Privacy Policy

Privacy Policy – Effective Starting Date 01/08/2022

• Coverage 

This Privacy Policy is developed in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and covers the information we collect about you when you use our Services, or otherwise interact with us, unless a different policy is displayed. This policy may be updated from time to time, and we will notify you of any material changes by posting the new Privacy Policy and revising the Effective Starting Date. We refer to all our services together with our Website as “Services” in this policy. This policy covers how we collect, use, share, store the information about you and how you can access and control your personal data, and other aspects. The terms mentioned with capital letters are defined within the Terms and Conditions published on the Website if they are not otherwise defined within this policy. 

This policy also explains your choices surrounding how we use information about you, which include how you can object to certain uses of information about you and how you can access and update certain information about you. By accessing and using this Website, you confirm that you have read and fully understood this Privacy Policy, that you agree to the collection and the usage of your own and others’ personal information in accordance with the Privacy Policy and that you have the authority to provide us with all information submitted by you via the Website, including but not limited to personal information of third parties, if the case may be. By registering for or using the Services and accepting the Terms and Conditions you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

Where we provide the Services under contract with a Corporate Client (for example, your employer) that organization controls the information processed by the Services. This policy does not apply to the extent we process personal information in the role of a processor on behalf of Corporate Clients. In such cases another user (such as an administrator) may create an account on your behalf and may provide your personal information (most commonly when your company requests that you use our Services). We collect personal information under the direction of our Clients and often have no direct relationship with the Students – individuals whose personal information we process. If you are an employee of one of our Corporate Clients and would no longer like us to process your information, please contact your employer and us at the contact information provided on the Website.

• Collection

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below. We collect information about you when you input it into the Services or otherwise provide it directly to us. We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. For example, you provide your contact information and, in some cases, billing information, when you register for the Services. You also have the option of adding a display name, profile photo, job title, company, email address and telephone number and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.

We also collect Services usage data in aggregate form (i.e. demographics) to improve our service. When you register to the Services, we may collect information about your industry and your position in the company, to adjust the Services to the needs of your industry and make them more functional for your industry as well as to promote our Services. We also collect certain information about Client’s use of Services (this applies only to account owners and not Teachers) to email to our Clients/Students newsletters, announcements regarding our Services, or marketing material. 

We use marketing automation software to achieve this. If you are a Student and no longer wish to receive such emails you can remove yourself from the recipients list at any time by selecting the “unsubscribe” link provided within the e-mail footer. Occasionally and for a limited amount of time we may use software in order to better understand our Clients’ needs (this applies only to account owners and not Teachers) and to optimize this experience. The software uses cookies and other technologies to collect data on our users’ behavior and their devices, device screen size, device type, browser information, geographic location (country only), preferred language used to display our Website. The software stores this information in a pseudonymized user profile. Neither the software nor we will ever use this information to identify individual users or to match it with further data on an individual user. 

The Services include the products you use, where we collect and store content that you access, post, send, receive and share. This content includes any information about you that you may choose to include. 

Content also includes the files and links you upload to the Services, where and if the case may be. If you use a server or data center version of the Services, we do not host, store, transmit, receive or collect information about you (including your content), except in limited cases, where permitted by your administrator: we collect feedback you provide directly to us through the product and; we collect content using analytics techniques that hash, filter or otherwise scrub the information to exclude information that might identify you or your organization; and we collect clickstream data about how you interact with and use features in the Services. Server and data center administrators can disable our collection of this information from the Services via the administrator settings or prevent this information from being shared with us by blocking transmission at the local network level. 

The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Therefore, we may also acquire additional data through our customer’s support requests to the extent this is required for us to resolve a technical issue or respond to a request or complaint. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue. We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services. Where you give us express permission to do so, we share information with a third party expert for the purpose of responding to support-related requests.

In addition to the data we collect about all users, we also collect data that are required for your contract with us, such as your company affiliation, invoicing data, credit/debit card and also Services usage data that prove that the Services is used in accordance to your subscription terms. We collect payment and billing information when you register for certain paid Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services. We do not store your credit/debit card information in our systems. All credit/debit card transactions are processed using secure encryption – the same level of encryption used by leading banks. Card information is transmitted, stored, and processed securely at gateways on a PCI-compliant network. 

We collect information about you when you use our Services, including browsing our Website and taking certain actions within the Services. We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; the type, size and filenames of attachments you upload to the Services, if the case may be.

We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We may use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services. Server and data center Service administrators can disable collection of this information via the administrator settings or prevent this information from being shared with us by blocking transmission at the local network level.

We use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookies and Tracking Notice, which includes information on how to control or opt out of these cookies and tracking technologies.

We may receive information about you from other Service users, from third-party services, from our related companies, social media platforms, public databases, and from our business and channel partners. We may combine this information with information we collect through other means described above. This helps us to update and improve our records, identify new customers, create more personalized advertising and suggest services that may be of interest to you. 

Other users of our Services may provide information about you when they submit content through the Services. Similarly, an administrator may provide your contact information when they designate you as the billing or technical contact on your company’s account or when they designate you as an administrator. 

We work with a global network of partners who provide consulting, implementation, training and other services around our products. Some of these partners also help us to market and promote our Services, generate leads for us, and resell our Services. We receive information from these partners, such as billing information, billing and technical contact information, company name, what Services you have purchased or may be interested in, evaluation information you have provided, what events you have attended, and what country you are in. 

We may receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services and online advertisements. We may receive information about you from third party providers of business information and publicly available sources (like social media platforms), including physical mail addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses and social media profiles, for the purposes of targeted advertising of products that may interest you, delivering personalized communications, event promotion, and profiling.

• Usage

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate, maintain, and improve the Services. For example, we may use the name and picture you provide in your account to identify you to other Service users, if the case may be. 

We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful. We use information and collective learnings (including feedback) about how people use our Services to troubleshoot, to identify trends, usage, activity patterns, and areas for integration and to improve our Services and to develop new products that benefit our users and the public. 

We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We send you email notifications when you or others interact with you on the Services. Depending on your chosen method of contact, we may send you SMS notifications or call you if you are on-call for incident alerts. 

We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying ads on other companies’ websites and applications. These communications may be informed by audits of interactions (like counting ad impressions), and are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new Services, product offers, promotions, and contests. You can control whether you receive these communications as described below.

We use information about you and your Service use to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activity, including violations of Service policies. Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business. 

We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.

In synthesis, we collect and use your information only where we need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services, where it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests, where you give us consent to do so for a specific purpose or where we need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services. 

• Sharing

We may develop within the e-learning domain some collaboration tools, and we want them to work well for you. This means sharing information through the Services and with certain third parties. We share information we collect about you in the ways discussed below, including in connection with possible business transfers. We are not in the business of selling information about you to advertisers or other third parties. When you use the Services, we may share certain information about you with other Service users.

You can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content based on settings you or your administrator (if applicable) select. Some of the collaboration features of the Services may display some or all of your profile information to other Service users when you share or interact with specific content. For example, when you make a comment, we display your profile picture, name of nickname/initials next to your comments so that other users with access to the page or issue understand who made the comment. Please be aware that some aspects of the Services can be made publicly available, meaning any content posted in that space, including information about you, can be publicly viewed, indexed by, and returned in search results of search engines. You can confirm whether certain Service properties are publicly visible from within the Services or by contacting the relevant administrator.

If you register or access the Services using an email address with a domain that is owned by your employer or organization or associate that email address with your existing account, and such organization wishes to establish an account or site, certain information about you including your name, profile picture, contact info, content and past use of your account may become accessible to that organization’s administrator and other Service users sharing the same domain. If you are an administrator for a particular site or group of users within the Services, we may share your contact information with current or past Services users, for the purpose of facilitating Services-related requests. 

Our Website may offer publicly accessible blogs, forums, issue trackers, and wikis. You should be aware that any information you provide on these Website pages – including profile information associated with the account you use to post the information – may be read, collected, and used by any member of the public who accesses the Website. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.

• Sharing with Third Parties

We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.

We work with third-party service providers to provide the Website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including appropriate security and confidentiality procedures designed to protect your information.

We work with third parties who provide consulting, sales, support, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.

You, your administrator or other Services’ users may choose to add new functionality or change the behavior of the Services by installing third party apps/add-ins within the Services. Doing so may give third-party apps/add-ins access to your account and information about you like your name and email address, and any content you choose to use in connection with those apps. If you are an administrator, or a technical or billing contact listed on an account, we share your details with the third-party app/add-ins provider upon installation. Third-party app/add-ins policies and procedures are not controlled by us, and this privacy policy does not cover how third-party apps/add-ins use your information. We encourage you to review the privacy policies of third parties before connecting to or using their applications/add-ins or services to learn more about their privacy and information handling practices. If you object to information about you being shared with these third parties, please uninstall that app/add-in.

The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit starting our Website.

We may offer you the ability to interact with or share information with third parties through the Services. For example, we may offer users the ability to log in to the Services via a third-party service like Google, Apple access embedded maps through Google Maps or Apple Maps or interact with social media networks via links on the Services. When you intentionally interact with these third parties, we may share certain information with those third parties or receive information with those third parties, consistent with your privacy settings on the third-party service. Such information may include contact information, identification, and demographic information, and device information and identifiers. You should always check the privacy settings and notices in these third-party services to understand how those third-parties may use your information.

Some of our Services may contain widgets and social media features, such as access/like buttons. These widgets and features may collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third-party or hosted directly on our Services. You should always check the privacy settings and notices in these third-party services to understand how those third-parties may use your information. 

We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial. 

In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect the Company, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person. 

We may share information we collect with affiliated companies and, in some cases, with prospective affiliates. Affiliated companies are companies under the same control as the Company. The protections of this privacy policy apply to the information we share in these circumstances.

We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information.

• Storage

We use industry standard technical and organizational measures to secure the information we store. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

If you use our server or data center Services, responsibility for securing storage and access to the information you put into the Services rests with you and not the Company. We strongly recommend that server or data center users configure SSL to prevent interception of information transmitted over networks and to restrict access to the databases and other storage points used.

How long we keep information we collect about you depends on the type of information and the scope of collection and usage. After such time, we will either delete or de-identify your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. 

We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you. 

If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display content you provided, but when requested details that can identify you will be removed. 

If the Services are made available to you through a Corporate Client (e.g., your employer), we retain your information as long as required by the administrator of your account. 

If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

• Access and Control

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator, you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact section to request assistance.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps/add-ins, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Our Services and related documentation give you the ability to access and update certain information about you from within the Services. For example, you can access your profile information from your account and search for content containing information about you using key word searches in the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.

If you no longer wish to use our Services, you or your administrator may be able to deactivate your Services account. If you can deactivate your own account, that setting is available to you in your account settings. Otherwise, please contact your administrator. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact the appropriate support team. Please be aware that deactivating your account does not delete your information; your information remains visible to other Services users based on your past participation within the Services. Our Services and related documentation give you the ability to delete certain information about you from within the Services. For example, in certain cases you can remove content that contains information about you using the key word search and editing tools associated with that content, and you can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us. When you make such requests, we may need time to investigate and facilitate your request within the timeframe permitted by the law. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.

You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Services account settings menu, or by contacting us to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings and you may be able to opt out of receiving personalized advertisements from third parties. 

Relevant browser-based cookie controls are described in Cookies & Tracking Notice.

Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Our Services do (not) currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.

Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces under your sole control. 

• International Transfer

We may collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it. Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of users in the European Economic Area, the UK, or Switzerland, we make use of the European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.

• Miscellaneous

Many of our products are intended for use by organizations (Corporate Clients). Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy. 

Administrators are able to require you to reset your account password, restrict, suspend or terminate your access to the Services, access information in and about your account, access or retain information stored as part of your account, install or uninstall third-party apps/add-ins or other integrations. In some cases, administrators can also restrict, suspend or terminate your account access, change the email address associated with your account, change your information, including profile information, restrict your ability to edit, restrict, modify or delete information.

Even if the Services are not currently administered to you by an organization (Corporate Client), if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens. 

If you do not want an administrator to be able to assert control over your account or use of the Services, you should deactivate your membership, or use your personal email address to register for or access the Services. If an administrator has not already asserted control over your account or access to the Services, you can update the email address associated with your account through your account settings in your profile. Once an administrator asserts control over your account or use of the Services, you will no longer be able to change the email address associated with your account without administrator approval.

For any related aspects regarding the application of this policy, you may contact us at [email protected]