A Play2learn is owned by Skillcore, a company that deeply values the privacy of its users. In line with this commitment, we have developed this Privacy Policy to explain how we handle users' personal information on our platform. By using our services, you agree to the collection and use of your personal data as described here. 

SKILLCORE greatly values the protection of its users' privacy, which is why we pay close attention to how we handle our users' personal data. Therefore, we have developed this Privacy Policy, which describes how we handle personal information and data on our platform. By using our services, the user understands and declares awareness that their personal data and information will be collected and used as described in this Privacy Policy.

If the user or their organization has entered into a specific/individual contract with SKILLCORE, the mentioned contract may contain specific provisions about privacy that complement, restrict, or even expand the rules present in this Privacy Policy. For this reason, it is essential that the user reviews the content of the mentioned contract to be fully aware of the duties and obligations undertaken.

This Privacy Policy does not apply to third-party websites, applications, services, and products that the user may have accessed through the P2L Platform and its services. Therefore, we alert the user to always read the Privacy Policies and Terms of Use of third parties before accepting any offer.

The P2L Platform is a tool equipped with artificial intelligence (“AI”) technology that allows its users to create training and learning journeys by creating immersive and interactive scenarios/games to assist in teaching certain topics, developing skills of its users, analyzing profiles and behaviors, among other applications. SKILLCORE, therefore, provides access and usage services of the P2L Platform and licenses the right to use it and the content generated and made available to the user exclusively for the purposes described in its respective Terms of Use. In this sense, our services necessarily include user registration and the offer of payment methods for operations on our platform. For this reason, providing some personal data, strictly for the purposes proposed on this platform, will be necessary, following the rules of this Privacy Policy.

In respect for our users, we adopt the concept of privacy by design as one of the pillars of our business, that is, we collect and process only the personal data essential for the service we provide. If there is any change in our business model that requires the use of other personal data from our users, we will always inform our users in advance so that they can choose to continue their subscription.

It is important that you read this entire Privacy Policy, but if you have a specific interest, we have prepared a summary below to facilitate your navigation through this document:

1. Definitions

• Database: structured set of data, established in one or several locations, in electronic or physical support;

• Cookies: files sent by SKILLCORE's server to the computer of those accessing the P2L Platform, for the purpose of identifying the computer, personalizing access, and obtaining browsing data to improve and make the services offered by SKILLCORE more efficient;

• Personal data: information related to an identified or identifiable natural person;

• Consent personal data: personal data that has received explicit consent from its owner for processing and that are not public personal data;

• Public personal data: personal data whose access is public and personal data made public by its owner and/or third parties authorized to do so and that therefore do not require prior consent for processing; 

• SKILLCORE: the company SKILLCORE as a whole, including its group of companies, website, mobile applications, and platforms used for providing its services;

• Input: data that the user provides to the P2L Platform tool (e.g., subject matter of the training to be conducted; roles of the characters/people involved; etc.) for the creation of gamified trainings through the tool;

• Output: result generated by the P2L Platform tool in response to the inputs provided by the platform's users;

• P2L Platform: tool provided by SKILLCORE that consists of a platform for creating trainings and learning journeys through gamification and artificial intelligence processes;

• SKILLCORE Services: the paid or free services and licenses provided by SKILLCORE through the P2L Platform;

• Owner: natural person to whom the personal data refers;

• Processing: any operation carried out on personal data, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, assessment, or control of information, modification, communication, transfer, dissemination, or extraction;

• Users: all those who register on the P2L Platform;

• Paying Users: all those registered on the P2L Platform and/or who have purchased any plan offered by SKILLCORE for using the P2L Platform;

2. Collection of Personal Data

In order for the services of SKILLCORE to be provided efficiently and with quality and aiming, always, at constant improvement, as well as for supporting our advertising and marketing activities, we collect personal data and information from our users, from the devices they use, and from their locations. This collection can occur directly and voluntarily when users fill out forms with their personal data.

This collection can also be done automatically by SKILLCORE, especially data/information about electronic devices, browsers used, and their locations, without a form being filled out for this purpose. Moreover, SKILLCORE may collect data/information from users through other sources that the user has authorized for sharing personal data (e.g., when the user registers via social media API) or collect public personal data.

Visiting our websites, installing our mobile applications, and providing personal data are optional, but to use some of SKILLCORE's services, providing certain personal data is essential, such as subscribing to a P2L Platform plan.

2.1 Collection of Personal Data Provided by the User

SKILLCORE collects personal data provided by the user when the user:

• (i) Registers or logs into their account created on the P2L Platform;

• (ii) Creates and/or edits their user profile on the P2L Platform;

• (iii) Makes a financial transaction through the P2L Platform;

• (iv) Contacts our customer service;

• (v) Provides personal data for inviting new users, for inputs intended for the system, and in documents used on the P2L Platform;

• The personal data that can be collected this way by SKILLCORE are:

• (i) Full Name;

• (ii) CPF;

• (iii) Email;

• (iv) Address;

• (v) Phone number;

• (vi) Credit/debit card data, PIX key, payment tool account data (e.g., PayPal, pagseguro), etc., and other billing data depending on the payment tool used;

• (vii) Other personal data provided by the user at their sole discretion;

All data collected will be incorporated into SKILLCORE's database, which will be responsible for its storage.

2.2 Automatic Collection of Personal Data

SKILLCORE automatically collects data from the user and their device when you use our services and/or when accessing our platform. We collect this information to understand how you use our services and electronic devices, such as computers, smartphones, tablets, and others. The data that can be collected this way by SKILLCORE are:

• (i) IP Address;

• (ii) Device location;

• (iii) Attributes of the electronic device used by the user, such as operating system, browser type, among others;

• (iv) Usage-related data, such as: web registration data indicating entry and exit pages, type of platform used, the number of clicks, accessed domain names, landing pages, viewed pages in order, the time the user stays on each page, date and time of service use, frequency of service use, error events, and other similar information;

2.3 Cookies and Similar Technologies

SKILLCORE may use cookies or similar/related technologies (e.g., tracking pixels, web beacons) to store and collect information. 

SKILLCORE also allows third parties to use cookies and similar technologies in conjunction with our services for the following purposes:

• (i) Analytics: SKILLCORE uses services like Google Analytics and others, which use cookies to collect usage data to understand and enhance the experience of users of our services. In these cases, data such as: pages visited, time spent on pages, means by which the user arrived at the P2L Platform page, among others;

• (ii) Personalized Advertising: third parties whose products and/or services are offered through the P2L Platform may use and read cookies to collect information in order to target personalized ads based on previous visits to the P2L Platform and assess the performance of ads made. Similarly, SKILLCORE also relies on services from third parties, like Google, which may promote personalized ads to users on other sites based on cookies captured when accessing our services. However, SKILLCORE has no control over the technologies used by these third parties, and this Privacy Policy does not apply to them.

2.4. Data Collected from Third Parties

SKILLCORE may collect data about its users from other sources, such as:

• (i) Partners, researchers, and others who are legally authorized to share their information with SKILLCORE (e.g., if access is made to our services via a third-party website/mobile app/API, it may provide us with your data);

• (ii) Users: some users may provide personal data of third parties and other users when performing tasks on our platforms (e.g., indicating colleagues/coworkers to participate in certain training);

• (iii) Public Data: publicly accessible data and data made publicly available by the owner can be collected by SKILLCORE without the prior consent of the owner, observing the guiding principles of privacy protection;

3. Data Processing

As noted above, SKILLCORE collects and uses data from its users (only those minimally necessary) with a single clear purpose: to provide an efficient, high-quality service with constant improvement. In this sense, here are examples of the purposes for which the collected data are used:

• (i) Provide the services of the P2L Platform and enhance the AI tool used;

• (ii) Provide online payment options for users of the P2L Platform; 

• (iii) Enhance the user experience in navigating the P2L Platform and using SKILLCORE's services;

• (iv) Send promotional advertisements about products and services that may be of interest to users via email, notifications, SMS, and other means of communication;

• (v) Choose and present personalized ads;

• (vi) Conduct raffles and contests;

• (vii) Prepare statistics without identifying users;

• (viii) Develop new features, services, and products;

• (ix) Correct problems with our services;

• (x) Manage all SKILLCORE's platforms and tools;

• (xi) Prevent, investigate, and respond to: fraud, unauthorized access and use of our services, violations of our terms, policies, and contracts, and any other types of malicious and irregular behaviors occurring on our platforms, including through inserting the user's personal data (name, email, CPF) in watermarks on the licensed and available content on the platform to inhibit its improper exploitation;

• (xii) Establish, defend, and/or exercise rights in administrative and/or judicial settings;

• (xiii) Comply with legal obligations relevant and applicable to SKILLCORE's operations that require retaining certain data for a certain period;

SKILLCORE may also take steps to remove and/or anonymize part of the data to avoid identifying the owner, to whom this Privacy Policy does not apply.

3.1. Authorizing Hypotheses

SKILLCORE typically processes personal data (i) only when there is clear consent to do so, (ii) when we need the information to perform our functions related to the services contracted and accepted by users, (iii) when there are legal obligations that require it, or (iv) when processing this data is based on our legitimate interest and does not violate the rights of our users. In certain cases, however, we will have a legal obligation to collect and/or retain personal data to protect the vital interests of our users. 

4. Data Sharing

SKILLCORE may share the collected data in certain situations. Below are these situations:

• (i) Third-party Vendors: the personal data we have access to may be shared with other companies that provide some type of support to SKILLCORE, such as database technology, advertising systems, authentication systems, payment systems, fraud detection services, customer support services, shipping services, among others. All of our vendors will be committed to protecting the personal data they have access to and may not use it for purposes other than those determined by SKILLCORE and known by the owners; 

• (ii) Legal Obligations: the personal data we have access to may be shared to comply with legal obligations or by judicial order. Occasionally, SKILLCORE may share personal data when there is a threat to the physical safety of any person and/or violations of this Privacy Policy or other terms, contracts, and policies of SKILLCORE, as well as to protect the rights of third parties, such as our users, employees, and other individuals and/or legal entities;

• (iii) Corporate Operations: we may share data collected during corporate transactions such as mergers and/or acquisitions when there is a sale and/or evaluation of our assets. Any change in control of SKILLCORE will be notified to our users;

• (iv) Consent: we may share personal data in other ways if the data owner has requested us to do so or has given us their express and unequivocal consent;

• (v) Public Data: we may share publicly accessible personal data or those made manifestly public by the owner;

• (vi) Employers / Organizations: we may share collected data with employers and/or organization leaders when the data owner registers as an employee, representative, and/or member of a company and/or organization using a corporate email (e.g., name@organizationname.com.br);

5. Data Retention

SKILLCORE will retain the collected personal data only for as long as necessary for the purposes of its processing, which may vary according to the treatment carried out, or until a request for removal/deletion of data made by the owner, except for any legal requirements for data retention, such as, but not limited to, those provided for in Law No. 12.965/2014 (Legal Framework of the Internet).

If there are technical limitations that prevent the deletion or anonymization of personal data, SKILLCORE will make every effort to protect such data and limit its access and use.

6. Options for Limiting/Altering the Owner

The data owner who uses the licenses and services offered by SKILLCORE has options to change and limit the collection and use of their data, as illustrated below:

• (i) Profile: the owner does not need to provide data beyond what is necessary for the desired services to complete their registration on the P2L Platform. The owner can always review and change the data provided in their registration/profile;

• (ii) Promotional Advertisements: the owner can always choose not to receive messages and promotional advertisements via email marketing, push notifications, messaging apps and/or SMS, an option that will be offered in the advertisements received;

• (iii) Cookies and similar technologies: the owner can reject the option of collecting cookies and similar technologies through their browser. The owner who opts not to provide such data acknowledges that they will not enjoy part of the benefits contained in our services;

• (iv) Information about devices and browsers: the owner can turn off the option for sharing the location of their devices, change privacy settings on their devices, and/or refuse to share location in their browser;

• (v) Account Closure: the owner can always close their account on the P2L Platform whenever they wish, an option available in the profile settings panel. If the owner has a pending transaction on the P2L Platform, SKILLCORE may condition the full closure of such account to the completion of the transaction;

• (vi) Complaints: the owner can make requests/complaints to SKILLCORE whenever they feel their rights are being affected, according to the contact information of our privacy department cited below;

7. Other Rights of the Owner

In addition to the rights provided for in other sections of this Privacy Policy, owners will have the following rights, which will be fully addressed by SKILLCORE within its operational and technical capabilities and in reasonably expected time frames:

• (i) The owner can access and review personal data associated with their account at any time;

• (ii) The owner can request the following information to be provided in reports in electronic and/or printed formats: what forms their personal data is processed, what the purposes of processing their personal data are, what categories of their personal data are processed, who are the recipients of their processed personal data, how their processed personal data is received, how long we use and/or store their personal data;

• (iii) The owner can request correction of their personal data;

• (iv) The owner can request deletion and/or cessation of use of their consented personal data;

• (v) The owner can prevent the export of their consented personal data;

• (vi) The owner can, with respect to consented personal data, refuse to give such consent or revoke consent already given, respecting the legality of treatments carried out during the validity of consent;

• (vii) The owner can request the portability of their personal data to send to other service providers, if there is technical compatibility;

• (viii) The owner can request a review of decisions made by natural persons when the decisions to be reviewed involved the analysis of personal data and were made by automated systems and, in some way, affected the legitimate interests of the owner;

To exercise these and other rights, any interested party can contact SKILLCORE through its privacy department.

SKILLCORE may delay responses to requests made by users based on the rights above if there are any pending issues that may cause harm to SKILLCORE and/or third parties.

8. Provision of personal data in the inputs of the P2L Platform

Due to the characteristics of the AI tool provided by the P2L Platform, the user will have the freedom to provide the inputs they deem necessary to obtain the desired outputs, which may include any personal data of themselves or third parties. 

The P2L suggests that the user refrain from providing personal data, especially of third parties, in the inputs formulated for the P2L Platform. If the user chooses to do so, they declare and guarantee that they have the necessary prerogatives for providing the personal data submitted to the P2L Platform to be processed by SKILLCORE, assuming full responsibility for any infringement of this guarantee.

SKILLCORE may, if deemed appropriate and following its operational guidelines, reject or adopt anonymization techniques and similar measures for personal data listed in the inputs provided by its users, which may affect the results of the outputs generated by the P2L Platform.

9. Data of Children

The P2L platform was not developed for children. Thus, SKILLCORE does not intentionally request or collect children’s data, nor does it allow, intentionally, children to use its platform.

At the time of registration of the owners, they will confirm that they have full legal capacity to enter into commitments. 

SKILLCORE will immediately delete any data it has access to that belongs to children. In this same sense, SKILLCORE encourages all its users to report situations that may involve children's data on our platform by submitting a report to our privacy department, according to the contact information below.

10. Security and Protection Measures

To keep our users' information secure, SKILLCORE employs physical tools (e.g., different storage environments), electronic tools (e.g., encryption, firewalls), and administrative measures (e.g., access hierarchy, access control).

The SKILLCORE team is fully aware of this Privacy Policy, and only qualified and authorized personnel are permitted access to the treated personal data under threat of facing disciplinary action in case of violation of the norms herein.

Similarly, SKILLCORE requires its suppliers and partners to guarantee protection and privacy of data as assured in this Privacy Policy for those who have, in any way, access to the personal data treated by SKILLCORE.

However, despite adopting various protection and security mechanisms, the internet and our services are not 100% secure. For this reason, we cannot guarantee that the data we process will always be protected from unauthorized access and use.

SKILLCORE commits to notify affected or possibly affected owners whenever a failure occurs that leads to a data breach, explaining the nature of the event that occurred, the possible leaked data, and explaining what measures will be taken in response to the reported situation, providing ample support to its users.

11. Changes to this Privacy Policy

SKILLCORE may change this Privacy Policy to meet any legal changes, as well as any changes in our organization, our services, our data processing practices, and the technologies employed by SKILLCORE.

Any substantial changes to this Privacy Policy that may affect in any way the rights of personal data owners processed by SKILLCORE will be notified to the owners by email and/or through another form of communication chosen by the owner.

12. SKILLCORE's Trade Secret

SKILLCORE utilizes a series of methods, plans, source codes, algorithms, structures, information, and other knowledge developed and acquired throughout the assembly of its business, which are true competitive differentiators. A large part of this set of assets, which is not publicly known, forms a trade secret of SKILLCORE, which is kept confidential in SKILLCORE's operations, being known entirely only by key people in the company who have signed confidentiality and non-disclosure agreements, which include provisions for severe penalties in case of improper disclosure.

Thus, it should be clear to the personal data owners processed by SKILLCORE that some of their data is processed through tools composed of this trade secret, which must be respected when making requests for disclosure and/or providing information. For this reason, sometimes the information requested by the owner may not be provided in full and/or in the desired format, without prejudice to the rights of the personal data owner.

12. Contact – Privacy Department

SKILLCORE has a specific department to handle any issues related to Privacy and Personal Data Protection. For questions, complaints, or any other contact related to this topic, interested parties can contact our privacy department via the channels below:

p2l@skillcore.pro

14. General Provisions

Any issues arising from this Privacy Policy and any issues related to the protection of personal data are governed by Brazilian Law.

All those who, in any way, have an interest in claiming any rights related to the protection of personal data are subject to the jurisdiction of the District of Curitiba/PR.