COOKIE POLICY

This Cookie Policy explains how Skills Oxygen LLP, operating under the brand name SkillO ("SkillO", "we", "us", or "our"), uses cookies and similar tracking technologies on the SkillO website, platform, and digital services (collectively, the "Platform").

For the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act"), Skills Oxygen LLP acts as a Data Fiduciary, and users of the Platform are Data Principals.

This Cookie Policy should be read together with our Privacy Policy and Terms and Conditions.

1. WHAT ARE COOKIES?

Cookies are small text files placed on your device (computer, mobile phone, tablet, or other internet-enabled device) when you access the Platform. Cookies enable the Platform to recognize your device, maintain sessions, remember preferences, enhance security, and improve overall functionality.

Cookies may be:

• Session cookies, which are deleted when you close your browser, or
• Persistent cookies, which remain on your device until they expire or are deleted

Cookies do not provide SkillO access to your device or personal files.

2. PURPOSE OF USING COOKIES (DPDP ALIGNMENT)

SkillO uses cookies for purposes that are lawful, specific, and necessary for the functioning of the Platform, including:

• Enabling core platform functionality and service delivery
• Authenticating users and managing sessions
• Maintaining platform security and preventing fraud or misuse
• Remembering user preferences and settings
• Analyzing platform usage to improve performance and user experience
• Supporting analytics, system optimization, and AI-enabled insights
• Complying with legal, regulatory, and contractual obligations

Cookies are not used for unlawful purposes or in a manner inconsistent with this Policy.

3. TYPES OF COOKIES USED

3.1 Strictly Necessary Cookies (Legitimate Use)

These cookies are essential for the operation of the Platform and are processed under legitimate use as permitted under the DPDP Act. They enable:

• Secure login and authentication
• Session continuity
• Access to protected areas of the Platform

Disabling these cookies may result in the Platform not functioning correctly.

3.2 Performance and Analytics Cookies

These cookies collect information about how Data Principals interact with the Platform, such as pages visited, time spent, and technical errors.

The data collected:

• Is used in aggregated or anonymized form where feasible
• Helps SkillO understand usage patterns and improve services
• Does not independently identify a Data Principal unless combined with other data

3.3 Functional Cookies

Functional cookies allow the Platform to remember preferences such as language, region, or prior selections to provide a more consistent and personalized experience.

3.4 Security and Fraud Prevention Cookies

These cookies are used to:

• Detect suspicious activity
• Protect user accounts
• Prevent unauthorized access
• Maintain the integrity and safety of the Platform

Such processing is undertaken as a reasonable security safeguard under the DPDP Act.

3.5 Third-Party Cookies

SkillO may permit third-party service providers (such as analytics, hosting, or security partners) to place cookies on the Platform strictly for operational purposes.

SkillO does not control third-party cookies, and their processing is governed by the respective third party's policies. SkillO requires such partners to implement reasonable data protection safeguards.

4. COOKIES, ANALYTICS & AI SYSTEMS

Cookies may support:

• Platform analytics
• Performance measurement
• System optimization
• AI-enabled recommendations and insights

Such processing:

• Is assistive and analytical only
• Does not result in automated legal, employment, or similarly significant decisions
• Does not override human judgment

5. CONSENT & WITHDRAWAL OF CONSENT

Where required under applicable law, SkillO obtains clear and affirmative consent for the use of non-essential cookies.

As a Data Principal, you have the right to:

• Withdraw consent for cookies at any time
• Manage cookie preferences through browser or device settings

Withdrawal of consent may impact certain features or functionality of the Platform.

6. DATA PROTECTION & STORAGE LIMITATION

Information collected through cookies may constitute personal data under the DPDP Act.

SkillO ensures that:

• Cookie data is processed only for identified purposes
• Data is retained only for as long as necessary
• Reasonable technical and organizational safeguards are implemented
• Data is not sold or unlawfully disclosed

7. UPDATES TO THIS COOKIE POLICY

Skills Oxygen LLP may update this Cookie Policy to reflect changes in:

• Applicable laws or regulatory guidance
• Technology or platform functionality
• Business or operational requirements

Updates will be published on the Platform. Continued use of the Platform constitutes acceptance of the updated Policy.

8. GRIEVANCE REDRESSAL & DATA PRINCIPAL RIGHTS

In accordance with the DPDP Act, Data Principals may raise grievances or queries regarding the processing of personal data, including data collected through cookies.

Grievances will be addressed within the timelines prescribed under applicable law.

9. GOVERNING LAW

This Cookie Policy shall be governed by and construed in accordance with the laws of India, including the Digital Personal Data Protection Act, 2023. Courts located in India shall have exclusive jurisdiction.