Last Modified: February 12, 2020
WHO IS RESPONSIBLE FOR YOUR INFORMATION?
WHAT INFORMATION DO WE COLLECT?
Whenyou use the Services, you may provide the Company with two main types ofinformation: (1) personally identifiable information that you knowingly chooseto disclose, which is collected on an individual basis, and (2) general userinformation that does not contain personally identifiable information, which iscollected on an aggregate basis as you browse and use the Services. We collectinformation from you when you (a) use and/or access the Services, (b) registeran account and/or subscribe to the Company’s courses, (c) open and/or respondto our emails, (d) contact the Company, and/or (e) visit any page online thatdisplays our content, (f) make purchases or register through the Services,and/or (g) provide information to any of our customers, partners, and/or otherusers.
Wecollect and process the following information about you both online andoffline.
Personally Identifiable Information You Choose toProvide
We mayask for certain personal information from you for the purpose of providing toyou content and/or services that you request. We collect personalinformation such as: (i) your personal and/or business contact information(including name, telephone number, email and address, and business websiteaddress); (ii) Company name and title; (iii) your financial information (suchas checking account information, credit card number, expiration date,verification number, and billing address); (iii) username and password, ifapplicable; (iv) location information; and/or (v) preferences, behavior andtestimonials. Once you register, you have opted in to receive electroniccommunications from the Company. The Company may also provide you withthe opportunity to participate in surveys through the Services. If youparticipate, we will request certain personally identifiable information. Participation in surveys is completely voluntary and you therefore have achoice whether to disclose such information.
Information We Collect Automatically
DeviceData: We use device data, which is informationconcerning 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 andtime zone of your device, geo-location, unique device identifier and/or otherdevice identifier, mobile phone carrier identification, and device softwareplatform and firmware information.
Aggregate: We may collect non-identifying andstatistical information about the use of our Services, such as how manyvisitors visit a specific page, how long they stay on that page and whichlinks, if any, they click on, system configuration information, and/or otherinteractions with the Services. This information represents a genericoverview of our users, including their collective habits. Information collectedin the aggregate is not associated with you as an individual.
Analytics: We use analytic software to gatherstatistics and usage trends for product and service improvement purposes. The Service may record data from your phone, tablet, or computer such as howfrequently you use the Service, what actions you take and performancedata.
SiteInformation: We collect information related to course enrollments, course usage and othertransactional data, including without limitation product and/or serviceorders. We also collect data in the event you respond to a survey orsubmit publicly available information, such as through your social media posts.In the event you respond to us or submit requests through our Services, we mayretain the content of your messages together with our responses to yourrequests.
WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?
Theinformation collected in the aggregate enables the Company to better understandyour use of the Services and to enhance your enjoyment. We may use financialinformation to process payment, enroll you in one of our courses and/or otherrelated services in which you elect to participate. If you use theServices, you agree to receive certain communications from us including but notlimited to the following:
SpecialOffers, 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 anytime. Out of respect for your privacy, you may elect not to receive these typesof communications by contacting us or replying to our emails.
Blogs. Our Service may have links or accessto publicly accessible blogs or community forums. You should be aware that anyinformation you provide in these areas may be read, collected, and used byothers who access them.
CustomerService. Based upon the personally identifiableinformation you provide us, we will communicate with you in response to yourinquiries, to provide the services you request and to manage your account. Wewill communicate with you by email or telephone, as you may elect.
For anypersonal information collected about you in the EU, our basis for processing isthe following:
HOW LONG DOES THE COMPANY RETAIN PERSONAL INFORMATION?
We willonly retain your personal data for as long as necessary to fulfill the purposeswe collected it for, including for the purposes of satisfying any legal,accounting, or reporting requirements. To determine the appropriateretention period for personal data, we consider the amount, nature, andsensitivity of the personal data, the potential risk of harm from unauthorizeduse and/or disclosure of your personal data, the purposes for which we processyour personal data and whether we can achieve those purposes through othermeans, and the applicable legal requirements. In some circumstances wemay anonymize your personal data (so that it can no longer be associated withyou) for research or statistical purposes in which case we may use thisinformation indefinitely without further notice to you.
TheCompany maintains personal information for the following retentionperiods:
Pleasebe aware that even after your request for a change is processed or followingtermination and/or deactivation of your account, we may, for a time, retainresidual information about you in its backup, audit and/or archival copies ofits database, and reserve the right to access and utilize collected user datain the future. Please be aware that we may still email you non-commercialemails related to your account and your transactions through theServices. In some cases, if you choose not to provide the Company withrequested information, you may not be able to use and/or access all of theServices.
WHEN AND HOW WE CAN SHARE YOUR PERSONAL INFORMATION?
ForCollaboration: Wemay share your information, including when you choose to use certain featuresin the Services that by their nature support sharing with third parties who youchoose. Your name, email address, and any content you choose to share will beshared with such third parties, and such third parties may communicate with youin connection with your use of the Services. Additionally, if yourequest or authorize us to share your information, we will do so in such circumstances.
BusinessTransfers: If we sell or otherwise transfer part or allof the Company or our assets to another organization (e.g., in the course of atransaction such as a merger, acquisition, bankruptcy, dissolution, liquidationor similar proceedings), your information such as name and email address, usercontent and/or any other information collected through the Services may beamong the items sold and/or transferred.
General: Your personal information may beshared if it is made anonymous and aggregated, as in such circumstances theinformation ceases to be personally identifiable data. We do not providepersonal information to companies for the purpose of independent telemarketing,email marketing, or direct mail marketing of any products or services of thosecompanies.
HOW IS YOUR PERSONAL INFORMATION SECURED?
TheCompany has adopted appropriate physical, electronic and managerial proceduresto safeguard and secure the personal information we process. We followgenerally accepted industry standards to protect the personal informationsubmitted to us, both during transmission and once we receive it. We maintainsecurity standards and procedures to help prevent unauthorized access, loss,misuse, alteration, disclosure, or destruction of confidential informationabout you. All sensitive/credit card information you supply is encryptedvia Secure Socket Layer (SSL) technology. We periodically review ourinformation collection, storage and processing practices, including physicalsecurity measures, to guard against unauthorized access to systems. While westrive to secure your information, we cannot warrant or guarantee that thisinformation will be protected under all circumstances, including those beyondour reasonable control. Please do your part to help the Company. You areresponsible for maintaining the secrecy of your account information, and forcontrolling access to emails between you and the Company, at all times. Please limit your access to your computer and/or mobile device and/or browserby signing off after you have finished accessing the Services. Weare not responsible for the functionality, privacy and/or security measures ofany other organization.
WHAT ARE YOUR CHOICES?
Your Information Choices
Werespect your privacy and give you an opportunity to opt out of receivingannouncements of certain information. Although we think that you benefitfrom a more personalized experience when we know more about you and what youlike, you can limit the information you provide to us, and you can limit thecommunications that we send to you. You have the choice to exercise any of thefollowing choices:
You can exercise these choices by contacting us email@example.com.
Your California Privacy Rights
Under California Consumer Privacy Act (“CCPA”), Californiaresidents are entitled to receive the right to access and obtain a copy of yourpersonal information. You may write us and ask for records of any and allpersonal information. The CCPA requires businesses to disclose (1) thecategories 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 personalinformation, (4) the categories of third parties with whom the business sharespersonal information, and (5) the specific pieces of personal information thebusiness has collected about the Individual. To obtain such information fromthe Company, please email your request to firstname.lastname@example.org and we will provide a list of categoriesof personal information disclosed within thirty (30) days of receiving such arequest. This request may be made no more than once per calendaryear. We reserve the right not to respond to requests submitted in waysother than those specified above. The following exceptions may prevail withrespect to fulfillment of data access requests: (a) the Company may not providepersonal data to an Individual, if management determines that we cannotidentify the Individual in our systems because the data we have has beende-identified to the extent that identification is not possible; and/or (b) theCompany may not provide personal data to an Individual, if the Individual isinvolved 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”), wewould like to make sure you are fully aware of all of your data protectionrights. Under the GDPR, you have various rights in relation to your personalinformation, such as the rights of access and receive copies of personalinformation, rectification whereby you may ask us to correct any informationwhich you believe is inaccurate, restriction rights to request restrictions onprocessing of your personal data under certain circumstances, objection ofprocessing certain personal data, portability rights to request that wetransfer data to another organization, and erasure rights to request that theCompany erase certain personal data. Please note that these rights are subjectto certain limitations set forth in applicable law.
To exercise these rights, please contact our dataprotection officer at email@example.com. We will seek to deal with your requestwithout undue delay, and in any event in accordance with the requirements ofapplicable laws. Please note that we may keep a record of your communicationsto help us resolve any issues you raise. If you make a request, we have onemonth to respond to you.
DO WE COLLECT SENSITIVE INFORMATION FROM CHILDREN?
The Company does not knowingly collect personallyidentifiable information from children under the age of thirteen (13). If welearn that we have collected personal information from a child under agethirteen (13), we will delete such information as quickly as possible. If youbelieve that a child under the age of thirteen (13) may have provided uspersonal information, please contact us at firstname.lastname@example.org. By using the Services, you represent thatyou are at least eighteen (18) years old and understand that you must be atleast eighteen (18) years old in order to create an account and/or purchase thegoods 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 ORCOMPLAINTS
If you have any questions, comments or concerns, pleasecontact email@example.com