Privacy Policy

1. Preamble and Legal Framework

This Privacy Policy is intended to inform the Users and Buyers of the SkillED Platform of how their personal data are collected, processed, retained and protected, in accordance with Law No. 18-07 of 10 June 2018 on the protection of individuals with regard to the processing of personal data (Official Journal No. 34), as well as its implementing texts.

Legal note: Law No. 25-11 of 24 July 2025 amended and supplemented Law 18-07. It is recommended to have this Policy validated by a lawyer in light of the most recent implementing texts before publication.

SkillED acts as the data controller within the meaning of Law 18-07 for all data collected via the Application, the Site and the associated Services, including in the context of Starter Kit Orders and workshop registrations.

2. Identity and Contact Details of the Data Controller

The data controller is: [Company name of SkillED], [legal form], RC No. [RC], NIF [number], NIS [number], whose registered office is located at [full address], represented by [Sara Nasri, CEO]. Data protection contact: contact@skilled-dz.com.

3. Personal Data Collected

SkillED collects the following categories of data:

• Identification data of the User/Buyer: first name, last name, date of birth, profile photo (optional);
• Contact data: email address, phone number, delivery address;
• Connection and usage data: identifiers, educational progress history, scores, levels, badges, IP address, device type;
• Order data: purchase history of Starter Kits and boxes, workshop registrations, amounts (excluding sensitive banking data, processed exclusively by the approved payment provider and not stored by SkillED);
• Data relating to the parent/legal guardian, in the context of the consent required for minor Users and the Orders placed on their behalf;
• Data from cookies and trackers (see Section 12).

SkillED does not, in principle, collect any "sensitive" data within the meaning of Law 18-07 (ethnic origin, political opinions, religious beliefs, health data, biometric data, sex life). Any processing of this nature would be subject to prior authorization from the ANPDP and to separate explicit consent.

4. Purposes of the Processing

• The creation, management and securing of the User Account;
• The provision and personalization of the educational Services (progress, Points, recommendations);
• The processing and delivery of Starter Kit Orders and workshop registrations;
• The management of online payments, via approved providers;
• Communication with the User/Buyer (Order confirmation, customer support, notifications);
• The improvement of the Platform and statistical analysis of usage, where possible in aggregated and anonymized form;
• Compliance with the legal and regulatory obligations applicable to SkillED in Algeria (accounting, tax, consumer);
• Commercial prospecting, only subject to the prior and free consent of the User/Buyer (or of their legal representative if they are a minor).

5. Legal Basis and Lawfulness of the Processing

Each processing implemented by SkillED is based on one of the following grounds: the consent of the data subject (or of their legal representative for minors), the performance of an Order or of the requested Services, compliance with a legal obligation, or the legitimate interest of SkillED, while respecting the fundamental rights and freedoms of the User.

6. Recipients of the Data

• Authorized SkillED internal teams (education, support, operations, logistics), within the limits of their duties;
• Technical providers hosting the Application, the Site and the databases;
• Approved online payment providers (processing of Orders);
• Delivery providers, for the sole data necessary for the shipment of Starter Kits (name, address, phone);
• Messaging and notification providers (email, SMS, push notifications);
• Institutional or academic partners, only in anonymized or aggregated form unless otherwise expressly agreed;
• Administrative or judicial authorities, upon legal requisition.

SkillED undertakes never to sell Users' personal data to third parties for commercial purposes.

7. Transfer of Data Outside Algerian Territory

In the event that all or part of the data is hosted or processed by a provider located outside Algerian territory, SkillED undertakes to use only providers offering protection guarantees equivalent to those of Law 18-07 and, where the law so requires, to request prior authorization from the ANPDP.

8. Retention Periods

• Account data: for the duration of active use, and up to [12] months after deletion of the Account or last activity;
• Order and billing data: in accordance with the legal accounting and tax retention periods in Algeria;
• Connection data (logs): a maximum of [12] months for security purposes;
• Commercial prospecting data: until withdrawal of consent.

9. Data Security

• Encryption of sensitive data and communications (HTTPS/SSL protocol);
• Management of authorizations and accesses according to the need-to-know principle;
• Regular and secure backups;
• A robust password policy for internal accounts;
• Raising awareness of SkillED teams about Law 18-07 and professional secrecy, which remains imposed on them even after the end of their functions.

10. Rights of Data Subjects

• The right to information on any processing of their data;
• The right of access to the data, its origin and its purpose;
• The right to rectification of inaccurate, incomplete or obsolete data;
• The right to object for legitimate reasons, and to refuse without reason any commercial prospecting;
• The right to deletion when retention is no longer necessary or in the event of withdrawal of consent;
• The right to withdraw consent at any time, without effect on processing already carried out.

These rights are exercised by written request to contact@skilled-dz.com, accompanied by proof of identity. SkillED undertakes to respond within a reasonable time. In the event of a persistent disagreement, the User may refer the matter to the National Authority for the Protection of Personal Data (ANPDP), Algiers.

11. Minors, Parents and Orders

• No data of a minor is collected without the prior and verifiable consent of their parent or legal guardian;
• Any Order of Starter Kits or workshop registration intended for a minor is placed by the parent/legal guardian, the sole holder of the payment method and responsible for the delivery information;
• No direct commercial prospecting is addressed to a minor without the consent of their legal representative;
• Parents/guardians may at any time consult, rectify or delete their child's data by contacting contact@skilled-dz.com.

12. Cookies and Trackers

The Site and the Application may use cookies to ensure their proper functioning (strictly necessary cookies), to measure audience (statistical cookies) and, subject to consent, to personalize the experience. The User can manage their preferences via the settings of their browser/Application or the cookie management banner of the Site.

13. Commercial Prospecting

In accordance with the principle of prohibition set out in Law 18-07, no commercial prospecting by electronic means is carried out without the prior, free and informed consent of the User/Buyer, or of their legal representative for minors. This consent may be withdrawn at any time, free of charge, via an unsubscribe link or a request to contact@skilled-dz.com.

14. Declaration with the ANPDP

In accordance with Article 12 of Law 18-07, any processing of personal data must be the subject of a prior declaration, or where applicable of an authorization, with the National Authority for the Protection of Personal Data (ANPDP). SkillED undertakes to complete these formalities for all processing implemented [and to indicate here the receipt number once obtained].

15. Modifications to the Privacy Policy

This Policy may be updated at any time, in particular to take into account the evolution of the legal framework (Law No. 25-11 amending Law 18-07), the technical or functional evolution of the Services. Any substantial modification will be brought to the attention of Users before its entry into force.

16. Contact

For any question relating to this Privacy Policy or to exercise your rights: contact@skilled-dz.com.

Done in Algiers, 20/08/2026 — SkillED