • Amazon Web Services (AWS) (Amazon Web Services, Inc.): AWS serves as the primary infrastructure and hosting service, managing a wide array of personal data including login information, images, and message content, with servers located in Germany and the United States.
  • Google Cloud Platform (Google Inc.): This platform hosts various types of data, helping to manage the backend services necessary for Skealed’s operation, processed primarily in the United States.
  • Azure (Microsoft Ireland Operations Ltd.): Like AWS, Azure is crucial for hosting a broad spectrum of personal data for Skealed, with processing occurring in Germany.
  • CDS Global Cloud (Beijing CapitalOnline Data Service): Utilized specifically for enhancing service reliability and speed in Mainland China, CDS Global Cloud processes data within the European Union.

9.3 Processing Payments

Skealed integrates several payment processing services to handle transactions securely:

  • Apple App Store (Apple Inc.): Manages payments for app purchases and in-app transactions, with data processing taking place in the United States.
  • Google Play Store (Google Ireland Limited): Similar to Apple, this service processes payments for app and in-app purchases, with data processing in Ireland.

These services ensure that Skealed does not handle or store sensitive credit card details directly, enhancing security.

9.4 Infrastructure Monitoring

Monitoring services are employed to maintain and improve the app’s performance:

  • Crashlytics (Google Inc.): Helps reduce app crashes by tracking stability issues and collecting data like geographical location and device identifiers.
  • Firebase Crash Reporting and Firebase Performance Monitoring (Google Inc.): These services collect various types of data to aid in optimizing app performance and stability, processed in the United States.

9.5 Managing Contacts and Sending Messages

To manage communications with users, Skealed uses:

  • Firebase Cloud Messaging (Google Inc.): This service allows Skealed to send messages and notifications across different platforms including Android, iOS, and web.
  • SparkPost (Message Systems, Inc.): Manages email communications by handling email addresses and other relevant data.
  • Iterable (Iterable, Inc.): Supports user communication and database management, processing data such as email addresses and activity trackers in the United States.
  • Agora (Agora Lab, Inc): Utilizes the Vonage API for high-quality audio and video communications across Skealed’s applications, collecting only necessary operational information like IP addresses.

These sections provide comprehensive details about how Skealed manages hosting, payments, infrastructure monitoring, and user communications, emphasizing security and compliance across all operations.

9.6 Web and Mobile Analytics

To monitor and analyze the performance and traffic on our web and mobile platforms, we use the following services:

  • Skealed Direct Analytics: An internal system that does not rely on third parties. Data collected: Cookies and usage data.
  • Google Analytics: A service by Google Inc. that helps track user interactions and optimizes user experiences. Google may use the data to personalize ads across its network. Data collected: Cookies and usage data. Opt-out: Users can opt out by visiting the Google Analytics opt-out page.
  • Google Analytics for Firebase: This service integrates with Firebase’s suite to enhance app functionality and analytics. Data collected: Cookies, device identifiers, and usage data. Opt-out: Modifications can be made through device settings or specified sections of this privacy policy.
  • Adjust: Provided by Adjust GmbH, this tool tracks and attributes ads, improving the relevance and effectiveness of marketing efforts. Data collected: Cookies, device identifiers, and usage data. Opt-out: Adjust provides an opt-out option on its website.
  • Facebook Ads Conversion Tracking: An analytics tool by Facebook, Inc. that links actions on Skealed with ad interactions. Data collected: Cookies and usage data.
  • TestFlight: Managed by Apple Inc., this service collects data to help test and improve app functionalities. Data collected: Cookies, email address, and usage data.

9.7 Managing Support and Contact Requests

To efficiently manage user inquiries and support needs, we use:

  • Zendesk: A platform by Zendesk, Inc. that handles support tickets and user communications. Data collected: Varies as per the interaction and user information provided.
  • FeatureOS: By Skcript Technologies Private Limited, this service collects feedback and feature requests from users. Data collected: Logs, analytics, cookies, and other tracking technologies. Processing: Complies with the Safe Harbor Privacy Principles.

9.8 Advertising

To support our free features through advertising, and to ensure relevance, we carefully manage ad placements and user data sharing:

  • AdMob by Google Inc.: Uses device identifiers and cookies to tailor ads based on user behavior and preferences. Opt-out: Users can adjust settings through Google’s ad preferences.
  • DoubleClick for Publishers by Google Inc.: This service allows integration with external ad networks. It uses cookies to track user interactions and preferences related to ads. Opt-out: Google provides a specific opt-out for Doubleclick cookies.
  • Facebook Audience Network by Facebook, Inc.: Uses mobile device identifiers and cookies to show personalized ads based on user preferences and actions. Opt-out: Adjustments can be made via Facebook’s ad settings or device settings for ad personalization.

These services ensure that user interactions, support needs, and advertising preferences are managed effectively, providing a tailored and secure experience on the Skealed platform. Users have the ability to control and opt out of certain data usages, aligning with our commitment to user privacy and compliance with data protection regulations.

9.9 Content Performance and Features Testing (A/B Testing)

To optimize and test different features and content, we employ the following services:

  • Firebase Remote Config (Google Inc.): A service designed for A/B testing and configuration adjustments. Data collected: Various types as detailed in their privacy policy. Place of processing: United States.
  • Google Optimize (Google Inc.): This tool is used for A/B testing, website testing, and personalization to enhance user experience. Data collected: Various types as specified in their privacy policy. Place of processing: United States.
  1. Your Rights

As a user of Skealed, you possess several rights concerning your personal data:

  • Right to Information and Correction: You can inquire about your personal data stored with us and request corrections if necessary.
  • Right to Deletion: You can request the deletion of your personal data, for example by using the “Delete Account” option in your profile settings.
  • Right to Restriction: Under certain conditions, you may request that the processing of your data be limited.
  • Right to Revoke Consent: You can withdraw your consent to data processing at any time, effective immediately for future processing.
  • Right to Data Portability: You have the right to receive your data in a standard format, accessible through the “Download my data” feature in your profile.
  • Contacting the Data Protection Officer: For any queries or concerns about privacy practices, our data protection officer is available to assist you.
  • Right to Lodge a Complaint: If you believe the processing of your data infringes legal regulations, you have the right to complain to the relevant supervisory authority.
  1. Requirement or Obligation to Provide Data

The provision of your data is not mandatory unless specifically stated during data collection.

Date of Issue of This Data Privacy Statement

  • 1st July 2024

This policy ensures that Skealed’s users are well-informed about their rights and the processes in place to protect their privacy, aligning with legal standards and providing transparency.