HELLOSKILLS PRIVACY POLICY

Effective Date: July 29^th, 2025

HelloSkills Group, Inc. (“HelloSkills,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy describes how we collect, use, share, and protect personal data when you access or use our platform, including our website, mobile experiences, and services (the “Platform”). HelloSkills is the data controller responsible for the processing of your personal data.

Our Platform is built for two types of users: SkillExperts and Followers. As a SkillExpert, you may provide paid or unpaid responses to your Followers using the Platform in accordance with our Terms of Service. As a Follower, your registration with HelloSkills unlocks access to our Platform, where you can submit a question or request to a SkillExpert. Either way, when you register with our Platform as a SkillExpert or as a Follower, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. If you do not agree, please do not use the Platform.

For purposes of this Privacy Policy, “personal data” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, and includes “personal information” or similar terms as defined in applicable law.

1. PERSONAL DATA WE COLLECT

As indicated in the chart, we collect the following categories of personal data from and about you. We also indicate the categories of personal data that we disclose to certain third parties, including advertising technology vendors, third-party advertising networks, social media platforms, and data analytics providers, for our advertising or analytics purposes (referred to as “targeted advertising,” or a “sale” or “share” in the U.S. state privacy laws).

Please navigate to the Do Not Sell or Share My Personal Information link in the footer of our website to opt out of targeted advertising/sales/shares. You may also choose to enable a universal tool that automatically communicates your opt-out preference (e.g., Global Privacy Control).

2. HOW WE USE YOUR PERSONAL DATA

We use the personal data we collect to:

• Operate, maintain, and improve the Platform and its features.
• Facilitate payments and payouts via our payment processor.
• Personalize content, recommendations, and functionality for a tailored user experience.
• Respond to support inquiries and provide customer service.
• Enforce our Terms of Service and community standards, including content moderation.
• Detect and prevent fraud, misuse, security incidents, or other illegal activities.
• Comply with applicable laws, regulations, and cooperate with legal authorities.
• Conduct research and analytics to understand user behavior and improve our Services.
• For marketing and promotional purposes, where consistent with your preferences and applicable law.
• To provide you with customized content or targeted offers.
• To carry out sales and business transactions in which information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction.
• To fulfill any other purpose for which you provide personal data or as explained to you at the point of information collection.

We rely on the following legal bases for processing your personal data:

• Performance of a contract: To provide and manage Platform services, including account management, facilitating transactions, and delivering Content.
• Consent: For specific purposes where required by law, which may include, depending on applicable legal requirements, sending marketing communications, personalization, and targeted marketing.
• Legal obligation: To comply with applicable laws, regulations, and legal processes, including fraud prevention, tax obligations, and responding to lawful requests from public authorities.
• Legitimate interests: For platform improvement, security, moderation, analytics, and marketing activities (where consent is not required), provided that such interests are not overridden by your fundamental rights and freedoms. Examples include: improving user experience, detecting and preventing fraud, ensuring platform security, and analyzing usage patterns.

3. RETENTION OF DATA

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as otherwise permitted or required in accordance with applicable law. We will retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. What this means in practice will vary between different types of data. When we consider our approach, we take into account ongoing business or legal needs for the data, such as tax, accounting, or reporting requirements, as well as potential or actual disputes or investigations.

We may retain certain anonymized or aggregated data indefinitely for analytics and platform improvement, as this data cannot be used to identify you.

4. HOW WE COLLECT PERSONAL DATA

There are several ways we may obtain personal data about you, including through (A) data you provide to us, (B) data we automatically collect, and (C) data we receive from third parties. We may combine personal data that we receive from these various sources. We use, disclose, and protect combined personal data as described in this Privacy Policy.

A. Data You Provide to Us

We or our third-party service providers, including payment processors, collect personal data directly from you when you register for an account on the Platform, inquire about our services, make a purchase, or create a SkillExpert or Follower profile.

B. Data We Automatically Collect

When you visit and interact with the Platform, we or our third-party partners and service providers may use a variety of technologies, such as cookies, tags, SDKs, or scripts, to collect certain data regarding your activity. Examples include (A) device and browser information, including device IP address, unique identifiers, browser type, device type, internet service provider, and operating system; and (B) usage information, including the date and time of your visit, the pages you view immediately before or after you access the Platform, the areas or pages of the platform that you visit, the amount of time you spend on the Platform, items you purchase, keystrokes, mouse movements, form field entries, inputs, and overall engagement with the Platform.

When you link your social media account in the Platform, we may automatically receive certain information about you based on your registration and privacy settings with those third-party social networks. This may include information and updates you post on your profile.

If you open a marketing email from us, we may collect information about your interaction with the message, including whether you opened, forwarded, or clicked through to the Platform from the message.

We may use third-party analytics tools to better understand who is using the Platform, how many people are using it, and how to improve its effectiveness as well as the effectiveness of any related content.

We may use cookies on the Platform, including the following categories of cookies:

• Strictly Necessary Cookies. These cookies are essential to enable you to move around the Platform and use its features. These cookies allow us to provide some of the basic functionalities of the Platform.
• Strictly Necessary Cookies. These cookies are essential to enable you to move around the Platform and use its features. These cookies allow us to provide some of the basic functionalities of the Platform.
• Performance Cookies. These cookies generally collect information about how visitors use the Platform so that we can improve our Platform. These cookies do not collect identifiable information.
• Functionality Cookies. These cookies allow the Platform to remember the choices you make as you browse it.
• Targeting/Advertising Cookies. These cookies may be set by our advertising partners, including social media platforms. They may be used by our partners to build a profile of your interests and show you relevant advertisements.

Please note that cookies and other similar technologies provided by third parties may be placed on our Platform. The providers of these technologies may create one or more identifiers associated with you or your device(s) both on and off our Platform, and combine this information with other sources and use the combined information for analytics and/or advertising purposes.

C. Data We Automatically Collect

We may receive personal data from third-party sources, including social media platforms, marketing or analytics providers, and our business partners.

5. DISCLOSURE OF PERSONAL DATA

When you use the Platform as a SkillExpert, you acknowledge and agree that your personal data, including videos and profile, will be disclosed to your Followers as intended consistent with the Platform’s functionality and in accordance with the Terms of Service. Similarly, when you use the Platform as a Follower, you acknowledge and agree that your personal data, including videos and profile, will be disclosed to the SkillExpert with whom you choose to engage in accordance with the Terms of Service. If you do not wish to make your personal data available via the Platform to other users, please do not use the Platform.

Additionally, we may disclose your personal data to the following categories of recipients:

• Service providers. We disclose your personal data to our service providers that provide business, professional, or technical support services to us, process financial transactions, oversee content moderation on the Platform, perform analytics, help us operate our business and the Platform, or administer activities on our behalf.
• Third-party providers. We disclose personal data to our third-party providers, including advertising technology vendors, third-party advertising networks, social media platforms, and data analytics providers, for our advertising or analytics purposes (referred to as “targeted advertising,” or a “sale” or “share” in the U.S. state privacy laws).
• Legal authorities or regulators as required by law, legal process, or governmental request.
• Relevant Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your personal data to certain third parties, such as the acquiring entity and its advisers.
• Other Third Parties. We will disclose your personal data to other third parties at your direction or with your consent. Additionally, we will disclose your personal data as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.
• We may disclose your personal data for other reasons we will describe at the time of data collection or prior to disclosing your personal data.
• Please note that we may de-identify or aggregate personal data so that it will no longer be considered personal data and disclose such information to other parties for purposes consistent with those described in this Privacy Policy.

6. YOUR PRIVACY RIGHTS

A. US Residents

If you are a US resident, you have the following rights:

• Right to Know what personal data we have collected about you, including the categories of sources from which the personal data is collected, the business or commercial purpose for collecting, selling, or sharing personal data, the categories of third parties to whom we disclose personal data, the categories of personal data disclosed to third parties, and the specific pieces of personal data we have collected about you. Depending on your state of residence, you may also have the right to request information about the third parties to which we have shared or sold your personal data (including Oregon, Minnesota, Connecticut, or Delaware residents). You have the right to access personal data in a portable format where feasible.
• Right to Delete personal data that we have collected from or about you, subject to certain exceptions.
• Right to Correct inaccurate personal data that we may maintain about you, subject to appropriate verification.
• Right to Opt Out of the disclosure of your personal data for targeted advertising (including “sales” or “shares” as such terms are defined in applicable law).

B. Non-US Residents, including Canada, EEA, and UK

Under applicable law, you may have certain rights in relation to your personal data, including:

• Right to Access: You have the right to request access to, or copies (and transmission) of, the personal data we hold about you and the purposes for which we are using it.
• Right to Rectify: You have the right to correct inaccurate personal data that we have collected from and maintain about you, subject to appropriate verification.
• Right to Erase: You have the right to erase personal data pertaining to you, under certain conditions. We will assess any deletion request after verifying your identity and work to respond within one calendar month, and let you know if we need additional time.
• Right to Object: You have the right to object to processing the personal data we process, under certain conditions.
• Right to Restrict: You have the right to restrict the processing of your personal data, under certain conditions.
• Right to Data Portability: You have the right to receive the data we have collected from you. Under certain conditions, you may request that we transfer your personal data to another organization, or directly to you.
• Right with respect to Automated Processing: You have the right not to be subject to automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• Right to Lodge a Complaint: You have the right to file a complaint with the supervisory authority in your jurisdiction.

C. Exercise Your Privacy Rights

Please contact us to exercise your privacy rights at privacy@helloskills.com . To manage your cookie preferences or to opt out of the sale or sharing of your personal information, please use the links in the footer.

US residents: If you enable a browser-based opt-out preference signal, such as Global Privacy Control, upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of personal information or opt out of targeted advertising.

Other than for opt-out requests, we may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us. Other than for opt-out requests, we may decline a request if we are not able to verify your identity. Submitting a privacy rights request does not require you to create an account with us.

We will not discriminate against you if you decide to exercise your privacy rights.

You have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at privacy@helloskills.com.

D. AUTHORIZED AGENT REQUESTS

Only you, or someone legally authorized to act on your behalf, may submit a request related to your personal data.

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.

7. CHILDREN’S PRIVACY

You must be 18 years or older to create an account and use the Platform. Individuals under 18 years old are not permitted to create an account or use the Platform.

We do not knowingly process personal data for targeted advertising or “sell” or “share” personal data from individuals who are under 18 years old.

Please do not upload an image, video, or other content about an individual under 18 years of age on the Platform. If you are aware of content that does not comply with this policy, please contact privacy@helloskills.com , and our team will assist with taking down the relevant content.

8. INTERNATIONAL TRANSFERS

We operate globally, and our servers are located in the United States. If you access the Platform from outside the U.S., your personal data may be transferred to, processed in, and stored in the United States or other countries, which may have different data protection laws than your country of residence.

For EEA and UK users, we ensure that such international transfers are conducted with appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission and the UK Information Commissioner’s Office (ICO), as applicable.
• Adequacy decisions where applicable (e.g., transfers to countries deemed to provide an adequate level of data protection by the European Commission or UK government).
• Other legally recognized transfer mechanisms.

9. DATA SECURITY

We implement robust administrative, technical, and physical safeguards designed to protect your personal data from unauthorized access, disclosure, alteration, and destruction.

While we strive to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

10. EXTERNAL LINKS

Our Platform may have links to third-party services, including social media networks, which may have privacy policies that differ from our own. We are not responsible for the practices of such services or websites.

11. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated to you by posting the updated Privacy Policy on the Platform, through email notification, or other reasonable means. Your continued use of the Platform after the effective date of the revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically.

12. CONTACT US

For questions, concerns, or to exercise your rights under this Privacy Policy, please contact our Privacy Officer at: privacy@helloskills.com