Privacy Policy

1. Introduction

This Privacy Policy (the “Policy”) describes how Skillmaker, Inc. (“Skillmaker”), together with the National Automotive Parts Association, LLC (“NAPA”), Genuine Parts Company (“GPC”), Solera Holdings, LLC and its affiliates including Identifix (collectively, “Solera”), AutoVitals, Inc. (“AutoVitals”), and other authorized partners, licensors, suppliers, and affiliates (each a “Partner” and collectively the “NAPA XcceleratoR Parties,” “we,” or “us”) collect, use, disclose, and protect personal information in connection with the NAPA XcceleratoR^TM program (the “Program”), including the NAPA XcceleratoR application, the extended reality (XR) headset and any associated Smart Glasses, peripherals, and other hardware (the “Devices”), the software, firmware, and platform that operate them (the “Software”), and any related websites, content, services, and support (collectively with the Devices and Software, the “Services”).

By accessing, registering for, deploying, or otherwise using the Services, you agree to the collection, use, and disclosure of your information as described in this Policy. If you do not agree, do not use the Services.

Skillmaker publishes this Policy on behalf of itself and the other NAPA XcceleratoR Parties solely with respect to personal information collected through the Services. With respect to such information, this Policy supplements and, in the event of any conflict, supersedes the general privacy notices published by individual NAPA XcceleratoR Parties (including the Genuine Parts Company Online Privacy Notice posted at napaonline.com/privacy). Personal information collected by a NAPA XcceleratoR Party outside of the Services continues to be governed by that party’s own privacy notice.

2. Scope and Applicability

This Policy applies to personal information collected from or about:

•  Account holders, administrators, owners, and personnel of NAPA Auto Care centers, NAPA AutoCare shops, independent service centers, fleets, dealerships, training institutions, and other enterprise customers (each a “Subscriber”) that license the Services;

•  Technicians, apprentices, instructors, students, and other end users who use the Devices and Software (each a “User”);

•  Visitors to any Program-related website, portal, e-commerce store, or support channel; and

•  Individuals who otherwise interact with the Services, including in connection with sales inquiries, demonstrations, conferences, or pilots.

The Services are intended for business and workforce-development use and are not directed to children under thirteen (13). See Section 11 (Children’s Privacy).

3. Information We Collect

We collect information directly from you, automatically through the Devices and Software, and from third parties such as Subscribers and Partners.

3.1 Information You Provide

•  Identifiers and contact data: name, employer, job title, work email and phone, mailing address, ASE certification numbers, and similar professional identifiers.

•  Account credentials: username, password, security questions, and authentication tokens.

•  Commercial information: orders, invoices, deposit and subscription records, license keys, hardware serial numbers, and shipping information.

•  Training and assessment information: course enrollments, scenarios completed, scores, certifications earned, instructor feedback, and skills profile.

•  Communications: messages, support tickets, survey responses, recorded calls (where lawful and disclosed), and content you submit to forums, reviews, or feedback channels.

•  Payment information: billing contact, payment method details, and tax identifiers (collected and processed by our payment processors and not stored in cleartext on our servers).

3.2 Information Collected Automatically by the Devices and Software

The Devices and Software are designed to deliver immersive, performance-driven training. To do so, they collect technical, sensor-based, and usage information, which may include:

•  Device information: hardware identifiers, model and serial numbers, firmware version, battery and storage status, network identifiers, IP address, and diagnostic logs.

•  Usage information: features accessed, modules launched, scenarios attempted, time on task, completion status, error events, and crash reports.

•  Sensor and environmental data: motion, orientation, position, and inertial data; controller inputs; ambient lighting; and, where supported, room-scale boundary configurations and environmental images used solely to establish a safe play area.

•  Interaction signals: eye-tracking metrics (such as fixation, dwell time, and gaze direction), hand-tracking, head pose, and gesture inputs, used to evaluate task performance and adjust the simulation.

•  Audio and voice: microphone input captured during voice commands, instructor coaching, or scenario narration; voice recordings may be transcribed and analyzed for training quality and platform improvement.

•  Imagery from Smart Glasses or cameras: when the Smart Glasses or any Device camera is engaged, still images and short video segments of the work environment may be captured to enable remote assistance, scenario authoring, quality review, and case-study development.

•  Cookies, pixels, and similar technologies: used by our companion websites and portals to authenticate users, remember preferences, measure performance, and—subject to your choices—deliver relevant content.

We do not use the Devices’ sensors to identify individuals through facial recognition or to derive a unique biometric template for identification purposes, except where (a) the Subscriber has expressly enabled such functionality for legitimate training, safety, or proctoring use cases, and (b) we have obtained the written consent required by applicable law.

3.3 Information from Third Parties

•   Subscribers: rosters of authorized Users, employment status, role, location, training assignments, and supervisor relationships.

•  From NAPA, GPC, and Participating Stores: store affiliation, NAPA program enrollment, and related account information.

•  From Solera/Identifix and AutoVitals: integrated diagnostic data, repair-order references, content licensing identifiers, and authentication tokens necessary to deliver integrated functionality.

•  From background, identity verification, and fraud prevention services where required.

•  From publicly available sources, marketing partners, and analytics providers.

4. How We Use Information

The NAPA XcceleratoR Parties use information for the following purposes:

•  Provide, operate, and maintain the Services, including provisioning Devices, delivering content, scoring assessments, and issuing certifications.

•  Authenticate Users, prevent unauthorized access, and protect the integrity of the Services.

•  Personalize training pathways, recommend modules, and adapt scenarios based on User performance.

•  Communicate with you about orders, deposits, shipments, releases, training events, support matters, and safety advisories.

•  Provide reporting to Subscribers and Partners regarding workforce performance, license utilization, and program outcomes (in identified, de-identified, or aggregated form, as agreed).

•  Improve and develop the Services, including training and improving artificial intelligence and machine-learning models that power the platform; we use de-identified or aggregated data wherever feasible for these purposes.

•  Conduct research, case studies, benchmarking, and analytics — for example, the NAPA XcceleratoR case-study program — using data that is aggregated, anonymized, or used with consent where required.

•  Market and promote the Services and related offerings of the NAPA XcceleratoR Parties, subject to your communication preferences and applicable law.

•  Comply with legal obligations, enforce our agreements, defend legal claims, and respond to lawful requests from government authorities.

•  Detect, investigate, and prevent fraud, security incidents, harassment, and other harmful or unlawful activity.

5. How We Share Information

We share personal information among the NAPA XcceleratoR Parties and with the following categories of recipients, in each case subject to appropriate contractual and security safeguards:

•  Among the NAPA XcceleratoR Parties: Skillmaker, NAPA, GPC, Solera, AutoVitals, and other Partners share the personal information necessary to deliver the Services, integrate diagnostic and shop-management content, fulfill orders, support Devices, and report on program outcomes.

•  Subscribers and their authorized administrators: We share User account, training, and performance information with the Subscriber that licenses the Services on the User’s behalf. Subscribers are responsible for providing required notices to their personnel and for setting internal access controls.

•  Service providers and processors: Hosting, cloud infrastructure, analytics, customer support, communications, payment processing, shipping and logistics, identity verification, and similar vendors that act on our behalf under written agreements that limit their use of personal information.

•  Authorized resellers and channel partners: Including independent NAPA-branded stores and Auto Care centers, where necessary to administer accounts, fulfill orders, or provide support.

•  Professional advisors: Auditors, accountants, attorneys, insurers, and consultants, in connection with their professional services.

•  Corporate transactions: In connection with a financing, merger, acquisition, reorganization, sale of assets, bankruptcy, or similar event, in which case personal information may be transferred subject to standard confidentiality protections.

•  Legal and safety: When we believe disclosure is required by law, court order, or governmental request, or is necessary to protect the rights, property, or safety of the NAPA XcceleratoR Parties, our Users, or others.

•  With your direction or consent: Including when you choose to publish content, share scenarios, or participate in case studies or marketing materials.

We do not sell personal information for monetary consideration. To the extent that any sharing is considered a “sale” or “sharing for cross-context behavioral advertising” under applicable law, we honor opt-out requests as described in Section 9.

7. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, including to provide the Services, maintain training records and certifications, comply with legal, accounting, or reporting obligations, resolve disputes, and enforce our agreements. When personal information is no longer needed, we will delete it or de-identify it. Aggregated and de-identified information may be retained indefinitely.

8. Information Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against loss, misuse, unauthorized access, disclosure, alteration, and destruction. Measures include encryption in transit and at rest where appropriate, role-based access controls, secure software development practices, audit logging, and personnel training.

No method of transmission over the internet or electronic storage is one hundred percent (100%) secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your credentials and notifying us promptly of any suspected compromise.

9. Your Privacy Choices and Rights

Subject to applicable law and to verification of your identity, you may have the following rights with respect to your personal information:

•  Access: request confirmation of, and a copy of, the personal information we hold about you.

•  Correction: request correction of inaccurate or incomplete personal information.

•  Deletion: request deletion of personal information, subject to exceptions permitted by law (for example, certifications and records we are required to retain).

•  Portability: request a portable copy of certain personal information you provided to us.

•  Opt-out of sale or targeted advertising: where applicable, opt out of sharing that constitutes a “sale” or “sharing for cross-context behavioral advertising.”

•  Limit use of sensitive personal information: where applicable under California or other state law.

•  Withdraw consent: where processing is based on consent, you may withdraw consent at any time without affecting prior lawful processing.

•  Lodge a complaint: with a supervisory authority where you reside.

If you are a User accessing the Services through a Subscriber, please direct rights requests to your Subscriber first; we will support the Subscriber in responding. To submit a request directly, contact us using the information in Section 14. We will not discriminate against you for exercising your privacy rights.

9.1 Cookies and Tracking

You can manage cookies through your browser settings and through cookie-preference tools made available on our websites. Industry self-regulatory programs, including the Network Advertising Initiative and the Digital Advertising Alliance, also provide opt-out tools for interest-based advertising. We also honor Global Privacy (GPC) opt-out preference signals where technically feasible.

10. International Transfers

The Services are operated from the United States. If you access the Services from outside the United States, you understand that your personal information may be transferred to, processed, and stored in the United States and other countries where the NAPA XcceleratoR Parties or their service providers operate. Where required, we use appropriate transfer mechanisms to safeguard cross-border transfers.

11. Children’s Privacy

The Services are not directed to children under thirteen (13), and we do not knowingly collect personal information from children under thirteen (13). Where the Services are deployed in approved educational, secondary, or post-secondary settings involving Users between thirteen (13) and seventeen (17), Subscribers (such as schools, training institutions, or guardians) are responsible for providing required notices and obtaining required consents under the Children’s Online Privacy Protection Act (“COPPA”), the Family Educational Rights and Privacy Act (“FERPA”), and other applicable laws. We do not condition participation in our Services on disclosure of more personal information from a child under thirteen (13) years, or Users between (13) and seventeen (17), than is reasonably necessary for participation, and we do not retain personal information from such Users longer than is reasonably necessary in order to fulfill the purpose for which it was disclosed.

12. Third-Party Sites, Services, and Content

The Services may contain links to or integrate with third-party websites, applications, content, or services, including those operated by Solera/Identifix, AutoVitals, NAPA, hardware manufacturers (such as smart-glasses providers), and other Partners. This Policy does not apply to those third-party sites and services. We encourage you to review the privacy notices of any third party before providing your information.

13. Important Notice Regarding XR Devices and Sensor Data

The Devices include sensors that collect data about you and your environment in real time. Before using the Devices, please be aware:

•  Sensor data described in Section 3.2 (including motion, gaze, audio, and environmental imagery) may be processed locally on the Device, transmitted to our cloud, and analyzed to deliver and improve the Services.

•  When operating in a shop, classroom, or other shared space, the Devices may capture images of bystanders, vehicles, customer property, and surrounding environments. Subscribers and Users are responsible for posting any signage and obtaining any consents required by law in their jurisdiction.

•  If a User wishes to opt out of optional features such as voice analytics, gaze analytics, or environmental imagery for case-study purposes, the User or Subscriber may adjust the relevant settings in the Software or contact us for assistance.

15. Changes to this Policy

We may update this Policy from time to time. Material changes will be posted with an updated effective date, and we may provide additional notice where required by law.

— End of Privacy Policy —

NAPA XcceleratoR™ is a trademark of Skillmaker, Inc., used in cooperation with the National Automotive Parts Association, LLC.