Last revised: August 30, 2023
This privacy policy (the “Privacy Policy”) describes our policies and procedures on the collection, use, and disclosure of any personal information that Disque Foundation Ltd, a Domestic Nonprofit Corporation formed in the State of Indiana in the United States of America (“us,” “we,” “our” or the “Company”) may obtain when you visit us, use our services, or access the features on disquefoundation.org (the “Website”).
For the Purposes of this Privacy Policy, “You” or “Your” means the individual accessing or using the Service, or the Company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. In all cases described in this Privacy Policy, we will process your personal data as a data controller.
Your access to and use of the Website is conditional upon your acceptance of and compliance with this Privacy Policy. This Privacy Policy also governs the use of Personal Information we obtain from you from any third party site or application where we post content or invite your feedback or participation, including, but not limited to, Twitter, Facebook, and LinkedIn. This Privacy Policy applies to everyone, including, but not limited to: visitors, users, and others, who wish to access or use the Website. Please take a moment to read this Privacy Policy carefully.
By accessing or using the Website, you agree to be bound by this Privacy Policy. If you disagree with any part of the Privacy Policy, then you do not have our permission to access or use the Website.
I. Concerning the information we collect:
We may collect and store any and all information that you enter on this Website. This Privacy Policy is intended to inform you how we gather, define, and use information that could identify you, including, but not limited, to items such as your first and last name, email address, address, phone number, other contact details, online identifiers or other information that you provide to us when using our websites or when relying on our services.
When you visit our Website or use our Service, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area (EEA), this information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g., country or city-level location), and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked, or Service, including content accessed. Collecting this information enables us to better understand the visitors who come to our Website or use our Service, where they come from, and what content and functionality are of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website and/or Service to our visitors and users.
If you are a visitor or user from the EEA, our legal basis for collecting and processing your Personal Information will depend on the personal information concerned and the specific context in which we collect it. This legal basis may include, but is not limited to:
- The processing is necessary to perform our contractual obligations, such as to provide you with our services;
- The user giving prior consent, which may be withdrawn at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time) by contacting us at the email provided under Questions at the bottom of this Privacy Policy;
- The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
- The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing our services, marketing new features or products that may be of interest, and promoting safety and security as described above.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at the email provided under Questions at the bottom of this Privacy Policy.
The following information is also required to be collected to perform a contract: (i) Name, (ii) Postal/Address, (iii) Billing Address, (iv) Email Address, and (v) Products/ Services Purchased, Obtained or Considered. It is also necessary to collect your Billing Address for compliance with any associated legal obligation(s) and your Email Address in order to take steps that you requested prior to entering into a contract. We also collect the types of Products or Services Purchased, Obtained or Considered by the user in order to fulfill requests prior to entering into a contract.
The charts below provide additional details about collection and storage of your information for the following: (i) Identifying Information, (ii) Characteristics of Protected Classifications, (iii) Commercial Information, and (iv) Internet or Other Electronic Activity:
| Identifying Information | |
| Type of Information | What we use this information to assist with |
| Name |
|
| Postal/ Address |
|
| Billing Address |
|
| Phone number |
|
| IP Address |
|
| Email Address |
|
| Device Identifier |
|
| Characteristics of Protected Classifications | |
| Type of Characteristic | What we use this information to assist with |
| Age |
|
| Sex | |
| Commercial Information | |
| Type of Information | What we use this information to assist with |
| Products/ Services Purchased, Obtained or Considered |
|
| Purchasing or Consuming Histories or Tendencies |
|
| Internet or Other Electronic Activity | |
| Type of Activity | What we use this information to assist with |
| Browsing Information |
|
| Search History |
|
| Information Regarding Your Interaction with Our Website |
|
| Geolocation Information |
|
In each of the instances mentioned in the charts above, the user’s information collected has been submitted by the consumer and the user’s submission of this information is consent to the collection and processing of their information; provided that the user’s Name can also be obtained through social networks and surveys, and the user’s IP address and Device Identifier can be obtained through tracking pixels. Commercial Information and Internet or Other Electronic Activity also collects information through tracking pixels. With the exception of the user’s Search History and Products/ Services Purchased, Obtained or Considered, all other Commercial Information and Internet or Other Electronic Activity may also collect information through the observation and recording of activities by the business, such as through the use of cookies.
If you have any questions or would like further information concerning the legal basis on which we collect and use your Personal Information, please contact us by email (see Questions at the bottom of this Privacy Policy).
II. With whom we share your personal information
Your personal information will be used in connection with our Website to send you communications about new services, features, or enhancements that may be of interest to you and to handle your customer service questions or issues. We may share your personal information with our affiliates that provide services on our behalf or that we engage for the purpose of processing information on our and your behalf. Additionally, we may partner with other companies to process, analyze, and/or store data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures. We will also share the personal information we collect from you under the following circumstances:
- Protection of rights. We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the Terms and Conditions or any other agreement, understanding or arrangement between you and the Website, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Website, or (iv) such action is appropriate to protect the rights, property or safety of the Company, its employees, its independent contracts, users of the Website, or others.
- Asset transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of the Company’s assets, user information, including personal information collected from you through your use of the Website, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you through email and/or a prominent notice on the Apps and/or Website.
Your information is shared with the following third parties to (i) manage our interactions with you, (ii) process transactions; and (iii) analyze your interactions with us or our website:
- CUSTOMER MANAGEMENT SYSTEMS
- DATA ANALYTICS PROVIDERS
- DATA LINKING PLATFORMS
- EMAIL MARKETING VENDORS
- EMAIL SERVICE PROVIDERS
Your information is shared with the following third parties to market to you via email:
- CUSTOMER MANAGEMENT SYSTEMS
- DATA ANALYTICS PROVIDERS
- EMAIL MARKETING VENDORS
We also use:
- CUSTOMER MANAGEMENT SYSTEMS to enforce our Terms and Conditions for Services.
- FINANCIAL TRANSACTION PROVIDERS to process transactions
- SOCIAL NETWORKS to manage our interactions with you and analyze your interactions with us or our Website.
- SHIPPING COMPANIES to process transactions and deliver products and services.
How we protect your personal information
We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use, and modification. We use robust security measures to protect data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of data. When the Services are accessed using the internet, Secure Socket Layer (“SSL”) technology protects your Information, using both server authentication and data encryption. These technologies help ensure that your Information is safe, secure, and only available to you and to whom you have granted access. We have implemented the following measures to protect and safeguard your personal information:
- Using SSL or other secure connection technologies when receiving or sending personal information beyond internal networks;
- Performing regular risk assessments;
- Screening all employees and independent contractors with access to personal information;
- Training our employees and independent contractors;
- Requiring our employees and independent contractors to sign confidentiality agreements;
- Performing regular due diligence of vendors.
Sale of your information
We do not sell your personal information.
Cookies
Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. Cookies are widely used to make websites work, or work more efficiently, as well as to provide reporting information and assist with service or advertising personalization. The files are added once you agree to store cookies on your computer or device, and the cookie helps analyze web traffic or lets you know when you visit a particular site. The Website can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.
This Website collects cookies and may use cookies for reasons including, but not limited to:
- Analyze our web traffic using an analytics package;
- Identify if you are signed in to the Website;
- Test content on the Website;
- Store information about your preferences;
- Recognize when you return to the Website.
Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. Cookies do not allow us access to your computer or any information about you, other than the data you choose to share with us. You can accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This setting may prevent you from taking full advantage of the Website. If you view our Website without changing your cookie settings, you are indicating your consent to receive all cookies (that are not related to third party advertisers and analytics providers) from the Website. For more information on managing cookies operated by third party advertisers and analytics providers, please see the Analytics Program section below.
Children’s Privacy
This Website is intended for use by a general audience. We do not knowingly collect or solicit personal data from anyone under the age of 16. We strongly believe in protecting the privacy of children. Any use or access by anyone under the age of 16 is prohibited, and certain regions and content offered through our Website may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect or maintain Personal Data (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information”) on our Website from persons under 16 years of age, and no part of our Website is directed to persons under 16 years of age. If you are under 16 years of age, then please do not use or access this Website at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 16 years of age that has been collected on our Website without verified parental consent upon learning of the existence of such Personal Data.
If you wish to submit a privacy request as a minor or on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative). Please contact us at the email provided under Questions at the bottom of this Privacy Policy. We may not be able to modify or delete your information in all circumstances
Analytics Programs
We use data for analytics and measurement to understand how our services are used. We use a variety of tools to do this, such as Google Analytics, Microsoft Clarity, VWO, and may use other similar sites or services now and in the future (collectively, “Analytics Programs”). These Analytics Programs will track and analyze traffic on the Website, and to collect information about you and your behaviors. These companies use cookies and similar technologies to collect and analyze information about use of the Website and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. These Analytics Programs will automatically track your computer’s IP address. That information will be transmitted to and stored by the applicable Analytics Programs. This information will be used for the purpose of evaluating consumer use of the Website, compiling reports on Website’ activity for our use, and providing other services relating to the Website activity and usage. These technologies may use information such as cookies, scripting language or clear gifs to measure the effectiveness of their advertisements and to personalize the content you see.
These Analytics Programs may also transfer this information to third parties where required to do so by law, or where such third parties process the information on its behalf. These third parties may view, edit, or set their own cookies. They may also collect non-personal and personal information concerning your online activities over time and across different websites. The information they may collect includes the other sites you have visited or applications that you have downloaded to your mobile device, and other information about you or your device in order to help analyze and serve targeted advertising on the Website and elsewhere.
This Website uses Google Analytics.. The use of cookies by Google Analytics is covered by Google’s privacy policy. You can learn more about Google’s practices at https://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the Website.
Data Retention
We keep your personal information for no longer than necessary for the purposes for which the personal information is collected and processed. The length of time we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights. We will retain your personal information in accordance with our record retention policy.
Direct Marketing
“Direct marketing” is the act of selling products or services directly to consumers rather than through retailers. We use the information that we collect about you for direct marketing purposes. However, you may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. You may, at any time, request that we cease to use your information for direct marketing purposes by contacting us at the email provided below under Questions at the bottom of this Privacy Policy.
Profiling
“Profiling” is a form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person. We use the information that we collect about you for Profiling. We use the logic below to conduct Profiling:
We use age and gender information to create persona categories that are used to more effectively direct marketing materials.
Your Data Protection Rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us by at the email provided below under Questions at the bottom of this Privacy Policy. Note that if you submit a request to delete your personal information, this may prohibit you from using the Website and/or Service.
- Additionally, if you are a resident of the European Union (EU), you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request the portability of your personal information. Again, you can exercise these rights by contacting us at the email provided below under Questions at the bottom of this Privacy Policy. Note that if you submit such a request, this may prohibit you from using the Website and/or Service.
- You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), please contact us at the email provided below under Questions at the bottom of this Privacy Policy. Note that if you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Service you have requested or received from us.
- Similarly, if we have collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
By visiting this website and communicating electronically with us, you consent to the transfer and processing of your data as set out in this Privacy Policy in the United States subject to the laws of the United States. If you do not consent to having your information used in accordance with this Privacy Policy, you should not provide your personal information and should disable all cookies and other technologies. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Where we process your personal information solely on behalf of a customer, we may be legally required to forward your request directly to our customer and social media business partners for their review/handling.
You may have certain rights relating to your Personal Information, subject to local consumer privacy and similar laws. In particular, please see the relevant State Laws Supplemental Notice here if you are a resident of California, Colorado, Connecticut, Nevada, Utah, Virginia, or any other state having specific privacy rights.
Complaints
You have the right to lodge a complaint regarding our collection, use and sharing of your personal information by contacting us at the email provided below under Questions at the bottom of this Privacy Policy. You will need to provide us with the following information to verify your identity prior to effectuating your request:
- Name;
- Phone number;
- Email address.
We will respond to most consumer requests within thirty (30) days of receipt. However, some requests may take longer. We will notify you in writing if we need more time to respond. We have the ability to deny your request(s) if certain exceptions in the law apply. If we do deny your request, we will provide you with the reasons for such denial. For any complaints that fall within the scope of legislation in the EU, please submit a consumer request to the email provided under Questions at the bottom of this Privacy Policy. Please note, some rights may be limited, and we may need to retain certain Personal Information, as required or permitted by applicable law. You also have the right to lodge a complaint to your local data protection authority.
For any complaints that fall within the scope of Canada, you may also lodge a complaint with the Office of the Privacy Commissioner of Canada by filling out this form or calling 1-800-282-1376.
For any complaints that fall within the scope of Australian legislation, any such complaints must first be addressed to us in writing as required by Australia Privacy Act 1988 S 40(1A).If you are not satisfied with our response to your complaint, you may then lodge a complaint with the Office of the Australian Information Commissioner by following the steps on this page.
Accountability
You may lodge a complaint with us by contacting the email provided under Questions at the bottom of this Privacy Policy for any concerns regarding our privacy practices and procedures.
Location of Data Processing
All data processing activities undertaken by us take place in the United States of America.
Do Not Track
Our Website does not respond to Do Not Track (“DNT”) signals. DNT is a preference you can set on your browser to inform websites that you do not want to be tracked. Some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Transferring Data
In order to provide the Services to you, we must transfer your data to the United States and process it there. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. When such transfer happens, we ensure that it takes place in accordance with this Privacy Policy.
Changes to Privacy Policy
You acknowledge that this Privacy Policy is part of the Terms and Conditions for your use of the Website, and you agree that using the Website signifies your assent to this Privacy Policy. We reserve the right to amend this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. As we may make changes from time to time without notifying you, we suggest that you periodically consult this Policy. Your continued use of the Website after the effective date of any modification to the Policy will be deemed to be your agreement to the changed terms. The revised Privacy Policy supersedes all previous Privacy Policies.
Links to Other Sites
Our Website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Questions
If you have any questions about this Privacy Policy, please contact us at info@disquefoundation.org.
Additional U.S. State Privacy Disclosure
Updated November 15, 2023
These Additional U.S. State Privacy Disclosures supplement the above information by providing additional information about our personal data processing practices relating to individual residents of the States of California, Colorado, Connecticut, Nevada, Utah, and Virginia. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these Disclosures.
Additional Personal Data Disclosures
Sensitive Information
The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):
- Credit/debit card number plus expiration date and security code (CVV), and financial account number and routing number; and
- Username and password
We use this sensitive information for the purposes set forth in the “Concerning the information we collect” section of our Privacy Policy, to register you for training courses and to comply with legal and regulatory requirements.
We do not sell your sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.
Deidentified Information
We may at times receive or process personal data to create de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.
Your Privacy Choices
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
- The Right to Know. The right to confirm whether we are processing your personal data and, under some state laws, to obtain certain personalized details about the personal data we have collected about you, including:
- The categories of personal data collected;
- The categories of sources of the personal data;
- The purposes for which the personal data were collected;
- The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom the personal data were disclosed;
- The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
- The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold.
- The Right to Access & Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- The Right to Correction. The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- The Right to Deletion. The right to have us delete the personal data we maintain about you.
- The Right to Opt-Out of Sales or Sharing of Personal Data. The right to direct us not to “sell” your personal data to third parties for monetary or other valuable consideration, or “share” your personal data to third parties for cross-context behavioral advertising purposes and targeted advertising purposes. Good news about that – we don’t sell personal data or share it for targeted advertising purposes. Cross-context behavioral advertising means in essence that we would share your information with a third party which would then use that information to advertise in places unrelated to 360training. We don’t do that.
- “Shine the Light.” California residents that have an established business relationship with us have rights to know how their personal data is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, or the right to opt out of such practices (Civ. Code §1798.83).
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise any of the rights described in this “Additional U.S. State Privacy Disclosure”.
Submitting Privacy Rights Requests
To submit a request to exercise one of the privacy rights identified above, please email us at the email provided under Questions at the bottom of this Privacy Policy.
Before processing your request, we may need you to log in to your account with us so we can verify your identity. If you can’t log in or don’t have an account, we may not be able to link you to any personal data of yours on our systems, but we’ll do our best. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. We will only use personal data provided in connection with your request to review and comply with the request.
We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Policy.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. The authorized agent can submit a request on your behalf to the email provided under Questions at the bottom of this Privacy Policy along with a statement signed by you certifying that the agent is authorized to act on your behalf. To verify the request and your identity, you will need to provide your name, phone number, and email address when submitting your request.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted to the email provided under Questions at the bottom of this Privacy Policy.
Minors
See the Children’s Privacy section of the Privacy Policy.
California-Specific Disclosures
The following disclosures only apply to residents of the State of California.
The California Consumer Privacy Act of 2018 (the “CCPA”) is a California law that gives California residents (“You”, or “Your”), the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them. Pursuant to the CCPA, effective January 1, 2020, consumers whose personal information have been collected by us, have certain rights, including:
The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information;
- The right to know the business purposes for sharing personal information;
- The right to know the categories of third parties with whom we’ve shared personal information;
- The right to access the specific pieces of personal information we’ve collected; and
- The right to delete your information.
- California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.
YOUR PERSONAL INFORMATION UNDER THE CCPA:
| CATEGORIES OF PERSONAL INFORMATION UNDER THE CCPA | WHAT WE COLLECT | WHY WE COLLECT THAT INFORMATION |
| Identifiers | We may collect your:
|
We collect this information in order to provide services, maintain or service accounts, provide customer service, and for commercial purposes. |
| Personal information described in California Civil Code section 1798.80 | We may collect your:
|
We collect this information in order to provide services, maintain or service accounts, provide customer service, and for commercial purposes. |
| Protected classifications under California or federal law | We do not collect this information. | Not applicable. |
| Commercial information | We do not collect this information. | Not applicable. |
| Biometric information | We do not collect this information. | Not applicable. |
| Internet or other electronic network activity information (browsing history, search history, and information regarding a Consumer’s interaction with an internet website, application, or advertisement) | We may collect your:
|
We collect this information in order to provide services, maintain or service accounts, provide customer service, and for commercial purposes. |
| Geolocation data | We may collect this information. | We collect this information to better personalize your content. |
| Audio, electronic, visual, thermal, olfactory, or similar information | We do not collect this information. | Not applicable. |
| Professional or employment-related information | We may collect this information. | We collect this information to better personalize your content. |
| Education information (information that is not publicly available) | We may collect this information. | We collect this information to better personalize your content. |
| Inferences drawn from any of the above to create a profile about a Consumer | We may collect this information. | We collect this information to personalize your browsing experience and provide services. |
California Categories of Personal Data
California law requires that we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data, sources and purposes described in the “Concerning the information we collect” section of our Privacy Policy. Please note that our Website and Service do not collect all the types of personal data listed below.
- Identifiers, including account registration and profile information, information related to your feedback, inquiries, and communications, credit and identity information relating to data used to identify you, full name, IP address, and government identification number (including Social Security number, passport number and driver’s license number).
- Customer Records, including account registration and profile information, security/authentication information, and payment information.
- Protected Classification Characteristics, including age, date of birth, and gender.
- Commercial Information, including account registration and profile information relating to your purchases, profile information relating to your transactions, preferences, and interests, and feedback information.
- Internet/Network Information, including information about how you access and use the services, log data, and analytics data.
- Geolocation Data, including general geographic location or more precise location when permitted by law.
- Sensory Information, including, where permitted by law, recordings of phone calls between us and individuals and image and video recordings of visitors to our offices or events.
- Profession/Employment Information, including the business or organization you represent, your title with that business or organization and information relating to your role with the business or organization.
- Sensitive Information, including Social Security number, driver’s license number, passport number, credit/debit card number plus expiration date and security code (CVV), financial account number and routing number, username and password, and precise geolocation.
- Other Personal Data, including any information you provide us in connection with signing up for newsletters, email communications, and surveys, personal data you permit us to see when interacting with us through social media, and personal data you provide us in relation to a question, request, inquiry, survey, contest, or promotion.
- Inferences, including our predictions about interests and preferences.
We collect this data from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you use our Service, or from third parties that you permit to share information with us. Please see the “Concerning the information we collect” section of our Privacy Policy for more information about the sources of personal data we collect.
Personal Information Disclosed for a Business Purpose To Third Parties
While we don’t “share” your personal information for cross-context behavioral advertising, we may share your personal information for certain business purposes or at your direction. For example, we share your personal information with our data hosting and storage providers and other service providers. We enter into agreements with those service providers which specify that they can only use your information for the Website and/or Service purposes specified here:
| PARTNER | PURPOSE |
| Advertising Partners | Advertising |
| Cloud Storage Providers | Data storage |
| Content Providers | Content delivery
Content streaming Content storage Content review |
| Customer Support Providers | Customer support
Account verification Password recovery |
| Data Analytics Providers | Data analytics |
| Data Management Providers | Machine learning and algorithms |
| Data Solution Providers | Research |
| State Regulatory Agencies | Notice of Course Completion |
| Logistics Providers | Shipping products |
| Marketing Partners | Email marketing |
| Measurement Partners | Mobile measurement
Pixel tracking Targeting |
| Payment Providers | Payment services |
We may also share with third parties that provide services to us or perform business purposes for us aggregated, non-personally identifiable, or de-identified information.
Retention of Personal Data
See the Data Retention section of the Privacy Policy.
“Shine the Light” Disclosures
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. If you would like to (i) opt out of this type of sharing or (ii) learn how your Personally Identifiable Information (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please email us at the email provided under Questions at the bottom of this Privacy Policy.
Consumer Rights Metrics
The following metrics will be compiled for each calendar year. By July 1 of each calendar year, we will release the metrics for the previous calendar year with our Privacy Policy. You can find data that reflects the California consumer rights requests that we have processed in the 2022 calendar year (January 2022 – December 2022) below.
| Received | Complied | Denied* | Days to Complete | |
| CCPA Right to Know | 0 | n/a | n/a | n/a |
| CCPA Right to Delete | 0 | n/a | n/a | n/a |
| Do Not Sell or Share** | 0 | n/a | n/a | n/a |
* Denied means that the request was not verifiable or was denied on other grounds.
** We don’t sell your data, so we don’t process, or collect metrics on, opt-out requests for the sale or sharing (as defined by CCPA) of consumer data.