Updated: November 23rd, 2015.
We self-certify compliance with the following: the U.S. – E.U. Safe Harbor Framework and U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. We adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor.
Our privacy practices described in this Policy comply with the APEC Cross Border Privacy Rules System.
Please read the information below:
- Information we collect about you
- Where we store data
- How we use your information
- Disclosure of your information
- Updating or correcting your personally identifiable information
- Canceling your account or deleting your personally identifiable information
- Choices regarding control of your personally identifiable information
- Information related to data collected through the Service Management University platform service
- Data Security
- Mobile Analytics
- Links to third party web sites and advertisers
- Notice to California residents
- Communities, forums, chat rooms, and message boards
- Social Media features
- Gift Certificates
- How do you contact us with questions?
1. INFORMATION WE COLLECT ABOUT YOU
We collect several types of information about visitors and/or users of our Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Websites or App.
(a) Personally Identifiable Information. ‘Personally Identifiable Information’ refers to information by which you may be personally identified, such as your name, email address, or school. We will collect and process such data about you when you register for a Service/create an account, subscribe to a newsletter, submit feedback, enter a contest, fill out a survey, or send us a communication. When ordering products or services on the Websites or App, you may also be asked to provide a credit card number and other payment-related information. You may also provide information to be published or displayed (“posted”) on public areas of the Websites (such as blogs, forums, message boards, and the like), or transmitted to other users of the Websites using ‘sharing’ features (collectively, “User Contributions”). Your User Contributions are posted and transmitted to others at your own risk. We cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
We may also collect your Internet Protocol (‘IP’) address. We use your IP address to diagnose problems with our servers, software, to administer our Services and to gather demographic information.
We do not collect more Personally Identifiable Information than is reasonably necessary to participate in an activity on the Websites. If you are a school and you use our service within the United States for children under the age of 13, you are responsible for obtaining consent from the parents/legal guardians of each child you wish to allow to participate in using any of our Services. A child using our Services will be able to participate in certain activities such as taking online educational and informational courses.
(b) Non-Personally Identifiable Information. We may collect, or our third party ad server and/or content server may collect, certain Non-Personally Identifiable Information, that does not by itself identify a specific individual. Such information tells us about your equipment, browsing actions, the resources that you access and use through the Services, your operating system and browser type. Our third party ad servers will provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon at our Websites. The information that we collect automatically is ‘statistical’ in nature. It helps us to deliver a better and more personalized service to users, by enabling us to estimate usage patterns, customize our Services according to your individual preferences, and speed up your searches.
(c) Device Information. When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best application version to provide you with. We do not ask you for, access or track any location based information from your mobile device at any time while downloading or using our App or Services.
2. WHERE WE STORE DATA
3. HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
- To ensure that content from our Services is presented in the most effective manner for you and for your computer or mobile device
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
- To carry out our obligations arising from any contracts entered into between you and us, including for billing and collection
- If you pay for Services using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company
- To allow you to participate in interactive features of our Services, when you choose to do so
- To notify you about changes to our Services
- In any other way we may describe when you provide the information
If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
If you use the Contact Us form on our site, we will respond to your inquiry and delete the information provided after your request has been fulfilled.
4. DISCLOSURE OF YOUR INFORMATION
(a) We provide some of our Services through contractual arrangements with service providers and other third parties. We and our service partners use your Personally Identifiable Information to operate our Websites and to deliver Services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Websites; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us deliver the services.
(c) In the event that we decide to sell all or part of its stock or assets or enter into a merger, we reserve the right to include Personally Identifiable Information and Non-Personally Identifiable Information among the assets transferred to the acquiring or surviving company.
(d) We may provide Non-Personally Identifiable Information about our customers’ sales, traffic patterns, and related Website information to third party advertisers.
(e) Parents are able to consent to the use of their child’s Personally Identifiable Information without having to consent to the Website’s disclosure of the child’s Personally Identifiable Information to third parties, as we do not share Personally Identifiable Information of children under the age of 13 with any third parties (other than those service partners who help us provide our service to you).
If you have any inquiries regarding our privacy practices, please contact us directly at firstname.lastname@example.org.
5. UPDATING OR CORRECTING YOUR PERSONALLY IDENTIFYING INFORMATION
You may change any of your or your child’s Personally Identifiable Information online by logging into ‘My Account’ in accordance with instructions posted elsewhere on our Websites.
You may also access, request deletion, and correct yours or your child’s personal information and privacy preferences by emailing us email@example.com.
Please include your or your child’s name, address, and e-mail address when you contact us. We encourage you to promptly update your or your child’s Personally Identifiable Information if it changes. You may ask to have the information on yours or your child’s account deleted or removed and request that we no longer have contact with your child; however, because we keep track of past transactions for as long as is reasonably necessary, you cannot delete information associated with past transactions on this Website. In addition, it may be impossible to completely delete your information without some residual information because of backups.
6. CANCELING YOUR ACCOUNT OR DELETING PERSONALLY IDENTIFIABLE INFORMATION
If you would like to cancel your membership, log in to your account and go to My Account, Account + Billing. You can also email us with your request at firstname.lastname@example.org.
We will retain your or your child’s information for as long as your account is active or as needed to provide you Services. If you wish to cancel your or your child’s account or request that we no longer use your information to provide you Services email us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will respond to your request to access within 30 days.
7. CHOICES REGARDING CONTROL OF YOUR PERSONALLY IDENTIFIABLE INFORMATION
You can access some of the information that we collect about you or your child. For example, by logging in to your account, you can access information regarding recent orders from the Websites; Personally Identifiable Information; communication preferences; and payment settings.
With respect to your communications preferences, you can unsubscribe from newsletters by following the instructions included in the newsletter you receive or you can log into your account and update your newsletter and email subscription options. If your e-mail address has changed and you would like to continue to receive newsletters, you will need to access your account and update your e-mail address information in your account and sign-up again for the newsletter. Occasionally we may send out e-mails concerning website disruptions.
If you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only one of our authorized websites (or agents working on behalf of us and under confidentiality agreements) will send you these direct mailings, and only if you did not later ‘opt-out’ of such offers.
We do not send unsolicited commercial e-mails (“spam”). We offer commercial e-mail recipients the opportunity to opt-out of further communications in every e-mail. Please note that we may not include the opt-out information in non-commercial Service e-mails (i.e., e-mails concerning your order, the Website Terms of Service, etc.).
You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Websites may not work properly in your case.
8. INFORMATION RELATED TO DATA COLLECTED THROUGH THE SERVICE MANAGEMENT UNIVERSITY PLATFORM SERVICE
For certain services we collect information under the direction of its clients (e.g., an entity that subscribes to the Services for use by the entity’s personnel). In this respect, we act as a data processor and have no direct relationship with the individuals whose Personally Identifiable Information it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the relevant Service Management University client (the data controller). If the client makes a request to us to remove the data, we will respond to their request within 30 days.
We will retain Personally Identifiable Information we process on behalf of our clients for as long as needed to provide our services to our client. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. DATA SECURITY
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology.
To make online purchases you must use an SSL-enabled browser in order to protect the confidentiality of your personal and credit card information while it is transmitted over the Internet.
Access by you to your account is available through a password and/or unique user name selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone, that you change your password often using a combination of letters and numbers, and that you ensure you use a secure web browser. We cannot be held accountable for activity that results from your own neglect to safeguard the secrecy of your password and user name. If you share a computer with anyone, you should always log out of your account after you are finished, in order to prevent access to your information from subsequent users of that computer.
Please notify us as soon as possible if your user name or password is compromised and email us at firstname.lastname@example.org.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.
In the unlikely event that we believe that the security of your Personally Identifiable Information in our control may have been compromised, we will notify you as promptly as possible under the circumstances. To the extent we have your e-mail address, we may notify you by e-mail and you consent to our use of e-mail as a means of such notification. If you prefer for us to use another method to notify you in this situation, please e-mail us at email@example.com with the alternative contact information you wish to be used.
10. COOKIES AND OTHER TECHNOLOGIES
What is a cookie? A cookie is a small data text file, which a website stores on your computer or mobile device (if your Web browser permits) that can later be retrieved to identify you to us.
Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to our Websites. The cookies make your use of the Websites easier, make the Websites run more smoothly, and save your logged-in state so that you do not have to log in each time that you visit the Websites.
You can disable and/or delete all types of cookies by using your browser settings. Cookies are generally easy to disable and/or delete but how you do so varies from browser to browser. The “help” function within your browser should tell you how to do it. The best way may be to close your browser and then search for “cookie folder” or “cookie manager” or simply “cookie”. Please also visit www.allaboutcookies.org for more information about cookies and how to disable them. If you do disable cookies, our Websites will not recognize you and you may not have access to all portions of the Websites.
What are clear gifs? Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the full-stop or period at the end of this sentence.
What is a Flash cookie? Local storage objects, also known as “Flash cookies”, are similar in function to browser cookies in that they store some information about you or your activities on our Websites. We use Flash cookies in certain situations where we use Flash to provide some content such as video clips or animation. The options within your browser may not prevent the setting of Flash cookies. To manage Flash cookies please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
11. MOBILE ANALYTICS
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the App, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any Personally Identifiable Information you submit within the App.
12. LINKS TO THIRD PARTY WEB SITES AND ADVERTISERS
13. NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA PRIVACY RIGHTS
If you are a California resident and have provided us with Personally Identifiable Information, California law gives you the right to request and receive from us, once per calendar year, information as to how we have shared your Personally Identifiable Information with third parties for their direct marketing purposes If applicable, such information would include a list of names and addresses of all third parties with whom such information was shared during the prior calendar year as well as a list of the categories of Personally Identifiable Information shared. To make such a request, please send an email to firstname.lastname@example.org and include the phrase “California Privacy Request” in the subject line. Your request must also include your name, physical mailing address and email address. We will respond to you within thirty days of receiving such a request.
Note, that we will not share your Personally Identifiable Information with third parties for their marketing purposes without obtaining your prior consent. Moreover, if you have granted us permission, such third parties’ use of your Personally Identifiable Information will be subject to their privacy policies. You should contact those entities directly regarding any communications you may receive from them, including, if you later decide that you no longer want that third party to use your personal information.
If we make material changes to how we use Personal Information collected from children under 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of their child’s Personally Identifiable Information.
15. COMMUNITIES, FORUMS, CHAT ROOMS, AND MESSAGE BOARDS
If you or your child choose to disclose Personally Identifiable Information on communities, message boards, forums, and the like, which may be accessible via the Websites, you should be aware that such information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. To request removal of your personal information from our blog or community forum, contact us at email@example.com You acknowledge and accept that any submissions to chat rooms or other public areas on the Websites are accessible to all third parties. If you do not want yours or your child’s comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for all activity conducted by you via communities, forums, message boards, chat rooms, etc. Please be careful and responsible whenever you are online.
16. SOCIAL MEDIA FEATURES
17. GIFT CERTIFICATES AND PLAYLISTS
If you choose to send a gift certificate or playlist to an individual, we will ask you for the individual’s name and email address. We will automatically send a one-time email to the individual either with notice of their gift certificate along with an activation key or an invitation to visit the Websites. The recipient will be asked to create a user name and password to activate their subscription, and during this process, they will also be asked if they want to receive any newsletters or other emails from us, we store name and email address of the recipient for the sole purpose of sending this one-time email and tracking the success of our referral program. The individual may contact us at firstname.lastname@example.org to request that we remove this information from our database.
18. HOW DO YOU CONTACT US WITH QUESTIONS?