TraxxSkills Privacy Policy

Version 1.0 — Effective July 8, 2026

1. Introduction

This Privacy Policy describes how TraxxSkills, Inc. ("TraxxSkills," "we," "us," or "our"), a Delaware corporation, collects, uses, shares, retains, and protects information when you use the TraxxSkills™ platform, including our mobile and web applications, our learning curriculum, related in-person program events, and any associated websites and services (collectively, the "Platform").

TraxxSkills provides a learning platform offered to students at participating colleges and universities. Your institution may provide limited verification information (name, year of enrollment, student ID number) to confirm your eligibility. Your institution does not provide us with your education records or grades. We share specific individual alerts with your institution's advising team as described in Section 5. If this Policy says something different from an IRB-approved research consent form you have signed, the consent form takes priority for all matters relating to research participation and research data.

By creating an account or using the Platform, you acknowledge this Privacy Policy. If you do not agree with it, do not use the Platform.

2. Information We Collect

2.1 Information you provide

Account and identity information. Your name, university email address, institution, and the typed signature you provide during consent and account creation.
Consent records. Your documented agreement to participate, including the consent version, timestamp, and typed signature.
Assessment responses. Your answers to pre-program, mid-program, and post-program assessment instruments administered through the Platform.
Responses to Platform content. The responses and choices you make within Platform content, such as behavioral scenarios, interactive exercises, and games.
Field task records. Your reports on field tasks completed in your real-life context, including whether the task was attempted and any reflection you submit. We do not collect identifying information about other people involved in your field tasks.
Communications. Messages you send to us, including support requests to support@traxxskills.com.
Optional demographic information. You may voluntarily choose to share demographic information, such as your race or ethnicity, age, gender, whether your parent(s) completed college, your perception of your family's social standing relative to others (in terms of money, education, and respect), and your relationship to the English language, to help us understand program reach and participation across student populations, and to analyze whether program engagement and outcomes vary across these groups so we can better understand and improve the Platform's impact. Providing this information is entirely optional, and you can use the Platform fully without sharing it.

2.2 Information collected automatically (behavioral signals)

As you use the Platform, we automatically collect behavioral signals generated by your interactions with Platform content and activities. These signals are used to compute the Behavioral Persistence Index™ (BPI™) and to evaluate whether behavioral signals of this kind can reliably inform personalized learning in the future. During pilot programs, these signals are collected and analyzed but are not used to personalize or adapt your experience. The categories collected include:

How you interact with Platform content and activities, such as when you start, pause, resume, and complete them
The timing and frequency of your activity on the Platform
Session information, such as login times, session duration, and in-app navigation events
Program engagement records, such as lesson completions, field task completions, and confirmed attendance at in-person program events

During research programs, research data collection is described in the consent form you sign and is governed by the IRB-approved research protocol.

2.3 Device and technical information

We collect technical information needed to operate and secure the Platform, such as device type, operating system, app version, IP address, crash logs, and authentication events.

2.4 What we do not collect

The Platform measures how you interact with TraxxSkills content. It does not surveil your life outside the Platform. We do not:

Access your device microphone, camera, photos, contacts, or messages
Track your precise geolocation
Log keystrokes or capture content you type in other applications
Monitor your activity in other apps, browsers, or learning systems
Collect biometric identifiers
Scrape or ingest your social media accounts

3. How We Use Information

We use the information described above to:

Provide, operate, and improve the Platform
Evaluate the feasibility and reliability of behavioral measures that may inform personalized and adaptive learning in future versions of the Platform
Compute behavioral measures, including the BPI
Where you have voluntarily provided optional demographic information, analyze whether program engagement and outcomes vary across demographic groups to better understand and improve the Platform's impact
Conduct IRB-approved research, as described in the consent form you sign
Produce de-identified, aggregate cohort-level reporting for your institution
Generate individual alerts to your institution's advising team as described in Section 5
Administer in-person program events, including attendance confirmation
Communicate with you about your account, the program, and support requests
Maintain the security and integrity of the Platform, prevent fraud and abuse, and debug and fix errors
Comply with legal obligations, including research records retention requirements

We do not use your information for advertising. We do not display third-party advertising on the Platform, do not use your data for targeted advertising, and do not build profiles of students for any purpose other than providing the educational service, analyzing program engagement and outcomes (including in connection with the optional demographic information described in Section 2.1), and conducting the research described in your consent form.

4. Research Participation

Where the Platform is offered as part of an IRB-approved research study, your participation is governed by the informed consent form approved by the reviewing Institutional Review Board. The consent form describes the specific data collected for research, how research data is pseudonymized, who may access it, how long it is retained, and how to withdraw. With respect to research data, the consent form controls over this Policy.

Research data is pseudonymized in the manner described in your consent form, separating your identity from your behavioral and assessment data. TraxxSkills does not analyze or use your behavioral or assessment data in identifiable form: analysis is performed only on pseudonymized or de-identified data. Your identifying information, such as your name and email address, is used only to administer your account, maintain consent records, communicate with you, and where applicable to generate the alerts described in Section 5.

5. How We Share Information

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising. We share information only as follows:

With your institution. Two streams of information are shared with your institution. First, de-identified, aggregate cohort-level reports describing program engagement and outcomes. Second, individual alerts attached to your name, generated automatically when behavioral signals indicate you may benefit from support. Alerts are routed to your institution's designated advising or retention team. We do not share your full BPI score, your underlying behavioral signal data, or your assessment responses with your institution in identifiable form.
With service providers. Vendors who process data on our behalf and under our instructions, such as our software development and platform engineering vendor, cloud hosting, email delivery, analytics infrastructure, and assessment administration providers. Service providers are bound by contractual confidentiality and data protection obligations and may not use your information for their own purposes.
With the research team. Pseudonymized research data is accessible to the investigators and personnel identified in the IRB-approved protocol, under the access controls described in the consent form.
For legal reasons. When required by law, subpoena, or court order; to enforce our agreements; or to protect the rights, safety, or property of TraxxSkills, our users, or others. Where legally permitted, we will notify you of legal demands for your information before disclosure.
In a business transfer. If TraxxSkills is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Policy and applicable student privacy law. Any successor remains bound by the commitments in this Policy, including the prohibition on selling student personal information and on using it for targeted advertising.

6. Education Records

TraxxSkills receives only limited verification information from your institution (name, year of enrollment, student ID number) to confirm your eligibility. TraxxSkills does not receive your education records, grades, or other personally identifiable student information from your institution. If a future program involves the disclosure of education records by an institution to TraxxSkills, that program will be governed by a written agreement satisfying the Family Educational Rights and Privacy Act (FERPA), and this Policy will be updated before any such data is collected.

7. Student Data Privacy Commitments

TraxxSkills complies with applicable federal and state student data privacy laws and the commitments described in Sections 3 and 5.

8. Data Retention

We retain information only as long as needed for the purposes described in this Policy. In general: upon account deletion, your operational data is deleted or permanently de-identified within seven (7) business days, consistent with the deletion process described in Section 9.1; certain user activity records may be retained in de-identified or aggregated form for auditing, reporting, or research purposes, and once de-identified this data can no longer be associated with you; research data is retained for the periods stated in your consent form and the IRB-approved research protocol; consent and withdrawal records are retained separately for as long as required by the IRB-approved research protocol and applicable research regulations, even after account deletion, and are not linked to identifiable user data; de-identified and aggregated data may be retained indefinitely and is no longer traceable to any individual and deleted data is removed from system backups in the ordinary course of backup rotation.

When retention periods expire, we delete or de-identify the information. Data that has been genuinely de-identified and aggregated into research datasets is no longer associated with you and cannot be retrieved or deleted on an individual basis.

9. Account Deletion and Research Withdrawal

9.1 Deleting your account

You may delete your account at any time through the app or by emailing support@traxxskills.com from your registered email address. Email requests are reviewed and processed within 3 to 7 business days, subject to verification of your identity.

Deletion is irreversible. Your profile information, personal details, and account identifiers are deleted or detached from activity records, and the account can no longer be accessed or recovered. If you later register again with the same email address, you are treated as a completely new user, and no prior data, records, or settings are restored. De-identified activity records may be retained for reporting, audit, analytics, and compliance purposes, and aggregate reports generated before your deletion may continue to reflect your activity in non-identifiable, cohort-level form. Deleted data is removed from system backups in the ordinary course of backup rotation.

9.2 Research withdrawal options

If you are a research participant, withdrawal from research is distinct from account deletion and is governed by your consent form, which describes your withdrawal options and what happens to previously collected research data under each. You may withdraw at any time, and withdrawal carries no penalty and does not affect your standing with your institution. To withdraw, follow the instructions in your consent form or contact support@traxxskills.com.

Consent records are retained per Section 8 even after deletion or withdrawal, as required for research audit. Data already de-identified and aggregated into research datasets cannot be withdrawn because it can no longer be traced to you.

10. Your Privacy Rights

Subject to applicable law and the research records exceptions described above, you may request to:

Correct inaccurate personal information
Delete your personal information (see Section 9)
Know the categories of information we collect, the purposes of collection, and the categories of recipients

Residents of certain states (including, where applicable, California, Connecticut, Colorado, and others with comprehensive privacy laws) may have additional statutory rights, including the right to appeal a denied request and the right not to receive discriminatory treatment for exercising privacy rights. Because we do not sell personal information or use it for targeted advertising, no opt-out is required for those activities, and we do not need to and do not respond differently to browser-based opt-out preference signals (such as Global Privacy Control) for those purposes.

To exercise any right, email support@traxxskills.com. We will verify your identity using your account email and respond within the time required by applicable law (generally 45 days). If we deny a request, we will explain why, and you may appeal by replying to our response. Some requests may be limited where the information is required to be retained under the IRB-approved research protocol, applicable research regulations, or law; in that case we will tell you which exception applies.

Where you have voluntarily provided sensitive demographic information, such as race or ethnicity, you may request that we limit its use to the purpose for which it was provided, or ask us to delete it, at any time.

11. Age Requirements and Children

The Platform is intended for enrolled postsecondary students who are 18 years of age or older. Eligibility screening occurs before account creation, and individuals who indicate they are under 18 cannot create an account. The Platform is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, or from any individual under 18 in connection with a program restricted to adults, we will delete it promptly. If you believe a minor has provided us personal information, contact support@traxxskills.com.

12. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, separation of identifiers from behavioral data through pseudonymization, audit logging of administrative actions (including all deletion executions), and contractual security obligations for service providers. No system is perfectly secure; if we determine that a breach of security has resulted in unauthorized acquisition of your personal information, we will notify you and, where required, your institution and regulators, in accordance with applicable breach notification laws.

13. De-identified and Aggregate Data

We may create and use de-identified or aggregated data (data that cannot reasonably be linked to you) for research publication, product improvement, institutional reporting, and benchmarking. We commit to maintaining such data in de-identified form and not attempting to re-identify it, and we require the same of recipients.

14. Where Data Is Processed

Information is stored in the United States on Amazon Web Services (AWS) US-region infrastructure. Mobisoft Infotech is our software development and platform engineering vendor, and developer personnel may access the Platform from outside the United States solely to operate, maintain, support, and improve the system on our behalf. Such access is subject to the contractual confidentiality and data protection obligations described in Section 5. The Platform is intended for users in the United States and is not directed to individuals in the European Economic Area or the United Kingdom.

15. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you through the Platform or by email before the changes take effect, and where the change affects research data practices, any required IRB and re-consent processes will be followed. The "Version" and date above indicate the current revision. Your continued use of the Platform after the effective date of an updated Policy constitutes acknowledgment of the update.

16. Contact Us

TraxxSkills, Inc. Attn: Privacy 26 Pebble Dunes Ct, Las Vegas, NV 89141 Email: privacy@traxxskills.com

For research-related questions or concerns about your rights as a research participant, you may also contact the Principal Investigator or the reviewing IRB identified in your consent form.