Privacy Policy

Last updated September 30, 2025

This Privacy Notice for I/E Mishiko Taliashvili ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

Visit our website at https://myskillmaster.org or any website of ours that links to this Privacy Notice

Use Disclaimer. The Website and its services are provided "as is" and "as available" without warranties of any kind. We do not guarantee the accuracy, completeness, or security of data processed by third-party providers. Your use of the Website constitutes acceptance of these limitations. To the fullest extent permitted by law, we disclaim all liability for any data breaches, inaccuracies, or third-party actions, except where required by applicable law. We expressly disclaim any responsibility or liability for the policies, practices, actions, or omissions of third-party service providers (including Google, Hostinger, Cloudflare, affiliate partners, and payment processors). Your interactions with such third parties are solely at your own risk and governed by their respective policies.

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hi@myskillmaster.org.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://myskillmaster.org/support, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. EMBEDDED THIRD-PARTY SERVICES
15. DONATIONS
16. GOOGLE TRANSLATE FEATURE
17. POLLS AND QUIZZES
18. MINORS AND FINANCIAL TRANSACTIONS
19. CLOUDFLARE DDOS PROTECTION AND SECURITY SERVICES
20. AFFILIATE LINKS AND ADVERTISING
21. DO WE MAKE UPDATES TO THIS NOTICE?
22. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
23. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Automatically Collected Data. When you visit, our hosting provider (Hostinger) and content delivery network (Cloudflare (if applicable)) automatically log standard access data such as IP addresses, browser type, operating system, referring URLs, device identifiers, and timestamps for security, performance, and DDoS protection purposes.

Analytics and Security Tools. We use Google Analytics to understand visitor behavior and improve services. Data collected may include IP address, device identifiers, browser activity, and usage patterns. Google ReCaptcha is used to protect against spam and abuse, collecting device and behavioral information. Cloudflare may process IP addresses and request data for caching, security, and optimization.

Advertising. We use Google Adsense and third-party ad networks, which may place cookies or similar technologies to deliver personalized or contextual ads based on your browsing behavior.

Affiliate Links. Our Website may contain affiliate links. Clicking such links may allow third-party partners to track your activity (e.g., via cookies) and generate commissions for us. These third parties are responsible for their own privacy practices.

Polls and Quizzes. Participation is strictly anonymous. No personal data is collected or linked to responses; only aggregate results are stored for service improvement.

Email Communications. If you contact us at hi@myskillmaster.org, you voluntarily provide your email address and message content. We use such information only for responding to inquiries and service improvement.

Donations. Donations are processed through third-party payment providers (TBC Bank, KISA.GE, NOWPayments for cryptocurrency). We do not collect or store payment details. Such providers' privacy policies govern their processing.

Embedded Third-Party Services. Certain features, such as currency converters (from xe.com), cryptocurrency rates (from CoinGecko), and world time displays, may transmit data (e.g., IP addresses or usage details) directly to these providers when you interact with them. This processing is governed by their privacy policies, and we encourage you to review them (e.g., xe.com at https://www.xe.com/privacy.php; CoinGecko at https://www.coingecko.com/en/privacy). We do not control or assume responsibility for their data practices.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

Website Operations. Operating, maintaining, and improving the Website.

Security Protection. Protecting Website security and preventing unauthorized access or abuse (legitimate interest).

Analytics. Analyzing visitor interactions and Website performance (legitimate interest or consent for cookies).

Advertising. Displaying ads and affiliate links to support Website operation (legitimate interest).

User Communication. Responding to inquiries and communication requests (contractual necessity or consent).

Legal Requirements. Complying with applicable legal and regulatory obligations.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Develop and display personalised and relevant advertising content for our users
• Analyse how our Services are used so we can improve them to engage and retain users

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• Data Analytics Services
• Website Hosting Service Providers
• Cloud Computing Services
• Performance Monitoring Tools
• Affiliate Marketing Programs
• AI Platforms
• Ad Networks
• Privacy compliance and cookie consent management services
• Sales & Marketing Tools
• Retargeting Platforms

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Germany and United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), including facilities in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than we retain personal data for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required by law. specifically: comments and user-generated content: indefinitely (unless deletion is requested) analytics data: 26 months (google analytics default) server logs: 90 days cookie data: varies by cookie type (session to 2 years).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at hi@myskillmaster.org.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by By sending an unsubscribe request via email reply to the marketing message received, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at hi@myskillmaster.org.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section 'WHAT INFORMATION DO WE COLLECT?'

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

Category A - We retain identifiers for different periods based on their purpose: Comment data and usernames: indefinitely (as part of published content) Email addresses: as long as the user engages with our site IP addresses in logs: 90 days Analytics identifiers: 26 months User can request deletion at any time

Category F - We retain user internet activity data for up to 14 months (Google Analytics default retention period). This includes browsing behavior, pages visited, session duration, and device information. After this period, the data is automatically anonymized. Users can opt out of tracking at any time through browser settings or by contacting us to request data deletion.

Category G - Geolocation data is collected as follows: - Google Analytics: Country, city, and region data from IP addresses for audience insights (retained 14 months) - Hostinger server logs: IP addresses for security and performance monitoring (retained 90 days) - We do not collect precise GPS location or track real-time movements - Data is disclosed to Google (Analytics processing) and Hostinger (hosting services)

Sources of Personal Information

Learn more about the sources of personal information we collect in 'WHAT INFORMATION DO WE COLLECT?'

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

Category G. Geolocation data

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting https://myskillmaster.org/support, by emailing us at hi@myskillmaster.org, by visiting https://myskillmaster.org/support, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hi@myskillmaster.org. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California 'Shine The Light' Law

California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'

14. EMBEDDED THIRD-PARTY SERVICES

Our Website uses embedded third-party services (xe.com, CoinGecko, Logwork, Desmos, Windy.com, Elfsight (data transmitted directly when you interact with their embedded features)) that may transmit data directly to external providers when you interact with them. These services include currency converters (xe.com), cryptocurrency rates (CoinGecko), world time displays (Logwork), mathematical calculators (Desmos), weather maps (Windy.com), and interactive widgets (Elfsight). When you use these features, data such as your IP address, browser information, and usage details may be transmitted to and processed by these third-party providers in accordance with their own privacy policies. We do not control, and expressly disclaim responsibility for, the data collection or processing practices of these third parties. We strongly encourage you to review their respective privacy policies before interacting with embedded features: - xe.com: https://www.xe.com/privacy.php - CoinGecko: https://www.coingecko.com/en/privacy - Logwork: https://logwork.com/blog/contact-us - Desmos: https://www.desmos.com/privacy - Windy.com: https://www.windy.com/privacy - Elfsight: https://elfsight.com/privacy-policy/ By using these embedded services, you acknowledge and accept that your data will be processed by these third parties under their own terms.

15. DONATIONS

Donations We gratefully accept voluntary donations to support our Website. All donations are processed through secure third-party payment providers: - TBC Bank - Georgian bank transfers and card payments - KISA.GE - Local payment processing - NOWPayments - Cryptocurrency donations (Bitcoin, Ethereum, etc.) Key Terms: - We do not collect or store payment card details, bank account information, or cryptocurrency wallet keys. - All payment data is processed directly by the respective provider under their privacy policies (TBC Bank: https://www.tbcbank.ge/web/en/web/guest/privacy-statement; NOWPayments: https://nowpayments.io/privacy-policy). - Transaction records (transaction IDs, amounts, dates) are retained for 7 years as required by Georgian tax law. - Cryptocurrency transaction IDs are pseudonymous and stored for compliance purposes only. - Donations are generally non-refundable except in cases of processing errors. - Minors must have parental/guardian consent to donate. Unauthorized donations by minors may be voided and refunded. By donating, you confirm you are of legal age, have reviewed the payment processor's privacy policy, and consent to data retention as described. For questions about donations or to exercise data rights, contact: hi@myskillmaster.org

16. GOOGLE TRANSLATE FEATURE

Google Translate Feature Our Website offers an optional translation feature powered by Google Translate, a service provided by Google LLC ("Google"). This feature allows you to view Website content in different languages. How It Works: When you use the Google Translate feature, the content you choose to translate is temporarily transmitted to Google's servers for processing. Google may collect and process the following data during translation: - The text or content being translated - Your IP address - Browser type and language settings - Cookies and similar identifiers (if Google Translate cookies are enabled) - Device information and operating system - Referring URL and timestamp Data Processing and Privacy: - Translation requests are processed by Google in real-time and are not permanently stored by us on our servers. - Google processes translation data in accordance with its own Privacy Policy (https://policies.google.com/privacy) and Terms of Service (https://policies.google.com/terms). - Google may use translation data to improve its translation algorithms and services. - Translated content is cached temporarily by Google for performance optimization. - We do not control how Google processes, stores, or uses data transmitted through Google Translate. International Data Transfers: Translation data is transmitted to and processed on Google's servers, which may be located in the United States or other countries outside your jurisdiction. Google adheres to applicable data protection frameworks, including Standard Contractual Clauses for EU data transfers. Your Choices: - Use of Google Translate is entirely optional. You can choose not to use this feature and view content in its original language. - To limit data sharing with Google, you may disable third-party cookies in your browser settings or use Google's opt-out tools (https://tools.google.com/dlpage/gaoptout/). - For more information about how Google handles translation data, please review Google's Privacy Policy at https://policies.google.com/privacy. Legal Basis: We provide this feature based on your consent (by actively choosing to translate content) and our legitimate interest in making Website content accessible to a global audience. Disclaimer: - Translations are generated automatically by Google and may not be 100% accurate. We are not responsible for translation errors or inaccuracies. - Google Translate is a third-party service, and we disclaim all liability for Google's data processing practices, service availability, or any issues arising from its use. For questions about Google Translate data processing, contact Google directly or reach us at hi@myskillmaster.org for general inquiries.

17. POLLS AND QUIZZES

Our Website may offer interactive polls, quizzes, surveys, and assessments to engage visitors and gather feedback about content preferences and user experience. Anonymous Participation: All polls and quizzes are designed to be completely anonymous. We implement the following privacy protections: - No personal data (such as name, email address, or contact information) is collected during participation. - Responses are not linked to any personally identifiable information, IP addresses, or user accounts. - We do not use cookies or tracking technologies to identify individual participants. - No authentication or registration is required to participate. Data Collected: We collect only the following non-personal information: - Quiz/poll responses and answer selections - Aggregate statistics (e.g., total votes, percentage distributions) - Timestamp of submission (for statistical purposes only, not linked to individuals) Data Retention: - Individual anonymous responses: Stored indefinitely in aggregated form - Raw response data: Retained only in anonymous, non-identifiable format - Aggregate statistics: Retained permanently for analytical purposes - No personal identifiers are ever stored or retained Data Sharing: - Poll and quiz results may be displayed publicly on our Website in aggregate form (e.g., "75% of users selected option A"). - We do not sell, rent, or share individual response data with third parties. - Aggregated, anonymized insights may be referenced in blog posts or content updates.

18. MINORS AND FINANCIAL TRANSACTIONS

Age Restrictions: Our Website is intended for general audiences and does not knowingly target or direct services to minors. For purposes of this Privacy Policy, a "minor" is defined as any individual under 18 years of age, or under the age of majority in their jurisdiction of residence, whichever is higher. General Privacy Protection for Minors: - We do not knowingly collect, use, or disclose personal data from minors without verifiable parental or legal guardian consent. - Our Website does not require user registration or account creation, minimizing the risk of inadvertent data collection from minors. - Analytics and tracking technologies (e.g., Google Analytics) do not distinguish between adult and minor visitors and collect data anonymously as described in this Privacy Policy. Financial Transactions by Minors: Minors are strictly prohibited from engaging in any financial transactions through our Website, including but not limited to: - Making donations via TBC Bank, KISA.GE, or NOWPayments (cryptocurrency) - Clicking on affiliate links with the intent to make purchases - Participating in any monetized activities Parental/Guardian Consent Requirement: - Any financial transaction attempted or completed by a minor without explicit, verifiable consent from a parent or legal guardian is considered unauthorized and voidable. - We reserve the unconditional right to void, cancel, and refund any donation or transaction made by a minor without proper parental or guardian authorization, regardless of when the transaction is discovered. - Parents or guardians who become aware of unauthorized transactions by minors should contact us immediately at hi@myskillmaster.org. Refund and Cancellation Policy for Minor Transactions: - Upon verification that a transaction was made by a minor without authorization, we will: 1. Immediately cancel any ongoing services or benefits associated with the transaction 2. Process a full refund to the original payment method within 14-30 business days (subject to payment processor timelines) 3. For cryptocurrency transactions, refunds will be processed to the original wallet address at the equivalent value in the original cryptocurrency (subject to network fees and exchange rate fluctuations) - Processing fees, currency conversion fees, or blockchain transaction fees incurred during the original transaction may not be refundable and are subject to third-party payment processor policies. Knowledge of Minor Data Collection: - If we become aware or have reason to believe that we have collected personal data from a minor without proper consent, we will take immediate steps to delete such information from our systems, except where retention is required by law (e.g., for transaction records subject to tax compliance). - Transaction records involving minors may be retained for up to 7 years as required by Georgian accounting and tax legislation, but will be marked as voided/refunded and not used for any other purpose. Third-Party Services and Minors: - Third-party services embedded on our Website (Google Analytics, advertising networks, payment processors) have their own age restrictions and policies regarding minors. - We are not responsible for data collection by third parties from minors who misrepresent their age or bypass age verification mechanisms. - Parents should review third-party privacy policies and enable parental controls on devices used by minors.

19. CLOUDFLARE DDOS PROTECTION AND SECURITY SERVICES

Cloudflare DDoS Protection and Security Services We use Cloudflare for CDN, DDoS protection, WAF, caching, SSL/TLS, and bot detection. Cloudflare automatically processes: IP address, browser/device info, HTTP requests, cookies (__cfduid, cf_clearance), threat scores. Purpose: block attacks, distinguish bots, cache content, optimize routing, prevent abuse. Retention: logs 24-72 hours, security data longer, cached content temporary. Data processed globally (US, EU) under EU-U.S. Data Privacy Framework and Standard Contractual Clauses. Cloudflare acts as processor, doesn't sell data or use for ads. May present CAPTCHA for verification (temporary cookies). Cannot opt out (essential for security); manage cookies via browser. Processing governed by Cloudflare Privacy Policy (https://www.cloudflare.com/privacypolicy/). We have DPA with SCCs. Legal basis: legitimate interest in security. Not responsible for Cloudflare practices/outages. Contact: hi@myskillmaster.org; Cloudflare: privacyquestions@cloudflare.com

20. AFFILIATE LINKS AND ADVERTISING

Our Website may contain affiliate links, display advertisements, and mention third-party companies, products, or services as part of our content. This section explains how these features work and what data may be collected. 1. Affiliate Links and Commission-Based Content What Are Affiliate Links? Affiliate links are special URLs that allow us to earn a commission when visitors click on them and subsequently make a purchase or complete an action on a third-party website. How Affiliate Links Work: - Our Website may include affiliate links within blog posts, articles, reviews, recommendations, or resource lists. - When you click an affiliate link, you are redirected to a third-party merchant's website (e.g., Amazon, online retailers, service providers). - The affiliate partner may place cookies or tracking pixels on your device to track your activity and attribute any subsequent purchases or conversions to our referral. - If you complete a qualifying action (e.g., make a purchase, sign up for a service), we may earn a commission from the affiliate partner. Data Collected Through Affiliate Links: When you click on an affiliate link, the following data may be collected by the affiliate partner (not by us): - Click timestamp and referring URL - IP address and geographic location - Browser type, device information, and operating system - Cookies and unique tracking identifiers - Browsing behavior on the merchant's website - Purchase information (product, price, transaction ID) if you complete a transaction We do not directly collect or have access to this data. Affiliate partners process data under their own privacy policies. Each affiliate partner has its own privacy policy governing data collection and use. We encourage you to review their policies before clicking affiliate links. Transparency and Disclosure: - We clearly disclose when content contains affiliate links by using statements such as "This post contains affiliate links," "As an Amazon Associate, we earn from qualifying purchases," or similar language. - Disclosures are placed prominently at the beginning or end of relevant content, or near affiliate links themselves. - Affiliate relationships do not influence our editorial independence or the integrity of our content. We only recommend products or services we believe may be valuable to our audience. 2. Advertising Sponsored Blog Posts and Paid Content What is Sponsored Content? Sponsored content (also called "paid posts," "branded content," or "native advertising") refers to blog articles, reviews, guides, or other editorial content that has been commissioned, paid for, or otherwise compensated by a third-party company, brand, or organization. 3. Third-Party Mentions (Unpaid Editorial Content) We may mention companies, products, or services for: - Reviews and comparisons - Educational content - Industry analysis - Resource recommendations Important: - Not all mentions are paid or affiliate relationships - Unless disclosed as "Sponsored" or "Affiliate," content is editorial and unpaid - Mentions do not constitute endorsements - We maintain editorial independence regardless of affiliate/ad relationships

21. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

22. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at hi@myskillmaster.org or contact us by post at:

I/E Mishiko Taliashvili
Salkhino N6
Tbilisi 0101
Georgia

23. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://myskillmaster.org/support.