Last Modified: February 12, 2020
WHO IS RESPONSIBLE FOR YOUR INFORMATION?
WHAT INFORMATION DO WE COLLECT?
When you use the Services, you may provide the Company with two main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you browse and use the Services. We collect information from you when you (a) use and/or access the Services, (b) register an account and/or subscribe to the Company’s courses, (c) open and/or respond to our emails, (d) contact the Company, and/or (e) visit any page online that displays our content, (f) make purchases or register through the Services, and/or (g) provide information to any of our customers, partners, and/or other users.
We collect and process the following information about you both online and offline.
Personally Identifiable Information You Choose to Provide
We may ask for certain personal information from you for the purpose of providing to you content and/or services that you request. We collect personal information such as: (i) your personal and/or business contact information (including name, telephone number, email and address, and business website address); (ii) Company name and title; (iii) your financial information (such as checking account information, credit card number, expiration date, verification number, and billing address); (iii) username and password, if applicable; (iv) location information; and/or (v) preferences, behavior and testimonials. Once you register, you have opted in to receive electronic communications from the Company. The Company may also provide you with the opportunity to participate in surveys through the Services. If you participate, we will request certain personally identifiable information. Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.
Information We Collect Automatically
Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
Aggregate: We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on, system configuration information, and/or other interactions with the Services. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual.
Analytics: We use analytic software to gather statistics and usage trends for product and service improvement purposes. The Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.
Site Information: We collect information related to course enrollments, course usage and other transactional data, including without limitation product and/or service orders. We also collect data in the event you respond to a survey or submit publicly available information, such as through your social media posts. In the event you respond to us or submit requests through our Services, we may retain the content of your messages together with our responses to your requests.
WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?
The information collected in the aggregate enables the Company to better understand your use of the Services and to enhance your enjoyment. We may use financial information to process payment, enroll you in one of our courses and/or other related services in which you elect to participate. If you use the Services, you agree to receive certain communications from us including but not limited to the following:
Special Offers, Newsletters and Updates. We will occasionally send you information on products, special deals, promotions and newsletters. You can sign up for these emails from us at any time. Out of respect for your privacy, you may elect not to receive these types of communications by contacting us or replying to our emails.
Blogs. Our Service may have links or access to publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect.
For any personal information collected about you in the EU, our basis for processing is the following:
HOW LONG DOES THE COMPANY RETAIN PERSONAL INFORMATION?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
The Company maintains personal information for the following retention periods:
Please be aware that even after your request for a change is processed or following termination and/or deactivation of your account, we may, for a time, retain residual information about you in its backup, audit and/or archival copies of its database, and reserve the right to access and utilize collected user data in the future. Please be aware that we may still email you non-commercial emails related to your account and your transactions through the Services. In some cases, if you choose not to provide the Company with requested information, you may not be able to use and/or access all of the Services.
WHEN AND HOW WE CAN SHARE YOUR PERSONAL INFORMATION?
For Collaboration: We may share your information, including when you choose to use certain features in the Services that by their nature support sharing with third parties who you choose. Your name, email address, and any content you choose to share will be shared with such third parties, and such third parties may communicate with you in connection with your use of the Services. Additionally, if you request or authorize us to share your information, we will do so in such circumstances.
Business Transfers: If we sell or otherwise transfer part or all of the Company or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation or similar proceedings), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.
General: Your personal information may be shared if it is made anonymous and aggregated, as in such circumstances the information ceases to be personally identifiable data. We do not provide personal information to companies for the purpose of independent telemarketing, email marketing, or direct mail marketing of any products or services of those companies.
HOW IS YOUR PERSONAL INFORMATION SECURED?
The Company has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We maintain security standards and procedures to help prevent unauthorized access, loss, misuse, alteration, disclosure, or destruction of confidential information about you. All sensitive/credit card information you supply is encrypted via Secure Socket Layer (SSL) technology. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. While we strive to secure your information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control. Please do your part to help the Company. You are responsible for maintaining the secrecy of your account information, and for controlling access to emails between you and the Company, at all times. Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing the Services. We are not responsible for the functionality, privacy and/or security measures of any other organization.
WHAT ARE YOUR CHOICES?
Your Information Choices
We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to us, and you can limit the communications that we send to you. You have the choice to exercise any of the following choices:
You can exercise these choices by contacting us at email@example.com.
Your California Privacy Rights
Under California Consumer Privacy Act (“CCPA”), California residents are entitled to receive the right to access and obtain a copy of your personal information. You may write us and ask for records of any and all personal information. The CCPA requires businesses to disclose (1) the categories of personal information the business collected about Individuals, (2) the categories of sources from which personal information is collected, (3) the business or commercial purpose for collecting or selling personal information, (4) the categories of third parties with whom the business shares personal information, and (5) the specific pieces of personal information the business has collected about the Individual. To obtain such information from the Company, please email your request to firstname.lastname@example.org and we will provide a list of categories of personal information disclosed within thirty (30) days of receiving such a request. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above. The following exceptions may prevail with respect to fulfillment of data access requests: (a) the Company may not provide personal data to an Individual, if management determines that we cannot identify the Individual in our systems because the data we have has been de-identified to the extent that identification is not possible; and/or (b) the Company may not provide personal data to an Individual, if the Individual is involved in a civil or criminal proceeding with the Company.
Data Protection Rights for EU members. For purposes of the applicable data protection laws (the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), we would like to make sure you are fully aware of all of your data protection rights. Under the GDPR, you have various rights in relation to your personal information, such as the rights of access and receive copies of personal information, rectification whereby you may ask us to correct any information which you believe is inaccurate, restriction rights to request restrictions on processing of your personal data under certain circumstances, objection of processing certain personal data, portability rights to request that we transfer data to another organization, and erasure rights to request that the Company erase certain personal data. Please note that these rights are subject to certain limitations set forth in applicable law.
To exercise these rights, please contact our data protection officer at email@example.com. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of applicable laws. Please note that we may keep a record of your communications to help us resolve any issues you raise. If you make a request, we have one month to respond to you.
DO WE COLLECT SENSITIVE INFORMATION FROM CHILDREN?
The Company does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information, please contact us at firstname.lastname@example.org. By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Services.
HOW WE USE OTHER WEB SITES AND SERVICES
WHAT LANGUAGE GOVERNS?
HOW TO CONTACT THE COMPANY IF YOU HAVE QUESTION, COMMENTS OR COMPLAINTS
If you have any questions, comments or concerns, please contact email@example.com