Privacy Policy

Privacy Policy

Your privacy is important to us. This Privacy Policy explains how UpSkill Global Education Technologies Inc., a corporation incorporated under the laws of the Province of Ontario, Canada (Ontario Corporation Number 1001630517) (“UpSkill Global,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal data through the website www.upskillglobaledutech.ca and all related services, portals, and applications (the “Platform”), which is owned and operated exclusively by UpSkill Global.

UpSkill Global's courses and certification programmes are currently made available to learners in India through UpSkill Education Technologies Private Limited, an independently owned and operated Indian company that has entered into a written memorandum of understanding with UpSkill Global to act as an Independent Commercial Distribution Partner for the territory of India. As of the Effective Date of this Privacy Policy, UpSkill Global does not maintain any office, employees, agents, or other fixed place of business in India, does not negotiate or habitually conclude contracts with learners in India, and does not exercise control over the day-to-day business operations of its Independent Commercial Distribution Partner in India.

This Privacy Policy should be read together with our Website Terms of Use, which incorporates this Policy by reference. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Platform. This Privacy Policy applies to all Users worldwide, regardless of the country from which the Platform is accessed, and takes into account our obligations under the law of Canada, India, and other jurisdictions in which we operate.

1. Definitions and Interpretation

• “UpSkill Global,” “we,” “us,” and “our” refer solely to UpSkill Global Education Technologies Inc., the Canadian corporation described above. These terms do not include any Independent Commercial Distribution Partner, Institutional Partner, or other independent third party.
• “Personal Data” or “Personal Information” means any information relating to an identified or identifiable individual, including information that can be used, directly or indirectly, to identify a specific person.
• “Independent Commercial Distribution Partner” means an independently owned and operated company that has entered into a written memorandum of understanding or partnership agreement with UpSkill Global to market, enrol students in, and collect payment for UpSkill Global's courses and certification programmes within a specific country or region, including UpSkill Education Technologies Private Limited, a company incorporated under the laws of India and registered under the particulars set out in Section 10 below, which is an Independent Commercial Distribution Partner for the territory of India. An Independent Commercial Distribution Partner is an independent contracting party, conducts its own business at its own risk and for its own account, and is not, and shall not be represented or construed as, an agent, employee, subsidiary, branch office, franchise, representative office, fiduciary, permanent establishment, joint venture, or legal representative of UpSkill Global. Nothing in this Privacy Policy, any MOU, or any commercial arrangement shall be interpreted as creating such a relationship
• “Institutional Partner” or “Authorised Training Center” means any college, university, school, or training academy that has entered into a written partnership agreement with UpSkill Global or its Independent Commercial Distribution Partner in the relevant territory.
• “Cookie” means a small text file placed on your computer or device by the Platform when you visit certain parts of it or use certain features
• “You,” “your,” or “User” means any individual whose Personal Data we collect, including students, prospective students, Institutional Partner representatives, and general visitors to the Platform.

2. What Does This Policy Cover?

2.1 This Privacy Policy explains how we collect, hold, use, and disclose your Personal Data, and explains your rights in relation to it.

2.2 The Platform may contain links to third-party websites, including payment processors and social media platforms. We have no control over how your data is collected, stored, or used by such third-party websites, and we encourage you to review their privacy policies before providing them with any data.

3. What Is Personal Data?

3.1 Personal Data is, in simple terms, any information about you that enables you to be identified, whether directly or indirectly. This includes obvious information such as your name and contact details, and less obvious information such as identification numbers, device identifiers, and online identifiers.

3.2 The categories of Personal Data that we collect are set out in Section 5 below.

4. Your Rights

4.1 Depending on the law applicable to you, you may have some or all of the following rights in relation to your Personal Data, which we will work to uphold to the extent required:

• the right to be informed about our collection and use of your Personal Data.
• the right to access a copy of the Personal Data we hold about you.
• the right to have inaccurate or incomplete Personal Data corrected.
• the right to request deletion of your Personal Data, subject to our legitimate need to retain certain records.
• the right to object to, or request that we restrict, certain processing of your Personal Data.
• the right to withdraw consent at any time, where we rely on your consent as the basis for processing.
• the right to request a copy of your Personal Data in a commonly used, machine-readable format, where technically feasible and required by applicable law.
• the right to lodge a complaint with the applicable data protection authority in your jurisdiction.

4.2 We do not make decisions producing legal effects concerning you, or similarly significant effects, based solely on automated processing of your Personal Data, unless such automated decision-making is expressly disclosed to you at the point of collection.

4.3 To exercise any of these rights in relation to UpSkill Global's own processing of your Personal Data, please contact our Privacy Officer using the details in Section 16. We will respond to legitimate requests within a reasonable time and in any event within the timeframe required by applicable law.

4.4 Users in Canada may also contact the Office of the Privacy Commissioner of Canada if they are not satisfied with our response. Users in India whose Personal Data is processed directly by UpSkill Global may raise concerns with the Data Protection Board of India once constituted under the Digital Personal Data Protection Act, 2023; Users whose Personal Data is processed independently by our Independent Commercial Distribution Partner in India should first contact that partner's Grievance Officer as described in Section 10.4. We encourage you to contact the relevant Privacy or Grievance Officer directly first, so that there is an opportunity to resolve your concern.

4.5We may need to verify your identity before responding to a request, which may include asking you to confirm your name and the email address associated with your account.

5. What Data Do We Collect and How Do We Use It?

5.1 We collect the following categories of Personal Data, depending on how you interact with the Platform:

• Identity Data — your full name, and, where required for certificate issuance, information necessary to verify your identity.
• Contact Data — your email address, telephone number, and, where relevant to institutional enrolment, your postal address.
• Account Data — your username, password (stored in encrypted form), and account preferences.
• Enrolment and Academic Data — the courses you enrol in, your assessment results, pass/fail status, and Certificate details, including your unique Certificate identification number.
• Institutional Affiliation Data — where you are enrolled through an Institutional Partner, the name of that institution and any student identification number it has assigned you.
• Financial Data — payment method details processed on our behalf by our third-party payment processor(s) we do not directly store full payment card details.
• Technical Data — your IP address, browser type and version, device identifiers, operating system, and similar technical information collected automatically when you use the Platform.
• Usage Data — information about how you use the Platform, including pages visited, time spent, and course progress.
• Communications Data — the content of emails, support enquiries, and other correspondence between you and us.

5.2 We do not knowingly collect any special category or sensitive Personal Data (such as health information, religious beliefs, or biometric data) through the Platform, and we ask that you do not submit such information to us unless specifically required as part of an enrolment or identity verification process.

5.3 UpSkill Global does not currently process direct payments for enrolments in Canada or other territories outside India, as no payment gateway has yet been integrated for that purpose; this section will be updated to name the applicable payment processor once direct enrolment and payment functionality is implemented for those territories. Users enrolling through UpSkill Global's Independent Commercial Distribution Partner in India pay that partner directly, and payment is processed by the Independent Commercial Distribution Partner's own payment processor, Razorpay, under the partner's own arrangements; UpSkill Global does not process, receive, or store Indian-territory student payment data. We do not store your full payment card details on our own servers.

5.4 The table below summarises the main purposes for which we use your Personal Data, the categories of data involved, our lawful basis for processing under Canadian law, the corresponding ground under India's Digital Personal Data Protection Act, 2023 (which, unlike PIPEDA, does not recognise “legitimate interest” as a standalone lawful basis), and how long we generally retain it.

5.5 If you provide us with the Personal Data of any other person (for example, as an Institutional Partner submitting a batch of student enrolments), it is your responsibility to ensure you have the necessary authority and consent to do so, and you remain responsible for the accuracy of that data.

5.6 With your consent, or where otherwise permitted by law, we may use your contact details to send you information about new courses or updates to the Platform. You may opt out of marketing communications at any time using the unsubscribe link in our emails or by contacting us directly. Opting out of marketing communications does not affect our ability to send you important administrative or transactional messages relating to your account, courses, or Certificates.

5.7 You are responsible for ensuring that any Personal Data you submit through the Platform is accurate, current, and complete, and for promptly updating it if it changes.

6. How and Where Do We Store Your Data, and For How Long?

6.1 Personal Data collected through the Platform is currently hosted on servers provided by Hostinger, with primary servers located in India and backup data stored in Singapore. Where backup data is transferred to Singapore, this is subject to the cross-border transfer disclosures.

6.2 We retain different categories of Personal Data for different periods, depending on the purpose for which it was collected, our legal obligations (including India's DPDP Act, 2023, which requires erasure once a purpose is served unless retention is necessary for a specified legal ground), and our legitimate business interests. The table below sets out our proposed retention schedule.

Data Category	Proposed Retention Period
Student account and profile data	7 years from account closure or last activity
Certificate identification number, course, issuance date, and validity status (Verification record)	Permanently, for as long as the Certificate Verification system remains in operation, to preserve the integrity of issued Certificates
Certificate holder's name and other personal identifiers linked to a Certificate	7 years from issuance, after which such identifiers are minimised or pseudonymised on the public-facing record while the underlying Certificate ID and validity status remain independently verifiable.
Payment and financial transaction records	7 years, or as required by applicable Canadian and Indian tax and financial record-keeping law.
Support tickets and general correspondence	3 years from the date of last correspondence.
Marketing contact preferences	Until you unsubscribe, plus a reasonable period to record that preference.
Technical and security logs	2 years from the date of collection.

6.3 UpSkill Global and its Independent Commercial Distribution Partner in India operate as separate, independent businesses. Personal Data shared between UpSkill Global and its Independent Commercial Distribution Partner in India is limited to the minimum necessary for enrolment, certification, learning-platform (LMS) access, Certificate verification, and applicable regulatory compliance and no more. That sharing takes place under an arm's-length data sharing agreement, not an intercompany or group arrangement, and each party remains independently responsible for its own compliance with applicable law in its own territory. Where your Personal Data is otherwise transferred outside the country in which it was originally collected, we take reasonable steps to ensure it continues to be protected to a standard consistent with this Privacy Policy and applicable law.

6.4 To protect your Personal Data, we take measures including: restricting access to Personal Data to personnel and service providers with a legitimate need to know, who are subject to confidentiality obligations; maintaining technical and security logs to detect and investigate suspicious activity; using encryption and other technical safeguards for data in transit; and maintaining procedures for identifying and responding to any suspected data breach, including notification to affected Users and relevant authorities where required by law.

6.5 While we take reasonable steps to protect your Personal Data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, and any transmission of Personal Data to us is at your own risk.

7. Certificate Verification and Public Information

7.1 A core feature of the Platform is the independent, real-time verification of Certificates through our Certificate Verification system, accessible at www.upskillglobaledutech.ca/verify-certificate. This system allows any person, anywhere in the world, to confirm that a specific Certificate is genuine by entering the unique Certificate identification number or scanning the QR code printed on the Certificate.

7.2 When a Certificate is looked up through the Verification system, the following limited information is displayed publicly to the person performing the lookup: the certificate holder's name (subject to the minimisation approach described in Section 6.2), the course or programme completed, the issuing entity or Institutional Partner (where applicable), the date of issuance, and the validity status of the Certificate.

7.3 We do not display your contact details, payment information, assessment scores, or any other Personal Data beyond what is described in Section 7.2 through the public Verification system.

7.4 By enrolling in a course and accepting a Certificate upon successful completion, you acknowledge and consent to the information described in Section 7.2 being made available through the public Verification system, as this is a fundamental feature of the Certificate's value and credibility to employers and institutions.

7.5 If you have a specific concern about the public display of your Certificate information, please contact our Privacy Officer using the details in Section 16.

8. Do We Share Your Data?

8.1 We may share your Personal Data with the following categories of recipients:

• Our Independent Commercial Distribution Partner in India — UpSkill Education Technologies Private Limited, for the purpose of enrolling you in courses, processing payments, and delivering certification services within India, under an arm's-length written agreement. Our Independent Commercial Distribution Partner acts as an independent data controller/fiduciary for its own processing of your Personal Data within its territory and is solely responsible for its own compliance with applicable local law.
• Institutional Partners — where you are enrolled through a college, university, or academy, we share relevant enrolment and academic data with that institution for the purpose of managing your enrolment and supporting their own institutional record-keeping.
• Service Providers — including our payment processor(s), hosting provider, and any email or communications service providers we use to operate the Platform, each of whom is permitted to use your Personal Data only as necessary to provide services to us.
• Legal and Regulatory Authorities — where required to comply with a legal obligation, court order, or lawful request from a government or regulatory authority in Canada, India, or any other applicable jurisdiction, as further described in Section 8.5. and
• Successors in a Business Transfer — in the event of a merger, acquisition, corporate reorganisation, or sale of assets, your Personal Data may be transferred to the acquiring entity, subject to the same or materially similar privacy protections.

8.2 We do not sell your Personal Data to third parties, and we do not share your Personal Data with third parties for their own independent advertising or marketing purposes.

8.3 Our current service providers include: Hostinger (website hosting and DNS management, with backup storage in Singapore); Razorpay (payment processing for India-territory transactions, via our Independent Commercial Distribution Partner); and our website development and technical maintenance provider, who maintains administrative access to our servers and backups under a written maintenance and security agreement. We do not currently use a dedicated third-party email/SMTP service or any analytics tool; if either is introduced in future, this Policy will be updated accordingly.

8.4 Where any of your Personal Data is shared with a third party as described above, we take reasonable steps to ensure it is handled safely, securely, and in accordance with your rights and our obligations under applicable law.

8.5 Legal and Regulatory Disclosure We may disclose your Personal Data where we believe in good faith that disclosure is required or permitted by law, including in response to a valid court order, subpoena, government investigation, or lawful request from police, tax, or other regulatory authorities in Canada, India, or any other applicable jurisdiction, or where necessary to detect, prevent, or investigate fraud or other illegal activity affecting the Platform, its Users, or Institutional Partners.

9. International Users and Cross-Border Data Transfers

9.1 UpSkill Global is headquartered in Ontario, Canada. UpSkill Global's programmes are made available in India and other countries through Independent Commercial Distribution Partners and Institutional Partners, each of which is a separate legal entity operating its own business and responsible for its own compliance with applicable local law. Accordingly, your Personal Data may be collected, stored, and processed in Canada, India, or other countries in which we or our service providers operate.

9.2 Where we process the Personal Data of individuals in Canada, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

9.3 Where UpSkill Global processes the Personal Data of individuals in India directly (for example, through the Platform), we comply with the Digital Personal Data Protection Act, 2023, and other applicable Indian data protection law. Where our Independent Commercial Distribution Partner in India processes such data as an independent business, it does so under its own separate privacy notice as described in Section 10.

9.4 Where you provide explicit, informed consent through the Platform for example, by way of a dedicated consent action at account creation, rather than by general use of the Platform alone you consent to the cross-border transfer, storage, and processing of your Personal Data as described in this Section, which will in all cases be subject to appropriate contractual and technical safeguards and to any restrictions on transfer to specific countries that the Central Government of India may notify from time to time under the Digital Personal Data Protection Act, 2023.

9.5 Our lawful bases for processing your Personal Data, to the extent applicable law requires us to identify them, are: performance of our contract with you; compliance with our legal obligations; our legitimate interests, including securing the Platform and preventing fraud (for Canadian and other non-Indian Users); and, for Indian Users, your consent or the applicable ground under Section 7 of the Digital Personal Data Protection Act, 2023, as set out in Section 5.4.

9.6 By submitting Personal Data through the Platform, you acknowledge that privacy and data protection laws in Canada may differ from those of your own country or jurisdiction, and that your Personal Data will, in each case, be subject to the laws of the country in which it is actually collected, stored, or processed.

10. Our Independent Commercial Distribution Partner in India

10.1 UpSkill Global's courses and certification programmes are currently made available in India through UpSkill Education Technologies Private Limited (“our Indian Partner”), an independently owned and operated company incorporated under the laws of India, under a written memorandum of understanding with UpSkill Global. Our Indian Partner is an Independent Commercial Distribution Partner for the territory of India and is not an agent, employee, subsidiary, branch office, representative office, franchise, or joint venture of UpSkill Global. Consistent with Section 11, and as of the Effective Date of this Privacy Policy, UpSkill Global does not maintain any office, employees, or other fixed place of business in India, does not own or lease premises or maintain inventory in India, and does not negotiate or habitually conclude contracts with learners in India.

10.2 Our Indian Partner's registration details are set out below, provided for transparency only. Our Indian Partner is solely responsible for the accuracy of this information and for its own regulatory filings and compliance in India:

Legal Name	UpSkill Education Technologies Private Limited
Corporate Identity Number (CIN)	U85306MH2026PTC473241
Date of Incorporation	9 July 2026
Registered under	The Companies Act, 2013 — Ministry of Corporate Affairs, Central Registration Centre
Registered Office	Plot 55, S. No. 263, Sector 8, RSC-14, Malwani, Kharodi, Malad West, Mumbai – 400095, Maharashtra, India
Relationship to UpSkill Global	Independent Commercial Distribution Partner for the territory of India under a written memorandum of understanding, not an agent, subsidiary, branch, or legal representative of UpSkill Global.

10.3 Where you enrol in a course or certification programme through our Indian Partner, or otherwise interact with our Indian Partner in connection with UpSkill Global's programmes in India, our Indian Partner processes your Personal Data as an independent Data Fiduciary under the Digital Personal Data Protection Act, 2023, and other applicable Indian law, under its own separate privacy notice and on its own responsibility. This Privacy Policy governs only the collection and use of Personal Data by UpSkill Global directly through the Platform; it does not extend to, and UpSkill Global is not responsible for, our Indian Partner's independent processing of Personal Data within India.

10.4 For any query, request, or grievance relating to our Indian Partner's handling of your Personal Data in connection with your enrolment in India, please contact our Indian Partner's Grievance Officer at grievanceindia@upskillglobaledutech.ca, or write to the registered office address set out in Section 10.2. UpSkill Global's Privacy Officer (Section 16) can also help direct your enquiry appropriately.

10.5 UpSkill Global and our Indian Partner may share limited enrolment, academic, certification, and payment-related data with one another under an arm's-length data sharing agreement, strictly for the purposes of enrolling you, delivering the programme, and issuing and verifying your Certificate, as further described in Section 8.

10.6 Our Indian Partner contracts with the learner in its own name for payment collection and local commercial services. Where you enrol and pay through our Indian Partner, UpSkill Global is not a party to, and assumes no responsibility or liability in connection with, that payment transaction. Refund requests relating to an enrolment made through our Indian Partner are handled exclusively by our Indian Partner in accordance with its own contractual terms and applicable law. Refund requests relating to an enrolment made directly with UpSkill Global outside India are handled by UpSkill Global.

10.7 Any complaint, claim, or dispute arising solely from services provided by our Indian Partner including course delivery, local customer support, payment, or refunds should, in the first instance, be directed to our Indian Partner, using the contact details in Section 10.4. This does not affect any statutory right you may have to raise the matter with a regulator or court of competent jurisdiction.

11. Independent Corporate Relationship; No Liability for Partner Conduct

11.1 UpSkill Global Education Technologies Inc. is an independent Canadian corporation. Any company authorised to market, distribute, enrol students, provide local support, or collect payments within another jurisdiction including our Indian Partner operates as an independent commercial entity under separate ownership, management, governance, and regulatory responsibility. Nothing contained in this Privacy Policy, any MOU, website content, or commercial arrangement shall be construed as creating a subsidiary, branch office, agency, franchise, partnership, employment relationship, representative office, fiduciary relationship, joint venture, or permanent establishment of UpSkill Global in that jurisdiction. Each entity remains solely responsible for its own legal, tax, employment, regulatory, and operational obligations.

11.2 Each Independent Commercial Distribution Partner and Institutional Partner is solely responsible for its own compliance with consumer protection, taxation, employment, labour, licensing, advertising, and other applicable regulatory requirements in its own jurisdiction.

11.3 UpSkill Global shall not be responsible or liable for any act, omission, negligence, misrepresentation, breach of applicable law, or contractual default committed by any Independent Commercial Distribution Partner or Institutional Partner, including our Indian Partner.

11.4 As of the Effective Date of this Privacy Policy, UpSkill Global does not negotiate or habitually conclude contracts with learners in India, does not maintain inventory in India, does not own or lease premises in India, does not employ personnel in India, does not maintain any dependent agent in India authorised to habitually conclude contracts on its behalf, and does not otherwise conduct business in India through a fixed place of business. This Section reflects UpSkill Global's operating structure as at the date stated above and will be updated if that structure changes.

11.5 Personnel, contractors, and employees engaged by an Independent Commercial Distribution Partner or Institutional Partner are employees or contractors solely of that partner and are not, for any purpose, employees, contractors, or personnel of UpSkill Global.

11.6 For the purposes of applicable data protection law: UpSkill Global acts as an independent data controller in respect of Personal Data it processes directly through the Platform; our Indian Partner acts as an independent Data Fiduciary, under the Digital Personal Data Protection Act, 2023, in respect of Personal Data it processes in its own right. Each party independently determines the purposes and means of processing the Personal Data under its own control. Neither party acts as a data processor for the other, except to the extent expressly agreed in a written data processing agreement between them.

12. Our Use of Cookies

12.1 The Platform uses Cookies and similar technologies to operate correctly, remember your login session, and understand how the Platform is used.

12.2 Strictly necessary Cookies, such as those used to maintain your login session, are essential to the functioning of the Platform and are not subject to consent, although you may still block them through your browser settings at the risk of the Platform not functioning correctly.

12.3 We do not currently use any third-party analytics tool, such as Google Analytics, to understand how visitors use the Platform. If we introduce such a tool in future, it may place additional Cookies to collect anonymised or pseudonymised usage statistics, and this Policy will be updated accordingly before that tool is activated.

12.4 Where non-essential Cookies (such as analytics or performance Cookies) are used, we will provide a consent mechanism allowing you to accept or decline such Cookies before they are set, in accordance with applicable law.

12.5 You can control or delete Cookies through your browser settings. Please consult the help section of your browser (e.g., Google Chrome, Mozilla Firefox, Microsoft Edge, or Apple Safari) for instructions on how to manage Cookie preferences.

13. Children's Privacy

13.1 The Platform is intended for use by individuals who are at least 18 years of age, or who are using the Platform under the supervision and with the consent of a parent or legal guardian, consistent with Section 2 of our Website Terms of Use.

13.2 Where a User enrols through an Institutional Partner or our Independent Commercial Distribution Partner and is known to be under the age of 18, we require, under our written agreements with such partners, that they certify that verifiable parental or guardian consent has been obtained in compliance with applicable law prior to enrolment, and we reserve the right to audit compliance with this requirement (see also Section 11.2). We process such a minor's Personal Data solely for the purposes of course delivery, assessment, and Certificate issuance.

13.3 We do not knowingly collect Personal Data directly from children outside the context of a supervised institutional enrolment as described above. If we become aware that we have collected Personal Data from a child in a manner inconsistent with this Section, we will take reasonable steps to delete that data, save where its retention is necessary to preserve the integrity of an already-issued Certificate.

14. Governing Law and Disputes

14.1 Except where mandatory law requires otherwise including mandatory provisions of the Digital Personal Data Protection Act, 2023, applicable to Indian data principals, or of PIPEDA and applicable provincial privacy legislation this Privacy Policy, and any dispute concerning UpSkill Global's processing of your Personal Data directly through the Platform, shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to conflict-of-laws principles.

14.2 This Section governs disputes relating to this Privacy Policy only. Disputes relating to your contract of service with UpSkill Global, or with an Independent Commercial Distribution Partner or Institutional Partner, are governed by the applicable Terms of Use or partner agreement, as relevant, and are not affected by this Section.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes in our practices or applicable law. This Policy will also apply to any future website, mobile application, or other product or service we make available under the UpSkill Global name, unless accompanied by its own separate privacy notice. Any changes will be posted on the Platform with an updated “Last Updated” date. Your continued use of the Platform following any such change constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically.

16. Contact Us

16.1 If you have any questions, concerns, or requests relating to this Privacy Policy or UpSkill Global's own handling of your Personal Data, please contact our Privacy Officer at:

Privacy Officer
186 Jarvis Street, Toronto, Ontario, M5B 2B7, Canada
Email: privacy@upskillglobaledutech.ca

16.2 For matters relating specifically to our Indian Partner's handling of your Personal Data in connection with enrolment in India, please contact our Indian Partner's Grievance Officer as described in Section 10.4.

16.3 Our Privacy Officer is responsible for overseeing UpSkill Global's compliance with this Privacy Policy and applicable data protection law, and for responding to requests relating to your privacy rights, access, correction, or complaints regarding UpSkill Global's own processing. If you are not satisfied with our response, you have the right to escalate your concern to the applicable regulatory authority described in Section 4.4.