Privacy Statement

We may collect personal information from the following groups of data subjects: visitors to, and users of, our online and mobile resources; our customers; current members of our workforce and those who apply for posted jobs; and third party vendors and business partners.

Personal information generally means information that can be used to identify you or that can be easily linked to you (for example, your name, address, telephone number, email address, social security number and date of birth). The privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of the consumers or data subjects they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act (“CCPA”) or or other U.S. state-level data privacy laws, or the European General Data Protection Regulation (“GDPR”), our use of the phrase “personal information” includes the unique elements required by such laws.

The categories of information we collect from each of these groups, and the ways in which we use it, differs. As you may have noticed, it’s possible that the same person could fall into more than one group. Most of this statement addresses our processing and sharing of personal information collected from visitors to and users of our online and mobile resources and our customers.

Nonetheless, we collect and retain the types of professional or employment related personal information you would expect an employer to have about its existing and former workforce and new job applicants. We provide legally required notices of collection, and describe our use and sharing of the personal information of our workforce and applicants in greater detail in confidential internal human resource manuals and documents accessible to members of our workforce, or by publication on the proprietary workforce/applicant portals and apps we operate. In some cases, such portals and apps may be operated by third parties who transfer the personal information to us. In those situations, the legal responsibility to provide notice usually rests with the third party, not us.

In addition, like all corporate enterprises, we buy goods and services, lease equipment and office space and attend industry events. In doing so, we interact with many existing and potential vendors and business partners from whom we necessarily collect certain personal information in connection with our contractual and business relationships. As with our customers, this information is typically limited to minimum business contact information. We use and share personal information collected from our vendors and business partners to manage, administer and perform under our contracts with them, or share information about our products. We describe our use of vendor and business partner personal information in greater detail in our confidential contracts with those parties or on the internal vendor management portals we operate.

There are two types of information that we obtain from you online and then store and use: (i) non-personal information that’s collected automatically from each visitor, such as your device operating system; and (ii) personal information that you voluntarily provide to us or that is collected automatically.

By using our online and mobile resources or purchasing our products or services, you are signifying to us that you agree with this section of our privacy statement and that we may use and disclose your information as described.

Voluntarily Submitted Information.

If you participate in certain activities via our online and mobile resources, you may be asked to provide us with information about yourself. The types of personal information we collect in those situations includes identifiers (such as your name, email address, physical address, and phone number), professional information (such as the business you are in), and financial account information (such as your credit card information). We do not sell, rent, or trade voluntarily submitted personal information with third parties.

If you don’t want us to collect this type of personal information, please don’t provide it. This means you shouldn’t participate in the activities on our online and mobile resources that request or require it and you may want to communicate with us by phone or regular mail instead. Participation is strictly your choice. Not participating may limit your ability to take full advantage of the online and mobile resources, but it will not affect your ability to access certain information available to the general public on the online and mobile resources.

Some of the ways you voluntarily give us your personal information and how we use it:

Emails and Online Forms – When you send us an email or fill out an online form, such as to contact us, your email address and any other personal information (e.g., home address or phone number) that may be in the content of your message or attached to it, are retained by us and used to respond back directly to you and to process your request. Depending on the personal information provided, communications from us may be in the form of emails, telephone calls, and/or text messages. We may also send you information about any of our products or services we think may be of interest to you.

Registering for an Account – When you register for an account or you register your child for a sub-account, you submit personal information to us such as your name and email address (or your child’s name and email address) which we then retain. We use that information to create and manage your account and in some cases establish a password and profile to communicate with you and any sub-accounts you created via email.

Registering for Events – When you register for events, conferences or programs we ourselves may host (rather than outsource to a third party event manager with its own privacy policies), you will be submitting the types of identifiers described above. If the event requires a fee, we may also ask you to submit credit card or other financial information. We use this information to register you for the event and send you communications regarding the event.

Becoming a Subscriber to Our Service – We use any information provided from our customers to perform our contractual obligations and provide the products and services purchased to them, to manage their accounts and communicate with them.

Social Media and Community Features – Some of our online and mobile resources may offer social media-like community features letting users post messages and comments, and/or upload an image or other files and materials. If you choose to make use of these features, the information you post, including your screen name and any other personal information, will be in the public domain and not covered/protected by this statement.

Automatically Collected Information.

When you visit our online and mobile resources, basic information is passively collected through your web browser via use of tracking technologies, such as a “cookie” which is a small text file that is downloaded onto your computer or mobile device when you access the online and mobile resources. It allows us to recognize your computer or mobile device and store some information about your preferences or past actions. Additional information can be found in our Cookie Policy. You can learn more about cookies and tracking technologies in general here.

We allow third party vendors to use cookies or similar technologies to collect information about your browsing activities over time following your use of the site. For example, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how you use the online and mobile resources and enhance your experience when you visit the online and mobile resources. For more information on how Google uses this data, go to https://policies.google.com/technologies/partner-sites. You can learn more about how to opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout. Our use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use Requirements.

The internet activity information collected through cookies and other similar means includes such things as: the domain name and IP address from which you accessed our online and mobile resources; the type of browser and operating system you use; the date and time and length of your visit; the specific page visited, graphics viewed and any documents downloaded; the specific links to other sites you accessed from our online and mobile resources; and the specific links from other sites you used to access our online and mobile resources.

Additionally, if you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us uniquely identifiable mobile device information which allows us to then collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone vendors also operate systems that pinpoint the physical location of devices and we may receive this information as well if location services are enabled on your device. If you do not want us to collect and use geolocation data, disable location services through your device settings.

Regardless, we use both automatically collected information and mobile device information to compile generic reports about popular pages on our online and mobile resources, and to see how our customers and followers are accessing our online and mobile resources. We then use that data to administer the online and mobile resources and make them better, make your activities more convenient and efficient and to enhance the functionality of our online and mobile resources, such as by remembering certain of your information in order to save you time.

We use and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described above in accordance with our internal data retention procedures. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is an applicable legal obligation; or (iii) whether retention is advisable to enforce our agreements, satisfy applicable statutes of limitations, resolve disputes, or manage litigation or regulatory investigations.

User Beware: External Sites, Apps, Links and Social Media.

We maintain a presence on one or more external social media platforms such as Twitter, Facebook, YouTube and LinkedIn. We may further allow features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Similarly, our online and mobile resources may contain links to other websites or apps controlled by third parties.

We are not responsible for either the content on, or the privacy practices of, social media platforms, or any third party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore have their own privacy policies and terms of use. If you have questions about how those apps, sites and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide.

We use non-personal information to administer our online and mobile resources, make them better, and to make business decisions about what programs our customers might like.

We use voluntarily provided personal information for our legitimate interests, including to respond to your inquiries and provide you with the services you have requested, amongst other uses as further described below. We do not sell or rent your personal information to third party data vendors or marketing companies. As you might expect, we disclose your information when required by law. We may use your personal information when we have your consent to do so, where required or permitted under applicable law.

Legally Compelled Disclosures.

We may disclose your information, including personal information, to government authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including but not limited to responding to court orders and subpoenas.

To Prevent Harm.

We may disclose your information, including personal information, when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the online and mobile resources, or anyone else that could be harmed by such activities.

Business Transfer.

If we or any of our affiliates, or substantially all of its or their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be one of the transferred assets.

Vendors and Business Partners.

We may share your information, including personal information, with our vendors and other third parties with whom we have a contractual relationship. We may also share your information, including personal information, with vendors who provide third party software services that you have chosen to assist you with your sales funnels. We do our best to disclose only the information each of those parties need.

We have adopted standards for those vendors and business partners who receive personal information from us. We attempt to bind such vendors and business partners to those standards via written contracts. We further attempt to contractually restrict what our vendors and business partners can do with the personal information we provide to them such that it is used only to the extent necessary to carry out the business purpose for which it was provided; is not disclosed to anyone else without our consent or under our instruction; remains, as between us and the applicable vendor or business partner, our property; and is not transferred out of the United States without our consent.

Please note, however, that we cannot guarantee that all of our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.