PRIVACY POLICY

INTRODUCTION

Skills Oxygen LLP ("Skills Oxygen", "Company", "we", "us", or "our") operates a technology-driven, AI-enabled digital platform and provides skill development, employability enhancement, institutional partnership, industry collaboration, advisory & consultancy, business process improvement, project management and operations excellence services.

This Privacy Policy is intentionally drafted in an exhaustive, layered, repetitive, and defensive manner to ensure maximum transparency, clarity, and legal protection for Skills Oxygen LLP across jurisdictions.

By accessing, registering on, browsing, interacting with, or otherwise using the Platform or Services, you expressly acknowledge that you have read, understood, and agreed to this Privacy Policy in full.

1. PLATFORM ROLE, SERVICE SCOPE & LEGAL POSITIONING

Skills Oxygen LLP acts strictly and exclusively as a technology intermediary, an AI-assisted facilitation platform, and providing advisory and consultancy services.

For the avoidance of doubt and without limitation, Skills Oxygen LLP:

• Does not act as an employer, recruiter, staffing agency, placement agency, employment exchange, academic institution, training provider, certification authority, or regulator.
• Does not employ, recruit, shortlist, select, or hire individuals.
• Does not admit, certify, accredit, validate, or award academic or professional credentials.
• Does not control, verify, authenticate, endorse, validate, or guarantee user-provided information, claims, qualifications, skills, or representations.
• Does not supervise, manage, influence, or control employer, institutional, or third-party decision-making processes.
• Does not guarantee employment, placement, income, compensation, academic success, institutional outcomes, operational efficiency, business performance, or results of any kind.

All employment decisions, academic decisions, institutional decisions, business decisions, operational decisions, and regulatory decisions are taken solely, independently, and entirely at the discretion of the relevant user, institution, or industry partner.

1.1 ADVISORY, CONSULTANCY & SERVICES DELIVERY FRAMEWORK

In addition to operating the Platform, Skills Oxygen LLP provides advisory, consultancy, assessment, training, facilitation, diagnostic, implementation-support, and improvement services.

All such services are provided strictly on a best-effort, non-deterministic, non-binding, and advisory-only basis.

All Services are advisory, facilitative, analytical, informational, and support-oriented in nature.

Nothing provided by Skills Oxygen LLP — including reports, assessments, audits, analytics, AI outputs, training materials, counselling sessions, recommendations, introductions, communications, or facilitation — shall be construed as legal advice, financial advice, statutory advice, regulatory assurance, employment or placement guarantee, or guaranteed professional, academic, operational, or business outcome.

1.2 NO GUARANTEE, NO ASSURANCE & NO RELIANCE

Skills Oxygen LLP expressly disclaims all guarantees, warranties, representations, or assurances, whether express or implied, statutory or otherwise, including but not limited to guarantees relating to:

• Employment, placement, hiring, engagement, retention, promotion, or compensation outcomes
• Business performance, profitability, productivity, revenue growth, or cost reduction
• Institutional rankings, affiliations, accreditations, or regulatory approvals
• Project timelines, milestones, delivery schedules, or operational efficiency
• Skill acquisition, competency achievement, certification outcomes, or employability results.

All outputs, recommendations, assessments, analytics, AI-generated insights, and advisory inputs are based entirely on information, data, assumptions, and representations provided by users, institutions, or industry partners.

Any reliance placed on such outputs is undertaken solely at the user's own discretion, judgment, and risk.

2. APPLICABILITY & USER CATEGORIES

This Privacy Policy applies to, and governs data practices relating to:

• Individuals (job seekers, trainees, professionals, candidates)
• Institutions (educational institutions, training providers, academies)
• Industry partners (employers, recruiters, companies, organizations)
• Authorized representatives, officers, and signatories
• Visitors, prospects, and any other persons accessing or using the Platform

Each category acknowledges that the scope, purpose, legal basis, and extent of data processing may vary depending on role, relationship, contractual arrangement, and applicable law.

3. INFORMATION WE COLLECT

Skills Oxygen LLP collects a wide range of personal, institutional, business, and technical data, including but not limited to:

• Identity and contact information
• Educational qualifications, skills, certifications, and assessments
• Employment history, preferences, and career objectives
• Institutional records, student or trainee data, and skill metadata
• Business, operational, and workforce-related data
• Communications, platform interactions, usage logs, cookies, analytics, and AI-generated insights

Institutions and industry partners represent and warrant that they have obtained all necessary consents and authorizations before sharing any personal data and agree to fully indemnify Skills Oxygen LLP against any claims arising from unauthorized disclosure.

4. AI, MACHINE LEARNING & AUTOMATED PROCESSING

The Platform utilizes artificial intelligence, machine learning models, algorithms, and automated systems to support matching, ranking, scoring, recommendation, analytics, and insight generation.

AI outputs are:

• Probabilistic and non-deterministic
• Dependent on the quality and completeness of input data
• Informational and assistive only

Skills Oxygen LLP does not engage in solely automated decision-making that produces legal or similarly significant effects. Human judgment remains essential in all employment, academic, institutional, and business decisions.

5. PURPOSES OF DATA PROCESSING

Data is processed for multiple legitimate purposes, including but not limited to:

• Account creation, authentication, and platform access
• Platform operations and service delivery
• AI-based matching, analytics, and recommendations
• Advisory and consultancy services
• Security monitoring, fraud prevention, and risk management
• Compliance with legal and regulatory obligations
• Dispute resolution and continuous improvement of the Platform

6. LAWFUL BASIS FOR PROCESSING

Data processing is carried out on one or more lawful grounds, including:

• User consent
• Contractual necessity
• Legitimate business interests
• Compliance with applicable legal and regulatory obligations

7. USER INTERACTIONS, NON-CIRCUMVENTION & COMMERCIAL SAFEGUARDS

Users acknowledge that the Platform facilitates introductions, discovery, and matching.

Users shall not directly or indirectly circumvent the Platform by engaging outside the Platform with another user where the connection originated through the Platform.

Where any hiring, placement, consultancy, project engagement or business relationship arises directly or indirectly from the Platform:

• Both parties are obligated to disclose such engagement to Skills Oxygen LLP
• Applicable facilitation, success, or service fees shall remain payable in accordance with the user's plan or contract
• Fees remain payable even if the engagement is concluded off-platform, after subscription expiry, or through direct communication

8. DATA SHARING, DISCLOSURE & ACCESS CONTROL

Skills Oxygen LLP may disclose, share, transfer, or otherwise provide access to personal data and business data only to the extent necessary to operate the Platform and deliver the Services, and strictly in accordance with this Privacy Policy and applicable law.

All disclosures are governed by the principles of purpose limitation, data minimization, access control, confidentiality, and proportionality.

Without limitation, personal data and business data may be disclosed to:

• Employers, recruiters, institutions, and industry partners for the purpose of facilitating discovery, matching, engagement, hiring, training, internships, apprenticeships, consultancy, or business collaboration
• Technology service providers, including cloud hosting vendors, database providers, analytics partners, cybersecurity vendors, AI infrastructure providers, and communication service providers
• Professional advisors, including auditors, consultants, legal counsel, accountants, insurers, and compliance advisors engaged by Skills Oxygen LLP
• Payment processors, financial institutions, and transaction service providers, where applicable
• Government authorities, regulators, law-enforcement agencies, courts, or statutory bodies where disclosure is required by law, regulation, legal process, or governmental request

Skills Oxygen LLP does not sell personal data.

All disclosures are made on a need-to-know basis and are subject to reasonable contractual, technical, and organizational safeguards designed to protect confidentiality and integrity.

9. CROSS-BORDER DATA TRANSFERS & GLOBAL OPERATIONS

Skills Oxygen LLP operates a digital platform with global reach and may store, host, process, or transfer personal data and business data to jurisdictions outside India, including jurisdictions that may have different or less stringent data protection laws than those applicable in India.

By using the Platform and Services, users expressly acknowledge and consent to:

• The transfer of their personal data and business data across national borders
• The storage and processing of such data in jurisdictions outside India
• The application of foreign data protection laws to such processing, to the extent applicable

Skills Oxygen LLP implements reasonable safeguards, including contractual protections and security measures, to protect data during international transfers. However, users expressly acknowledge that absolute equivalence of protection cannot be guaranteed across jurisdictions.

To the maximum extent permitted by law, users waive any objections to such cross-border transfers.

10. DATA RETENTION, ARCHIVING & DELETION

Skills Oxygen LLP retains personal data and business data only for as long as reasonably necessary to fulfil the purposes for which such data was collected, including but not limited to:

• Platform operations and service delivery
• Account administration and user support
• Advisory and consultancy engagements
• Dispute resolution and enforcement of contractual rights
• Audit, compliance, and record-keeping requirements
• Fraud prevention, security monitoring, and risk management
• Compliance with legal, regulatory, and statutory obligations

Data may be retained beyond account termination or service completion where retention is required or permitted by law, contract, or legitimate business interests.

User requests for deletion are not absolute and may be denied, delayed, or partially fulfilled where retention is necessary for legal, regulatory, contractual, operational, or security reasons.

Where deletion is not feasible, Skills Oxygen LLP may anonymize, aggregate, archive, or otherwise render data non-identifiable in a secure manner.

11. USER RIGHTS, LIMITATIONS & RESTRICTIONS

Subject to applicable law, users may request:

• Access to their personal data
• Correction of inaccurate or incomplete data
• Withdrawal of consent where processing is based on consent
• Restriction or objection to certain processing activities
• Deletion of personal data

Users expressly acknowledge that these rights are not unconditional and may be restricted where fulfilment would:

• Conflict with legal or regulatory obligations
• Interfere with contractual commitments or enforcement
• Compromise fraud prevention, security, or risk management efforts
• Prejudice the rights, freedoms, or legitimate interests of other users or third parties

Skills Oxygen LLP reserves the right to:

• Verify the identity of requestors
• Refuse manifestly unfounded or excessive requests
• Charge reasonable administrative fees where permitted by law

12. COOKIES, TRACKING & ANALYTICS TECHNOLOGIES

The Platform uses cookies, pixels, tags, SDKs, web beacons, and similar tracking technologies to:

• Authenticate users and manage sessions
• Enhance platform security and fraud detection
• Collect usage analytics and performance metrics
• Support AI model training and optimization
• Improve user experience and platform functionality

Users may disable cookies through browser or device settings; however, doing so may impair platform functionality, availability, or performance.

Skills Oxygen LLP is not responsible for the privacy practices or data collection activities of third-party analytics, advertising, or technology providers.

13. DATA SECURITY, SAFEGUARDS & USER RESPONSIBILITY

Skills Oxygen LLP implements reasonable technical and organizational security measures designed to protect personal data and business data against unauthorized access, alteration, disclosure, or destruction.

Such measures may include, without limitation:

• Access controls and authentication mechanisms
• Encryption and secure storage practices where appropriate
• Monitoring, logging, and incident detection systems
• Internal security policies and employee training

Despite these measures, users acknowledge that no system is completely secure.

Skills Oxygen LLP shall not be responsible for data breaches or security incidents caused by factors beyond its reasonable control, including cyberattacks, system failures, acts of third parties, or force majeure events.

Users are solely responsible for maintaining the confidentiality of their login credentials and for all activities conducted through their accounts.

14. DATA BREACH RESPONSE & INCIDENT MANAGEMENT

In the event of a data breach or security incident, Skills Oxygen LLP will take reasonable and appropriate steps to:

• Investigate the incident
• Contain and mitigate potential harm
• Restore system integrity
• Notify affected users and/or authorities where required by applicable law

Skills Oxygen LLP shall not be liable for any data breach or security incident caused by factors beyond its reasonable control or by the actions or omissions of users, institutions, industry partners, or third-party service providers.

15. CHILDREN, MINORS & CAPACITY TO CONSENT

The Platform and Services are not intended for individuals under the age of eighteen (18) years.

Skills Oxygen LLP does not knowingly collect personal data from minors. Where personal data relating to minors is provided to the Platform by educational institutions, training partners, guardians, or other third parties, such parties expressly represent and warrant that:

• They have obtained all necessary parental, guardian, institutional, and legal consents
• They are legally authorized to disclose such data
• The disclosure and processing of such data complies with applicable laws

Any use of the Platform by a minor without appropriate authorization shall be at the sole responsibility of the parent, guardian, or institution, and Skills Oxygen LLP expressly disclaims all liability arising from such use.

16. THIRD-PARTY PLATFORMS, LINKS & INTEGRATIONS

The Platform may contain links to, integrations with, or access to third-party websites, tools, software, applications, APIs, or services that are not owned, operated, or controlled by Skills Oxygen LLP.

Skills Oxygen LLP:

• Does not control third-party platforms
• Does not endorse or guarantee third-party services
• Is not responsible for third-party privacy practices, data handling, security standards, content, availability, or conduct

Users acknowledge that access to third-party platforms is at their own risk, and that such platforms are governed by their own terms, policies, and practices.

17. POLICY MODIFICATIONS, UPDATES & CONTINUED USE

Skills Oxygen LLP reserves the right to modify, amend, update, or replace this Privacy Policy at any time to reflect changes in:

• Applicable laws or regulations
• Business practices or service offerings
• Technological infrastructure or security requirements
• Operational or compliance needs

Any modification shall become effective immediately upon publication on the Platform or website, unless stated otherwise.

Continued access to or use of the Platform after such publication constitutes deemed acceptance of the revised Privacy Policy.

18. INDEMNIFICATION

Users agree to indemnify, defend, and hold harmless Skills Oxygen LLP, its partners, designated partners, directors, officers, employees, consultants, contractors, and agents from and against any and all claims, demands, actions, damages, losses, liabilities, penalties, fines, costs, and expenses, including reasonable legal fees, arising out of or relating to:

• Any breach of this Privacy Policy, Terms & Conditions, or applicable law by the user
• Any misuse, abuse, or unauthorized use of the Platform or Services
• Any reliance placed on advisory outputs, assessments, reports, recommendations, or AI-generated insights
• Any employment, academic, institutional, business, operational, or regulatory decision taken by the user
• Any unauthorized sharing, disclosure, or processing of personal data by the user
• Any dispute between users, institutions, employers, or third parties

This indemnity obligation shall survive termination of the user's relationship with Skills Oxygen LLP.

19. LIMITATION OF LIABILITY

To the maximum extent permitted by applicable law, Skills Oxygen LLP shall not be liable for any direct, indirect, incidental, consequential, special, exemplary, or punitive damages whatsoever, including but not limited to:

• Loss of employment, placement, income, revenue, profits, or business opportunity
• Loss of academic opportunity, certification, accreditation, or institutional standing
• Business interruption, operational failure, project delays, or implementation failure
• Errors, inaccuracies, biases, limitations, or omissions in AI outputs, analytics, assessments, or recommendations
• Decisions taken by employers, institutions, regulators, or other third parties
• Any off-platform communications, engagements, contracts, or arrangements
• Reputational harm, loss of goodwill, or indirect economic loss

Users expressly acknowledge that Skills Oxygen LLP's role is limited to facilitation, analytics, and advisory support, and that all risks associated with the use of the Platform and Services are assumed entirely by the user.

20. GRIEVANCE REDRESSAL

In accordance with applicable law, Skills Oxygen LLP has appointed a Grievance Officer to address complaints relating to personal data processing and privacy.

Grievances shall be acknowledged and addressed within timelines prescribed under applicable law.

21. GOVERNING LAW & JURISDICTION

This Privacy Policy shall be governed by and construed in accordance with the laws of India.

Courts located in India shall have exclusive jurisdiction over any disputes arising out of or in connection with this Privacy Policy.