Privacy Policy

This Privacy Policy is valid in its current form December 19, 2023.

This Privacy Policy applies to the collection of your personal data, as well as the use of "cookies" and similar technologies as part of the SkillUp application ("Application" or "SkillUp"). The Controller of your personal data & the Application Operator is Skill-Up Sp. z o.o. with its registered office in Warsaw, Plac Europejski 1/p40, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw, in Warsaw, 13th Commercial Division of the National Court Register, under the number 0000837685 ("Skill-Up" or „We").

Protecting your privacy is our priority!

We realize that your privacy protection is very crucial to you and that you have the right to control what information about you next we process and how we do it. We know that providing us with personal data is an act of trust from you and we take this trust very seriously. SkillUp is committed to never selling, leasing or otherwise disclosing your personal information, except as described in this Privacy and Cookie Policy, and only if there is a legal basis for such disclosure (your consent or legal obligation). SkillUp is the administrator of your personal data and takes appropriate measures to ensure the security of your data.

By installing and starting to use the Application or continuing to use our services after the publication of new versions of this Privacy Policy (as the case may be), hereby you confirm that you have read and committed to comply with the regulations of the Privacy Policy. This document constitutes our complete and exclusive Privacy Policy and supersedes any prior versions. This Privacy Policy forms part of our Terms of Service and should be read in conjunction with them and any additional terms that apply to our services.

In justified cases, we may be required to make changes to our Privacy Policy (for example, in case of significant changes in the functioning of our services or Applications, or as a result of changes in law in general). We will notify you of the above-mentioned changes via e-mail or via a pop-up window in the application, as well as by posting an updated Privacy Policy on the website We recommend you to review this Privacy Policy regularly.

If we use your personal information in a way that is materially different from that specified at the time it was collected, we will notify you by email or via a pop-up window in the Application. The date this Privacy Policy was last updated can be seen at the top of the first page of this document.

What data do we process

When you use our services, we collect the following personal data:

  • Registration data: your e-mail address and password. We process this information to create and manage your user account, to contact you, as well as to enable you to make payments for our services. We only use payment information, such as credit card numbers, to complete a specific transaction or service and to prevent any fraud or misuse connected with using our services. Providing registration data is mandatory - otherwise, it will not be possible to provide services to you.

Legal basis for processing: The processing of your registration data is necessary in order to conclude and perform the contract concluded with you (i.e. to create your user account and offer services in connection therewith).

  • Data collected when you use our services: when you use our services, we collect information about your subscription made in the App and about the actions you have taken and take on SkillUp. We collect the above data in order to: (i) adjust our services to your needs, which is the essence of the services we provide, (ii) improve our relationship with you (iii) provide the best possible user experience by continuously improving our services, adapting content and materials advertising (iv) identifying the content you provide when using our services (v) compiling aggregate data for internal and external business purposes (vi) conducting research.

Thereby, your personal data can be profiled, which means that we can use the collected data to adapt the services we provide to your needs. In such cases, we do not use your personal data in a way that would effect in automated decision making that could affect your rights, produce legal effects or otherwise concern you (i.e. we do not use algorithms to make decisions that would influence on your individual rights or would materially affect your legal status or rights under a contract between us). Providing the aforementioned data is necessary if you want to use services tailored to your needs - otherwise, it will not be possible to provide content tailored to your needs.

Legal basis for processing: (i) performance of the contract concluded with you regarding data processing in order to adapt services to your needs; (ii) our legitimate interest in the direct marketing of our services in relation to the processing of your data in order to personalize advertisements.

Marketing activities. We also process your data for general marketing purposes, i.e. to send you advertising e-mails, unless you have opted out of this form of communication. By processing your data for the above purpose, we pursue our legitimate interest in the direct marketing of our own services, which is the legal basis for the processing of your data. Providing personal data is non-mandatory, but if you do not provide your e-mail address, then we will not be able to contact you.

Legal basis for data processing: our legitimate interest in the direct marketing of our services.

  • Login data. When you use the Services, our servers automatically record information that your browser sends each time you connect to a website or online service ("Login Information"). Login data may include, but is not limited to: the IP address of the user"s computer, the type of browser, the website visited before entering one of the Sites, and the information you search for on the Site. We process the above data to ensure security, save your preferences and for general marketing purposes.

Legal basis for data processing: our legitimate interest in (i) security; (ii) direct marketing of our services.

  • Data collected from Facebook. If you choose to log into the Application via Facebook, we will collect your data in the form of your username, email address and profile picture. We will process the above data in order to enable you to log in to our websites. We do not collect any other personal information from Facebook, but we may use Facebook analytics services based on anonymous, aggregated datasets.

Legal basis for processing: the processing of your data is necessary in order to conclude and perform a contract with you (i.e. to create your user account and offer services in connection with it).

Your rights

  • You have the right to object to the processing of personal data on the basis of a legitimate interest (in particular in the case of processing for marketing purposes). In addition, you are entitled to request us to make corrections or even delete your data if we find that certain information about you is incorrect or out of date. In addition, you have the option of updating and correcting your personal data directly in your user account in the Application settings panel.

  • If your data is processed on the basis of your consent, you have the right to withdraw it at any time, and the withdrawal of consent does not affect the lawfulness of the processing carried out before its withdrawal.

  • If you submit a request to stop processing your data and delete it, we will act in accordance with your request, unless there is an important overriding legal interest (e.g. defense against claims or the existence of a legal obligation to retain data, e.g. for accounting or tax purposes) which will entitle us to retain your personal data for a longer period of time. You also have the right to access your data, request a copy of the data we process, as well as the right to transfer data and limit their processing.

  • We process your personal data only for the purpose for which it was collected and only for as long as it is necessary. When the appropriate period of storage of your personal data is being determined, we take into account, among others: the following criteria: (i) whether you express an ongoing interest in our services, (ii) whether you still have an account with us and whether you use it, (iii) whether there are specific legal obligations to store your data (e.g. for accounting and tax purposes) ).

  • We entrust the processing of your personal data to entities that act on our behalf and solely on the basis of our instructions (data processors). Specifically, we use data processors that we have already carefully selected to store your data on secure servers located within the EU. Appropriate safeguards are applied, in particular, only trusted and proven processors and sign data processing agreements with them in accordance with the provisions of the GDPR are selected.

  • Your personal data are shared with payment service providers in order to process your payments. The transfer of data takes place on the basis of our legitimate interest and because it is necessary to perform the contract concluded with you. We may also be required to provide your personal data to the competent authorities (in particular the police or prosecutor's office), if they so request, but only if there is an appropriate legal basis for providing them with your personal data (e.g. court order).

  • SkillUp may also be required to share your information in the event of acquisition or disposal of subsidiaries or business entities in connection with the execution of market transactions, including sale, consolidation, acquisition or disposal of assets, internal restructuring or in the unlikely event of insolvency. In the event that the above-mentioned transaction or event requires the transfer of information about customers, this information will continue to be protected by the then-current Privacy Policy or its equivalent. You will be notified in advance of the disclosure of information in the above manner.

  • If you have any questions about our processing of your data, or if you wish to exercise your rights, you can contact us at [email protected]. In addition, you are entitled to lodge a complaint with the data protection authority.

Use of cookies and similar technologies

  • In order to improve the operation of the Application, we use cookies, web beacons, device fingerprinting and similar technologies. We also use Google Analytics tools.

  • Cookies are text files containing small amounts of information that are downloaded to your personal computer, mobile phone or other device when you visit a website. On each subsequent visit, cookies are then sent back to the originating website or to another website that recognizes the cookie. Cookies are useful because they allow a website to recognize a user's device. Cookies do many different jobs, such as allowing you to navigate between pages efficiently and remembering your preferences. In general, they serve to improve the user experience of websites. They can also help ensure that the advertisements you see on websites are more relevant to your interests. The website uses the following types of cookies:

    • Persistent cookies - these files remain on the user's device for the time specified in the file. They are activated each time the user visits the website that created the cookie.

    • Session cookies - these cookies allow website operators to analyze the user's activities during a given browser session. The browser session starts when the user opens the browser window and ends when the browser window is closed. Session cookies are created temporarily. After closing the browser, all session cookies are deleted.

    • Strictly Necessary Cookies - These cookies enable the provision of services that you have explicitly requested. For those types of cookies that are strictly necessary, your consent is not required. These files are necessary to enable you to navigate the Site and use its functionalities, including accessing secure areas of the Site. Without these cookies, services you have requested, such as shopping carts or e-billing, cannot be provided.

    • Performance cookies - These cookies collect anonymous information about the pages you visit. By using the Site, you consent to us placing these types of cookies on your device. These cookies collect information about how visitors use the Site, including, for example, which pages visitors view most often and whether they receive error messages on web pages. These cookies do not collect information that identifies the visitor. All information collected by these cookies is aggregated and therefore anonymous. They are used only to improve the functioning of the Website.

    • Functionality cookies - These cookies remember choices made by the user in order to improve the user experience on the website. By using the Site, you consent to us placing these types of cookies on your device. These cookies enable our Site to remember your choices (e.g. username, language or region) and to provide better and more personalized features. They can also be used to remember changes you make in terms of text size, fonts and other page elements that are subject to personalization. They may also be used to provide services you have requested, such as displaying videos or posting comments on a blog. The information collected by these cookies may be anonymized and cannot track your activity on other websites.

      • Web beacons (also known as pixel tags) are transparent graphic files used to monitor your interaction with the Website and its content.

      • Device fingerprinting means a technology that allows us to collect information about your device (what browser or operating system you use, what plug-ins you have installed, time zone and other settings). We use this information to identify you and to ensure the security of our website.

      • Cookies and similar technologies (web beacons, device fingerprinting) are used for statistical purposes, to adjust the content, operation and structure of the website to the individual preferences of users, as well as to provide users with advertising content adjusted to their preferences. Cookies and web beacons used to personalize ads may be linked to other online services or social media platforms such as Facebook. Please note that cookies may collect personal information to improve the functionality of the website. This data is stored in encrypted form and access to it is limited. Cookies used by third parties through the Website, including in particular in relation to users, are subject to the privacy policies of the relevant third parties.

      • The handling and use of cookies and similar technologies are allowed by default. However, these settings can be changed at any time. Detailed information on the handling and use of cookies can be found in the web browser settings. More information about cookies and similar technologies and how to disable them in your browser can be found at:

      • Google Analytics: We use third-party tracking tools that tell us that users have visited the Products by "clicking" on our sponsored ads or content hosted on third-party platforms. The products use Google Analytics & Firebase to collect statistical information. The Google Analytics tool sends cookies to help us accurately estimate the number of people visiting the Products and the scale of their use. The purpose of the above actions is to ensure that the Products will always be available when you want to use them. More information on how Google Analytics processes the above-mentioned information can be found at

      • To better understand the functionality of our mobile software on your smartphone, we use mobile analytics software. This software may record information such as how often the Products are used, events occurring in the Products, aggregate usage and performance data, and where the Applications were downloaded from. We may associate the information stored in the above-mentioned analytics software with the personal information you submit in the mobile application.

      • For the above purposes, we may require you to provide us with the following information:

        • Android Advertising ID.

        • Apple's Advertising Identifier (IDFA)

        • Personal data, including email address and information about the use of the Products and information collected by tracking technologies.

        • Device information such as operating system version, device type, and system performance information.

      • The information we request will be preserved and used by us in accordance with this Privacy Policy. The application uses third party services that may collect information used to identify you. Below are links to the privacy policies of external service providers used by the Application:

        • Google Play Services

        • Apple's Privacy Policy