PRIVACY POLICY

1. INTRODUCTION

SkillSpot is a family of software products operated by Mir Image Creations, LLC (“Mir Image Creations,” “SkillSpot,” “we,” “our,” or “us”).

This Privacy Policy explains how we collect, use, disclose, safeguard, and retain information when you access or use SkillSpot-branded mobile applications, web applications, and related services (collectively, the “Services”).

By using the Services, you acknowledge that you have read and understood this Privacy Policy.

For purposes of applicable data protection laws, Mir Image Creations, LLC is the data controller unless otherwise stated.

2. SCOPE OF THIS POLICY

This Privacy Policy applies to:

• All SkillSpot-branded applications and services currently offered
• Any future SkillSpot-branded products offered from time to time

This Policy does not apply to third-party websites, platforms, or services that are governed by their own privacy policies.

3. PRIVACY PRINCIPLES

We operate SkillSpot according to the following principles:

• Data minimization – we collect only what is reasonably necessary
• Purpose limitation – data is used only for defined, legitimate purposes
• User control – you control submissions, permissions, and deletions
• Security by design – safeguards are built into systems and workflows
• Transparency – practices are described clearly and truthfully

We do not knowingly collect sensitive personal information unless you voluntarily provide it.

4. INFORMATION WE COLLECT

4.1 Information You Provide Directly

You may provide information when you create an account, configure your profile, or use the Services, including:

• Account and Authentication Information: Information necessary to create and secure your account.
• Profile Information: Self-reported data such as skill level, preferences, time availability, physical limitations, accessibility preferences, and similar information.
• Practice, Activity, and Planning Data: Logs, notes, selections, feedback, and other information you submit while using the Services.

4.2 Camera, Video, and Image-Based Inputs

Certain optional features allow you to use your device camera only when you choose to do so, such as:

• recording motion or activity for analysis;
• capturing images (for example, scorecards or reference material).

Important clarifications:

• Raw video or image files are processed transiently to extract structured, non-visual analytical data (such as motion landmarks or text data).
• Mir Image Creations does not store or retain raw camera media on its servers.
• Only derived, non-image data may be retained to support functionality you request.

You control camera permissions through your device settings and may revoke access at any time.

4.3 Automatically Collected Information

When you use the Services, we may automatically collect limited technical information, including:

• Usage Analytics – anonymized or aggregated interaction data (e.g., feature usage, session patterns).
• Device and Technical Information – device type, operating system version, application version, and diagnostic or crash data.

This information is used to operate, secure, and improve the Services.

4.4 Location Information

Location information is collected only if you grant permission. Where location is optional, manual entry alternatives are provided.

5. HOW WE USE INFORMATION

We use information collected through the Services to:

• operate and provide requested features;
• generate personalized insights and planning recommendations;
• respect self-reported physical limitations and accessibility preferences;
• provide contextual information (such as weather, when enabled);
• support optional pre-activity or in-activity planning features;
• monitor reliability, security, and performance;
• improve and evolve the Services;
• send notifications or reminders where you opt in.

We do not use your information to make legal, medical, financial, or similarly significant decisions about you.

6. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING

The Services may use artificial intelligence or machine-learning systems to generate recommendations, insights, or structured outputs.

• AI outputs are informational and educational only.
• Outputs may be inaccurate, incomplete, or unsuitable for some users.
• You remain responsible for how you interpret and apply any output.

SkillSpot does not use facial recognition, identity verification, or biometric identification technologies.

7. LEGAL BASES FOR PROCESSING (WHERE APPLICABLE)

Where required by law (including GDPR and UK GDPR), we process personal information under one or more of the following bases:

• performance of a contract;
• your consent;
• legitimate interests (such as security, improvement, and fraud prevention);
• compliance with legal obligations.

8. DATA SHARING AND DISCLOSURE

8.1 No Sale of Personal Data

We do not sell personal information.

8.2 Service Providers

We may share information with trusted third-party service providers who process data on our behalf to support infrastructure, analytics, AI processing, or security. These providers are contractually required to protect information and use it only as instructed.

Service providers may change over time as the Services evolve.

8.3 Legal, Safety, and Business Transfers

We may disclose information where required to:

• comply with law or legal process;
• protect rights, safety, or property;
• complete a merger, acquisition, or asset transfer (subject to safeguards).

9. INTERNATIONAL DATA TRANSFERS

The Services are operated from the United States, and information may be processed in the United States or other jurisdictions. By using the Services, you acknowledge that your information may be transferred internationally, subject to appropriate legal safeguards.

10. YOUR RIGHTS AND CHOICES

Depending on your location, you may have the right to:

• access and receive a copy of your information;
• correct inaccurate information;
• request deletion of your account and personal data;
• withdraw consent where processing is based on consent;
• object to or restrict certain processing.

We respond to verified requests within 30 days, unless a shorter period is required by law.

11. DATA SECURITY

We use reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, loss, misuse, or alteration.

No system is completely secure, and we cannot guarantee absolute security.

Incident Response

If a data security incident occurs, we will notify affected users and authorities as required by applicable law.

12. DATA RETENTION

• Personal information is retained while your account remains active.
• When you delete your account, personal data is deleted or anonymized in accordance with applicable law.
• Aggregated or de-identified analytics data may be retained for up to two (2) years.

13. CHILDREN’S PRIVACY

The Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13 without parental consent. If we become aware that such information has been collected, we will take appropriate steps to delete it.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Material changes will be communicated through the Services or by other appropriate means. Continued use of the Services after an update constitutes acceptance of the revised Policy.

15. CONTACT INFORMATION

If you have questions, requests, or concerns regarding this Privacy Policy or our data practices, contact us at:

• Email: privacy@skillspotapp.com
• Website: skillspotapp.com