1. About This Policy

This Privacy Policy is issued by UPSKaiLL AI Technologies Inc., a corporation incorporated under the laws of Canada (the “Canadian Parent”), and its wholly owned subsidiary UPSKaiLL Inc., a Delaware corporation (the “US Subsidiary,” and together “UPSKaiLL,” “we,” “us,” or “our”). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our AI-powered career development and learning platform (the “Service”).

This policy applies to residents of Canada (including Quebec) and the United States. Where your jurisdiction grants specific rights, we identify them explicitly throughout this document.

Important: Certain data sharing described in Section 6 is strictly necessary to deliver the Service. You cannot create an account or use the Service if you do not consent to this sharing. By creating an account, you acknowledge that you have read this Privacy Policy in full and consent to the practices described herein.

2. Privacy Officer

UPSKaiLL AI Technologies Inc. (the Canadian Parent) has designated a Privacy Officer responsible for overseeing privacy compliance across both UPSKaiLL AI Technologies Inc. and UPSKaiLL Inc. (the US Subsidiary). The Privacy Officer is responsible for compliance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Law 25), and applicable US state privacy laws.

To reach our Privacy Officer:

Email: privacy@upskaill.ai — subject line: “Attention: Privacy Officer”

Note: The name of our designated Privacy Officer is available upon written request.

3. Information We Collect

3.1 Information You Provide

Account Information: Name, email address, and password.
Profile Data: Skills, work experience, education, and career goals.
Conversation Data: Messages and interactions with AI coaching, including voice transcriptions.
Documents: Files uploaded for skills assessment or profile completion.
Preferences: Learning preferences, career interests, and notification settings.

3.2 Information Collected Automatically

Usage Data: Pages viewed, features used, and learning progress, including the number, duration, and type (text or voice) of AI coaching and tutoring sessions associated with your account.
Device Information: Browser type, operating system, and device identifiers.
Log Data: IP address, access times, and referring URLs.
Cookies and Tracking Technologies: Used for session management, preferences, and experience improvement. See Section 11 for details.

3.3 Information from Third Parties

OAuth Providers: Name, email address, and profile picture from Google or LinkedIn sign-in.
Partner Organizations: Information shared by connected partner organizations with whom you engage through the Service.

3.4 CCPA Categories of Personal Information

For California residents, we collect the following statutory categories of personal information as defined under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA):

Identifiers: Name, email address, IP address, device identifiers.
Professional and employment-related information: Work history, skills, career goals.
Education information: Educational background and credentials.
Audio and electronic data: Transcriptions of voice interactions from coaching sessions. Note: audio recordings are not stored — only text transcriptions.
Internet or network activity: Usage data and log data.
Inferences: Career recommendations and skills assessments derived from your information.
Sensitive personal information: See Section 8.

4. How We Use Your Information

We use your personal information to:

Provide, maintain, and improve the Service.
Generate personalized career recommendations and coaching using AI.
Match your skills and goals with career paths and job opportunities.
Track your learning progress.
Administer subscription plan allowances and fair-use provisions, including monitoring per-account usage volumes, and detect and prevent abuse of the Service, free trials, and the public demo.
Communicate with you about your account and Service updates.
Analyze usage patterns to improve features and user experience.
Detect, prevent, and address security threats and fraud.
Comply with applicable legal obligations.

5. AI Processing of Your Data

Career Analysis: Your skills, experience, and goals are analyzed by AI to generate personalized career recommendations.
Coaching: Messages you send are processed by AI for real-time coaching. Conversation history is retained to provide contextual responses.
Voice: When you use voice features, your speech is transcribed in real time and the resulting text transcription is processed for coaching purposes. Audio recordings are not stored at any point — only the text transcription is retained.
Skills Assessment: Documents you upload are analyzed by AI to extract and evaluate your skills.

Automated Decision-Making

AI-driven recommendations, skills assessments, and coaching responses are at the core of what UPSKaiLL does. These processes analyze your personal information to evaluate and predict aspects of your professional performance and career prospects. AI Outputs are advisory in nature — they are intended to support, not replace, your own career judgment. See “Your rights” below.

Your rights: All AI Outputs generated by the Service are advisory in nature. They do not constitute “decisions made solely on the basis of automated processing” — they do not bind you, determine any outcome, or affect your legal rights. You retain full decision-making authority at all times and are always free to disregard any AI Output. If you have questions about an AI Output or believe it does not accurately reflect your circumstances, you can contact our support team at support@upskaill.ai and we will look into it with you.

We do not use your personal data to train or fine-tune AI models. We may use aggregated, de-identified data derived from Service usage — which cannot identify you individually — to improve or develop internal tools and Service features.

Public Voice Demo (No Account Required)

Our website offers a short, time-limited voice demo that does not require an account. If you use the demo:

your live audio is streamed to Google LLC (Gemini) in real time solely to power the conversation, under the same Data Processing Agreement described in Section 6 — your audio is not used to train AI models;
audio is not recorded or stored by UPSKaiLL, and demo conversations are not linked to any identity or retained after the session ends; and
we collect your IP address solely to enforce per-user and daily demo limits and to prevent abuse, and we retain it only as long as needed for those purposes.

The demo is not intended for the disclosure of sensitive personal information — please do not share information about third parties or details you would not want processed as described above.

6. How We Share Your Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

However, sharing your data with the third parties listed below is necessary to operate the Service. By creating an account you consent to this sharing as a condition of use. If you do not agree, you will not be able to create an account or access the Service.

AI Providers: Your conversation data, profile data, and documents are shared with our third-party AI providers — including Google LLC (Google Gemini) and Anthropic PBC (Claude) — to generate coaching responses, career recommendations, and skills assessments. These providers process your data on our behalf under Data Processing Agreements that restrict their use of your data solely to services provided to us.
Partner Organizations: When you apply for opportunities or connect with partner organizations through the Service, relevant profile information is shared with those partners.
Service Providers: We share data with third-party vendors providing hosting, analytics, security, and other operational services. These vendors are contractually bound to use your data only as required to provide their services to us.
Legal Requirements: We may disclose your information when required by law, regulation, or court order, or to protect the rights, property, or safety of UPSKaiLL, our users, or others.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your personal information becomes subject to a different privacy policy.

7. Cross-Border Data Transfers

UPSKaiLL operates in Canada and the United States and uses service providers and AI providers located in Canada and the United States. As a result, your personal information may be transferred to and processed in the United States, which has different privacy laws than Canada.

When we transfer personal information outside Quebec or Canada, we take steps to ensure it receives a comparable level of protection to that required under Canadian law, including:

Entering into Data Processing Agreements with service providers that include contractual obligations to protect your information.
Conducting Privacy Impact Assessments (PIAs) as required under Quebec Law 25 prior to transferring personal information outside Quebec.
Verifying that recipient organizations apply adequate safeguards consistent with applicable legal requirements.

If you have questions about our cross-border transfer practices or wish to obtain information about the safeguards in place, contact our Privacy Officer at privacy@upskaill.ai.

8. Sensitive Personal Information

Certain information we process may be classified as sensitive personal information under applicable law, including:

Audio data: Transcriptions of voice interactions from coaching sessions (audio recordings are not stored).
Professional inferences: Assessments of your skills, abilities, and career potential derived from information you provide.

We use sensitive personal information only for the purposes for which it was collected — specifically, to provide AI coaching and career development features. We do not use sensitive personal information for advertising or profiling unrelated to the Service.

California residents have the right to request that we limit our use and disclosure of sensitive personal information to purposes reasonably necessary to provide the Service. To exercise this right, contact us at privacy@upskaill.ai.

9. Data Retention

We retain your personal information for as long as your account is active and as necessary to provide the Service.

If you delete your account, we will delete or anonymize your personal information within 30 days, except:

Where we are required by applicable law to retain it for a longer period.
Where retention is necessary to resolve disputes, enforce our agreements, or for other legitimate business purposes.
Where data has been anonymized such that it can no longer be used to identify you.

Certain log data and usage analytics may be retained in anonymized form after account deletion for product improvement purposes.

10. Data Security

We implement industry-standard technical and organizational measures to protect your personal information, including:

Encryption in transit using TLS/SSL protocols.
Secure password hashing using industry-standard algorithms.
Role-based access controls and authentication requirements.
Regular security assessments and monitoring.

Breach Notification

In the event of a security breach that creates a risk of serious injury to affected individuals, we will:

Notify the applicable privacy authority without undue delay and, where required by law, within 72 hours of becoming aware of the breach — including the Commission d’accès à l’information (CAI) in Quebec and the Office of the Privacy Commissioner of Canada under PIPEDA.
Notify affected individuals as required by applicable law.
Maintain a register of confidentiality incidents as required by Quebec Law 25.

Despite our security measures, no system is completely secure. If you believe your account has been compromised, contact us immediately at privacy@upskaill.ai.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies for the following purposes:

Essential Cookies: Required for the Service to function, including session management and authentication. These cannot be disabled.
Preference Cookies: Remember your settings and preferences. You may disable these through your browser settings.
Analytics Cookies: Help us understand how the Service is used so we can improve it. You may opt out of analytics cookies.

Managing your preferences: You can manage cookie preferences through your browser settings or our cookie preference centre. Disabling non-essential cookies will not affect your ability to use core Service features. We do not use cookies for cross-site behavioral advertising.

Quebec residents: In accordance with Quebec Law 25, your consent is required before we deploy non-essential cookies. You will be prompted to manage your preferences on your first visit to the Service.

12. Your Rights and Choices

You have the following rights regarding your personal information. To exercise any right, contact us at privacy@upskaill.ai with the subject line “Privacy Rights Request.” We will respond within 30 calendar days of receiving your request. For complex or numerous requests, we may extend this period by a further 30 days (60 days total) and will notify you promptly of the extension. This timeline is consistent with PIPEDA and Quebec Law 25. For users in US states whose law provides a longer response window (such as the 45-day period under the CCPA), our 30-day commitment meets or exceeds those requirements.

Right to Access: Request a copy of the personal information we hold about you.
Right to Correction: Request correction of inaccurate or incomplete personal information.
Right to Deletion: Request deletion of your personal information, subject to certain legal exceptions (e.g., where retention is legally required).
Right to Portability: Request a machine-readable copy of your personal information.
Right to Object: Object to certain processing activities, including profiling.
Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time. Note that withdrawing consent for data sharing that is necessary to operate the Service will result in account termination.
Right to De-Indexation (Quebec residents): Request that we cease disseminating your personal information online, or de-index any hyperlink associated with your name, where that dissemination causes you harm.
Right to Limit Sensitive Personal Information (California residents): Request that we limit our use and disclosure of your sensitive personal information to purposes necessary to provide the Service.
Right to Non-Discrimination: We will not deny you service, charge different prices, or provide a lower quality of service based solely on your exercise of any privacy rights.
Authorized Agents (California residents): A California resident may designate an authorized agent to submit privacy rights requests on their behalf. We may require written proof of the agent’s authorization and may verify your identity directly.

Filing a Complaint

If you are unsatisfied with our response to a privacy request, you may file a complaint with the applicable supervisory authority:

Quebec: Commission d’accès à l’information (CAI) — www.cai.gouv.qc.ca
Canada (federal): Office of the Privacy Commissioner of Canada — www.priv.gc.ca
California: California Privacy Protection Agency (CPPA) — cppa.ca.gov

13. Children’s Privacy

The Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from individuals under 18. If we learn that we have collected personal information from a person under 18, we will promptly delete that information and terminate the associated account. The 18-year minimum applies globally; users in jurisdictions where the age of majority exceeds 18 must meet the higher threshold applicable in their jurisdiction.

If you believe we have inadvertently collected information from a child under 18, please contact us at privacy@upskaill.ai.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:

Post the updated policy on our website with a new “Last Updated” date.

Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you may delete your account before the effective date.

15. Contact Us

For privacy-related inquiries or to exercise your rights:

Privacy Officer: privacy@upskaill.ai — subject: “Attention: Privacy Officer”
General Support: support@upskaill.ai
Website: www.upskaill.ai

French version: This Privacy Policy is available in French at upskaill.ai/fr/privacy.