Last updated: March 15, 2024

SkillExus™ ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, process, and safeguard your information when you use our AI gaming coach and analytics platform.

Important: This policy complies with the European General Data Protection Regulation (GDPR) and Belgian data protection laws. As a Brussels-based company, we adhere to the highest European standards for data privacy and security.

1. Information We Collect

1.1 Gaming Performance Data

  • Real-time gameplay actions and decisions
  • Performance metrics and statistics
  • Game session duration and frequency
  • In-game achievements and progress
  • Hardware performance data (FPS, latency, system specifications)

1.2 Personal Information

  • Account registration details (username, email address)
  • Subscription and billing information
  • Communication preferences
  • Support ticket information and correspondence

1.3 Technical Information

  • Device information and operating system details
  • IP address and general location data
  • Browser type and version
  • Usage patterns and feature interactions

2. How We Use Your Information

2.1 Service Provision

  • Deliver real-time AI coaching and performance analytics
  • Generate personalized improvement recommendations
  • Create performance heatmaps and progress tracking
  • Provide access to our drill marketplace

2.2 Service Improvement

  • Enhance our AI algorithms and coaching accuracy
  • Develop new features and improve existing ones
  • Conduct research and analytics to optimize platform performance
  • Ensure platform security and prevent fraud

2.3 Communication

  • Send service-related notifications and updates
  • Provide customer support and respond to inquiries
  • Share important policy changes or security alerts

3. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

  • Contract Performance: Processing necessary to provide our gaming analytics services
  • Legitimate Interest: Improving our services and ensuring platform security
  • Consent: Marketing communications and optional data processing (where applicable)
  • Legal Obligation: Compliance with applicable laws and regulations

4. Data Sharing and Disclosure

We do not sell your personal information. We may share your data only in the following circumstances:

4.1 Service Providers

  • Cloud hosting and data storage providers (EU-based)
  • Payment processing services
  • Customer support platforms
  • Analytics and performance monitoring tools

4.2 Legal Requirements

  • Compliance with court orders or legal processes
  • Protection of our rights and property
  • Prevention of fraud or security threats
  • Compliance with applicable laws and regulations

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transaction, subject to the same privacy protections.

5. Data Security

We implement comprehensive security measures to protect your information:

  • End-to-end encryption for data transmission
  • Secure data storage with regular backups
  • Access controls and authentication systems
  • Regular security audits and vulnerability assessments
  • Employee training on data protection best practices
  • Incident response procedures for potential breaches

6. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

Right of Access

Request a copy of the personal data we hold about you

Right to Rectification

Correct inaccurate or incomplete personal data

Right to Erasure

Request deletion of your personal data under certain circumstances

Right to Restrict Processing

Limit how we process your personal data

Right to Data Portability

Receive your data in a structured, machine-readable format

Right to Object

Object to processing based on legitimate interests

To exercise any of these rights, please contact us using the information provided below.

7. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

  • Account Data: Retained while your account is active and for 2 years after account closure
  • Gaming Performance Data: Retained for the duration of your subscription plus 1 year for service improvement
  • Billing Information: Retained for 7 years as required by Belgian accounting laws
  • Support Communications: Retained for 3 years for quality assurance purposes

8. International Data Transfers

Your data is primarily processed within the European Union. If we need to transfer data outside the EU, we ensure adequate protection through:

  • European Commission adequacy decisions
  • Standard Contractual Clauses (SCCs)
  • Binding Corporate Rules
  • Other appropriate safeguards as required by GDPR

9. Automated Decision Making and Profiling

Our AI coaching system uses automated processing to provide personalized recommendations. This includes:

  • Performance analysis and skill assessment
  • Personalized coaching recommendations
  • Adaptive drill suggestions based on gameplay patterns
  • Progress tracking and improvement predictions

You have the right to request human intervention in these automated decisions and to challenge the results.

10. Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information.

For users between 16 and 18 years of age, parental or guardian consent may be required in accordance with local laws.

11. Third-Party Services and Integrations

Our platform may integrate with third-party gaming services and platforms. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before using their services.

11.1 Gaming Platform Integration

  • Steam, Epic Games Store, and other game launchers
  • Game-specific APIs for performance data collection
  • Hardware monitoring software integration

Contact Our Data Protection Officer

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Email: privacy@skillexus.be

Phone: +32 482 73 95 06

Address: SkillExus™ Data Protection Officer
Rue de Montigny 132
6000 Charleroi, Belgium

Supervisory Authority: You have the right to lodge a complaint with the Belgian Data Protection Authority (APD/GBA) if you believe we have not handled your personal data in accordance with applicable law.

12. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by:

  • Posting the updated policy on our website
  • Sending email notifications to registered users
  • Displaying prominent notices within our platform

Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy.