"means the information provided by one party to the other is written, graphic, recorded, machine-readable or another form concerning thebusiness, clients, suppliers, finances and other areas of the otherparty’s business or products, including, without limitation, theCourse Materials, but does not include information in the publicdomain other than through the default of the party disclosing theinformation, information required to be disclosed by any court orregulatory authority, or any information already in the possession orcontrol of the disclosing party.
"means the information and (or) content provided to the Purchaser toaccompany the Services provided in electronic form or hard copy.
"means the fees paid for the Services.
"means copyright, rights in or relating to databases, patent rights, performers' rights, designs and registered designs, trademarks, rights in or relating to Confidential Information and otherintellectual property rights (registered or unregistered) throughoutthe world.
"means the delivery by us of an online course pursuant to which youlearn course materials remotely.
"means the provision of the Online Course and/or the Course Materialstogether with other services as agreed from time to time andpurchased by you through the Website.
"means ClientsProgram, which renders the Services to the individual purchasing the Services.
"means the individual purchasing the Services.Tableof Contents
1.What Data We Get
2. How We Get Data About You
3. What WeUse Your Data For
4. Who We Share Your Data With
6. Your Rights
7. Jurisdiction-Specific Rules
8.Updates & Contact Info1.What Data We Get
Wecollect certain data from you directly, like information you enteryourself, data about your consumption of content, and data fromthird-party platforms you connect with Platform. We also collect somedata automatically, like information about your device and what partsof our Services you interact with or spend time using.1.1Data You Provide to Us
Wemay collect different data from or about you depending on how you usethe Services. Below are some examples to help you better understandthe data we collect.
When you create an account and usethe Services, including through a third-party platform, we collectany data you provide directly, including:
Account Data Inorder to use certain features (like accessing content), you need tocreate a user account. When you create or update your account, wecollect and store the data you provide, like your email address, password, phone number, and account settings and assign you a uniqueidentifying number ("Account Data").
Profile Data YourProfile Data will not be publicly viewable by others.
StudentPayment Data If you make purchases, we collect certain data aboutyour purchase (such as your name and ZIP code) as necessary toprocess your order. You must provide certain payment and billing datadirectly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may alsoreceive limited information, like the fact that you have a new cardand the last four digits of that card, from payment service providersto facilitate payments. For security, Platform does not collect orstore sensitive cardholder data, such as full credit card numbers orcard authentication data.
If you access or use ourServices through a third-party platform or service, or click on anythird-party links, the collection, use, and sharing of your data willalso be subject to the privacy policies and other agreements of thatthird party.
Sweepstakes, Promotions, and Surveys
The data listedabove is stored by us and associated with your account.1.2Data We Collect through Automated Means
Whenyou access the Services (including browsing content), we collectcertain data by automated means, including:
Technical data about your computer or device, like your IPaddress, device type, operating system type and version, uniquedevice identifiers, browser, browser language, domain and othersystems data, and platform types ("System Data").
Usage DataUsage statistics about your interactions with the Services, includingcontent accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services ("UsageData").
Approximate Geographic Data
An approximategeographic location, including information like country, city, andgeographic coordinates, calculated based on your IP address.
Thedata listed above is collected through the use of server log filesand tracking technologies, as detailed in the "Cookies and DataCollection Tools" section below. It is stored by us and associatedwith your account.1.3Data From Third Parties
Ifyou are a Platform Business enterprise or corporate prospect, we maycollect certain business contact information from third-partycommercial sources.2.How We Get Data About You
Weuse tools like cookies, to gather the data listed above. Some ofthese tools offer you the ability to opt out of data collection.2.1Cookies and Data Collection Tools
Platform andservice providers acting on our behalf (like Google Analytics andthird-party advertisers) use server log files and automated datacollection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, "DataCollection Tools") when you access and use the Services. These DataCollection Tools automatically track and collect certain System Dataand Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data CollectionTools to other data that we collect as described in this PrivacyPolicy.2.2Why We Use Data Collection Tools
Platformuses the following types of Data Collection Tools for the purposesdescribed:
StrictlyNecessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect andprevent abuse or unauthorized use of your account. These are requiredfor the Services to work properly, so if you disable them, parts ofthe site will break or be unavailable.
Functional: These DataCollection Tools remember data about your browser and yourpreferences, provide additional site functionality, customize contentto be more relevant to you, and remember settings affecting theappearance and behavior of the Services (like your preferred languageor volume level for video playback).
Performance: These DataCollection Tools help measure and improve the Services by providingusage and performance data, visit counts, traffic sources, or wherean application was downloaded from.
Advertising: These DataCollection Tools are used to deliver relevant ads (on the site and/orother sites) based on things we know about you like your Usage andSystem Data (as detailed in Section 1), and things that the adservice providers know about you based on their tracking data. Theads can be based on your recent activity or activity over time andacross other sites and services. To help deliver tailoredadvertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readableform) and content that you share publicly on the Services.
SocialMedia: These Data Collection Tools enable social media functionality, like sharing content with friends and networks. These cookies maytrack a user or device across other sites and build a profile of userinterests for targeted advertising purposes.
Weuse your data to do things like provide our Services, communicatewith you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessaryfor safety and integrity.
We use the data we collect throughyour use of the Services to:
Provide and administer theServices, including to facilitate participation in educationalcontent, issue completion certificates, display customized content, and facilitate communication with other users;
Process paymentsto instructors and other third parties;
Responding to yourquestions and concerns;
Sending you administrative messages andinformation, including messages from instructors, students, andteaching assistants; notifications about changes to our Service; andupdates to our agreements;
Sending you information, such as byemail or text messages, about your progress in courses and relatedcontent, rewards programs, new services, new features, promotions, newsletters, and other available instructor-created content (whichyou can opt out of at any time);
Manage your account and accountpreferences;
Facilitate the Services' technical functioning, including troubleshooting and resolving issues, securing theServices, and preventing fraud and abuse;
Solicit feedback fromusers;
Market products, services, surveys, andpromotions;
Market Subscription Plans to prospectivecustomers;
Learn more about you by linking your data withadditional data through third-party data providers and/or analyzingthe data with the help of analytics service providers;
Identifyunique users across devices;
Tailor advertisements acrossdevices;
Improve our Services and develop new products, services, and features;
Analyze trends and traffic, trackpurchases, and track usage data;
Advertise the Services onthird-party websites and applications;
As required or permittedby law; or
As we, in our sole discretion, otherwise determine tobe necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.4.Who We Share Your Data With
Weshare certain data about you with instructors, other students, companies performing services for us, Platform affiliates, ourbusiness partners, analytics and data enrichment providers, yoursocial media providers, companies helping us run promotions andsurveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data inother ways if it is aggregated or de-identified or if we get yourconsent.
We may share your data with third parties underthe following circumstances or as otherwise described in this PrivacyPolicy:
With Analytics and Data Enrichment Services: As part ofour use of third-party analytics tools like Google Analytics and dataenrichment services like Zoom Info, we share certain contactinformation, Account Data, System Data, Usage Data (as detailed inSection 1), or de-identified data as needed. De-identified data meansdata where we’ve removed things like your name and email addressand replaced it with a token ID. This allows these providers toprovide analytics services or match your data with publicly-availabledatabase information (including contact and social information fromother sources). We do this to communicate with you in a moreeffective and customized manner.
To Administer Promotions andSurveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, asrequired by applicable law (like to provide a winners list or makerequired filings), or in accordance with the rules of the promotionor survey.
For Security and Legal Compliance: We maydisclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
Permitted orrequired by law;
Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
Reasonably necessary aspart of a valid subpoena, warrant, or other legally-validrequest;
Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;or
Reasonably necessary in our discretion to protect againstimminent harm to the rights, property, or safety of Platform, ourusers, employees, members of the public, or our Services.
During a Change in Control: If Platformundergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or asale of all or some of its assets, we may share, disclose, ortransfer all of your data to the successor organization during suchtransition or in contemplation of a transition (including during duediligence).
After Aggregation/De-identification: We may discloseor use aggregated or de-identified data for any purpose.
Weuse appropriate security based on the type and sensitivity of databeing stored. As with any internet-enabled system, there is always arisk of unauthorized access, so it’s important to protect yourpassword and to contact us if you suspect any unauthorized access toyour account.
Platform takes appropriate security measuresto protect against unauthorized access, alteration, disclosure, ordestruction of your personal data that we collect and store. Thesemeasures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannotguarantee that communications between you and Platform, the Services, or any information provided to us in connection with the data wecollect through the Services will be free from unauthorized access bythird parties. Your password is an important part of our securitysystem, and it is your responsibility to protect it. You should notshare your password with any third party, and if you believe yourpassword or account has been compromised, you should change itimmediately and contact our Support Team with any concerns.6.Your Rights
Youhave certain rights around the use of your data, including theability to opt out of promotional emails, cookies, and collection ofyour data by certain third parties. You can update or terminate youraccount from within our Services, and can also contact us forindividual rights requests about your personal data. Parents whobelieve we’ve unintentionally collected personal data about theirunderage child should contact us for help deleting thatinformation.6.1Your Choices About the Use of Your Data
Tostop receiving promotional communications from us, you can opt out byusing the unsubscribe mechanism in the promotional communication youreceive or by changing the email preferences in your account. Notethat regardless of your email preference settings, we will send youtransactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about ourpolicies.
If you’re located in the European EconomicArea, you may opt out of certain Data Collection Tools by clickingthe "Cookie settings" link at the bottom of any page.
Thebrowser or device you use may allow you to control cookies and othertypes of local data storage. To learn more about managing cookies. Your wirelessdevice may also allow you to control whether location or other datais collected and shared.
To get information and controlcookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiativeand Digital Advertising Alliance, or if you’re located in theEuropean Economic Area, visit the Your Online Choices site. To optout of Google’s display advertising or customize Google DisplayNetwork ads, visit the Google Ads Settings page. To opt out ofTaboola’s targeted ads, see the Opt-out Link in their CookiePolicy.
To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Mixpanel Opt-OutCookie, ZoomInfo’s policy, and Clearbit data claimingmechanism.
Apple iOS, Android OS, and Microsoft Windows eachprovide their own instructions on how to control in-app tailoredadvertising. For other devices and operating systems, you shouldreview your privacy settings on that platform.
If you have anyquestions about your data, our use of it, or your rights, contact usat email@example.com
.6.2Deleting Your Personal Data
To request to access, correct, or delete your personal data, you can submit these requestsby emailing rostov. firstname.lastname@example.org. Please allow up to 30 days for aresponse. For your protection, we may require that the request besent through the email address associated with your account, and wemay need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basisto do so, including for mandatory record-keeping and to completetransactions.6.3Our Policy Concerning Children
Werecognize the privacy interests of children and encourage parents andguardians to take an active role in their children’s onlineactivities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where theylive (for example, 13 in the US or 16 in Ireland), may not set up anaccount, but may have a parent or guardian open an account and helpthem access appropriate content. Individuals younger than therequired age for consent to use online services may not use theServices. If we learn that we’ve collected personal data from achild under those ages, we will take reasonable steps to deleteit.
Parents who believe that Platform may have collectedpersonal data from a child under those ages can submit a request thatit be removed to rostov. email@example.com.Jurisdiction-Specific Rules
Ifyou live in California, you have certain rights related to accessingand deleting your data, as well as learning who we share your datawith. If you live in Australia, you have the right to make a formalcomplaint with the appropriate government agency. Users outside ofthe United States should note that we transfer data to the US andother areas outside of the European Economic Area.7.1Users in California
Userswho are California residents have certain rights under the CaliforniaConsumer Privacy Act, ("CCPA"). If you are an eligible Californiauser, included in these rights are:
"Right to Know" — Youhave the right to request to know more about the categories andspecific pieces of personal information that we have collected aboutyou and access a copy of your personal information.
"Rightto Deletion" — You have the right to request deletion of personalinformation that we have collected about you.
"Right toNon-Discrimination" — If you choose to exercise any of yourrights under CCPA, Platform will treat you like all other users. Inother words, there is no penalty for exercising your rights underCCPA.
Additionally, for more information about thepersonal information we collect and how we collect it, please see thesections above entitled "What Data We Get" and "How We Get DataAbout You."
To learn about the business and commercialpurposes for which your personal information is collected and thecategories of service providers who have access to your personalinformation, please see the sections above entitled "What We UseYour Data For" and "Who We Share Your Data With."
Asa California resident, you also have the right to request certaindetails about what personal information we share with third partiesfor those third parties' direct marketing purposes. To submit yourrequest, send an email to rostov. firstname.lastname@example.org with the phrase"California Shine the Light" and include your mailing address, state of residence, and email address.
Since there is no widelyaccepted standard for the browser-initiated Do Not Track signal, wedo not currently recognize or respond to Do Not Track signals.7.2Users in Nevada
Platformdoes not sell its users' personal information or personal data. Nonetheless, Nevada residents have the right to submit a request thatwe do not sell your covered personal information, which you can do byemailing email@example.com
.7.3Users in Australia
Ifyou are an Australia resident and you have a complaint, you may referit to the office of the Australian Information Commissioner ("OAIC").You can contact OAIC by visiting www.oaic.gov.au; forwarding an emailto firstname.lastname@example.org
.au; telephoning 1300 363 992; or writing toOAIC at GPO Box 5218, Sydney NSW 2001.7.4Users Outside of the U.S.
Inorder to provide the Services to you, we must transfer your data tothe United States and process it there. By visiting or using ourServices, you consent to storage of your data on servers located inthe United States. If you are using the Services from outside theUnited States, you consent to the transfer, storage, and processingof your data in and to the United States or other countries. Specifically, personal data collected in the United Kingdom ("UK"), Switzerland, and the European Economic Area ("EEA") istransferred and stored outside those areas. Additionally, if you arelocated in the EEA, UK, or Switzerland, you also have the right tolodge a complaint with your data supervisory authority.
Personaldata is also processed outside of the UK, Switzerland, and the EEA byour Platform group companies, or our service providers, including toprocess transactions, facilitate payments, and provide supportservices as described in Section 4. We use Standard ContractualClauses adopted by the European Commission to facilitate transfers ofpersonal data from the EEA to third countries and have entered intodata processing agreements with our service providers and Platformgroup companies to restrict and regulate their processing of yourdata. By submitting your data or using our Services, you consent tothis transfer, storage, and processing by Platform and itsprocessors.8.Updates & Contact Info
Ifyou have any questions, concerns, or disputes regarding our PrivacyPolicy, please feel free to contact our privacy team (including ourdesignated personal information protection manager) email@example.com
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