Privacy Policy

This Privacy Policy ("Policy") governs the collection, processing, storage, disclosure, and protection of personal information by Skillnyx Private Limited ("Company", "we", "us", or "our"), a company incorporated under the Companies Act, 2013, with respect to SkillNyx Pulse, accessible at https://pulse.skillnyx.com ("Platform").

By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree, you must immediately discontinue use of the Platform.

This Policy is published in compliance with: • The Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"); • The Digital Personal Data Protection Act, 2023 ("DPDPA"), to the extent applicable; • Applicable provisions of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), for users in the European Economic Area.

The data controller responsible for your personal data is:

Skillnyx Private Limited Email: editorial@skillnyx.com Website: https://pulse.skillnyx.com

For all data protection enquiries, including requests to exercise your rights, please contact us at the email address above.

We collect the following categories of information:

3.1 Information You Provide Directly • Contact information (name, email address) when you subscribe to our newsletter or contact us; • Communications you send us via email or contact forms; • Feedback, editorial suggestions, or correspondence.

3.2 Automatically Collected Information • Log data: IP address, browser type and version, operating system, referring URLs, pages visited, time spent on pages, and access timestamps; • Device information: device type, screen resolution, and unique device identifiers; • Cookie data and similar tracking technologies (see Section 7).

3.3 Third-Party Sources • Aggregated analytics data from service providers such as Google Analytics; • Advertising data from Google AdSense and other advertising partners.

We do not knowingly collect sensitive personal data or information ("SPDI") as defined under the SPDI Rules unless strictly necessary and with your explicit consent.

We process your personal data on the following legal bases:

• Legitimate Interests: To operate, maintain, and improve the Platform; to detect and prevent fraud, abuse, or security incidents; to conduct analytics and understand how the Platform is used. • Consent: Where you have provided explicit consent (e.g., newsletter subscriptions, cookie preferences). • Legal Obligation: Where processing is necessary to comply with applicable law, court order, or regulatory direction. • Contract Performance: Where processing is necessary to fulfil a service or transaction you have requested.

You may withdraw consent at any time where consent is the basis for processing, without affecting the lawfulness of processing carried out prior to withdrawal.

We use the information collected for the following purposes:

• Operating, delivering, and improving the Platform and its editorial content; • Sending newsletters and editorial updates (only with your consent); • Personalising content recommendations based on reading behaviour; • Displaying interest-based advertising through Google AdSense and other ad networks; • Detecting, investigating, and preventing security incidents, fraud, or violations of our Terms of Use; • Complying with applicable legal obligations and responding to lawful requests from authorities; • Measuring and analysing Platform performance and audience engagement; • Communicating with you in response to enquiries.

We will not use your personal data for purposes materially different from those described above without providing you prior notice and, where required, obtaining your consent.

We do not sell, rent, or trade your personal data. We may disclose information to:

6.1 Service Providers and Processors Trusted third-party vendors engaged to provide services on our behalf, including: • Cloud infrastructure and hosting providers (e.g., Amazon Web Services); • Analytics providers (e.g., Google Analytics); • Email delivery services; • Advertising networks (e.g., Google AdSense).

All service providers are contractually required to process personal data only on our documented instructions, maintain appropriate security measures, and not use the data for their own purposes.

6.2 Advertising Partners The Platform uses Google AdSense to display advertisements. Google and its partners may use cookies and device identifiers to show personalised ads based on your visits to this and other websites. You can opt out of personalised advertising by visiting https://www.google.com/settings/ads or https://www.aboutads.info/choices.

6.3 Legal and Regulatory Disclosure We may disclose information where required by applicable law, court order, governmental directive, or in connection with any legal proceeding, investigation, or regulatory enquiry. We will endeavour to notify you of such disclosure where legally permissible.

6.4 Business Transfers In the event of a merger, acquisition, restructuring, sale of assets, or insolvency proceedings, personal data may be transferred to the relevant successor entity, subject to equivalent data protection obligations.

6.5 Protection of Rights We may disclose information where necessary to protect the rights, property, safety, or security of Skillnyx Private Limited, its personnel, users, or the public.

7.1 What Are Cookies Cookies are small text files placed on your device by a website to remember your preferences and facilitate functionality. We also use web beacons, pixels, and similar technologies.

7.2 Types of Cookies We Use • Strictly Necessary Cookies: Required for the Platform to function. Cannot be disabled. • Performance & Analytics Cookies: Help us understand how visitors interact with the Platform (e.g., Google Analytics). These cookies collect anonymised aggregate data. • Advertising Cookies: Used by Google AdSense and advertising partners to serve relevant advertisements, measure ad performance, and limit ad frequency. • Functionality Cookies: Remember your preferences (e.g., region selection, theme).

7.3 Third-Party Cookies Google AdSense and other advertising partners set their own cookies on your device. Skillnyx Private Limited does not control these cookies. Please refer to the respective third-party privacy policies for details.

7.4 Managing Cookies You may control cookie preferences through your browser settings. Disabling cookies may affect the functionality of the Platform. To opt out of interest-based advertising by Google, visit https://adssettings.google.com.

We retain personal data for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by law.

• Newsletter subscriber data: Retained until you unsubscribe or withdraw consent. • Server log data: Retained for up to 90 days for security and diagnostic purposes. • Analytics data: Retained in anonymised or aggregated form for up to 26 months. • Correspondence and enquiry records: Retained for up to 3 years from the date of last contact.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised.

Skillnyx Private Limited implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols; • Access controls and role-based permissions for internal systems; • Regular security assessments and vulnerability management; • Incident response procedures.

Notwithstanding the above, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security and disclaim liability for breaches resulting from circumstances beyond our reasonable control. You are responsible for maintaining the confidentiality of any account credentials.

In the event of a personal data breach that is likely to result in a high risk to your rights, we will notify you and the relevant supervisory authority as required by applicable law.

Your information may be transferred to, stored, and processed in countries other than India, including countries where our service providers operate (e.g., the United States). Such transfers will be carried out in accordance with applicable data protection law, including by relying on standard contractual clauses or equivalent safeguards where required.

By using the Platform, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection standards.

Depending on your jurisdiction and applicable law, you may have the following rights regarding your personal data:

• Right of Access: To request a copy of the personal data we hold about you. • Right to Rectification: To request correction of inaccurate or incomplete data. • Right to Erasure: To request deletion of your personal data, subject to our legal retention obligations. • Right to Restriction: To request that we restrict the processing of your data in certain circumstances. • Right to Data Portability: To receive your personal data in a structured, commonly used, machine-readable format. • Right to Object: To object to processing based on legitimate interests or for direct marketing purposes. • Right to Withdraw Consent: To withdraw consent at any time where processing is based on consent.

To exercise any of the above rights, please contact us at editorial@skillnyx.com. We will respond within 30 days. We may require verification of your identity before processing your request.

We will not discriminate against you for exercising your privacy rights.

The Platform is not directed at children under the age of 18 years. We do not knowingly collect personal data from children. If you believe that a child under 18 has provided us with personal data without appropriate consent, please contact us at editorial@skillnyx.com and we will take prompt steps to delete such data.

The Platform may contain links to third-party websites, applications, or services. This Policy does not apply to such third-party properties. We are not responsible for the privacy practices of third parties and encourage you to review their privacy policies before providing any personal information.

We reserve the right to amend this Policy at any time. Material changes will be communicated by updating the effective date at the top of this Policy and, where appropriate, by notifying you via email or a prominent notice on the Platform. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

This Policy is governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts of India.

For any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact:

Data Protection Contact Skillnyx Private Limited Email: editorial@skillnyx.com Website: https://pulse.skillnyx.com/contact

We aim to acknowledge all privacy-related enquiries within 5 business days and resolve them within 30 days.