Effective January 16, 2019
WHO WE ARE
COLLECTION AND USE OF PERSONAL DATA
PERSONAL DATA WE COLLECT
We may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements listed in each category are only examples and may change):
Personal Data about you and your identity, such as your name, ID number, photo, the email/password combination you use to log in to our Site, and other Personal Data you may provide on various forms or in an account profile.
Personal Data used to contact an individual, e.g. email address(es), physical address(es), phone number(s), or social media platform account information, as well as a name or other salutation.
Personal Data relating to your device, browser, or application e.g. IP addresses, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies.
Personal Data relating to your preferences, interests, personal demographics (e.g. country from which you are accessing our Site), your “likes,” and other information provided to us via social media services and advertising technologies, including any other categories of information (such as Identity or Device Data linked to such information).
Special Category Data:
As defined in the EU General Data Protection Regulation, this includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, or information relating to sex life or sexual orientation. (Note: this Personal Data may be subject to additional restrictions, and we do not intentionally collect any of this data.).
PROCESSING OF PERSONAL DATA
You may be able to register and create an account on our Sites. Registration is optional in most cases. If you choose to register, we will process Identity Data, Preferences Data, and Contact Data.
We use the Identity Data and Contact Data as necessary to create, maintain, and provide you with important information about your account. Subject to Your Rights and Choices, we may also use the Identity Data and Preferences Data as part of our efforts to improve our Sites and to create a personalized user experience, and we may process the Identity Data, Preferences Data, and Contact Data in connection with promotional communications, requested emails and materials, and use analytics.
CONTENT DOWNLOADS AND REQUESTS
We process Identity Data, Preferences Data, and certain Contact Data when you complete a content download or request on our Sites, including downloading any of our lesson plans, training materials, posters, calendars, quotations, or other resources.
We use the Identity Data and Contact Data as necessary to complete and provide you with important information regarding your download or request. Subject to Your Rights and Choices, we may process Identity Data and Preferences Data to improve our services and create a personalized user experience (such as tailoring the content you see when you are on our Sites), and in connection with promotional communications and use analytics.
We may process Identity Data, Device Data, Preferences Data, and Contact Data when you enroll to receive, and when you open or interact with, our electronic promotional communications. Note, you may be enrolled with your consent or, where allowed, in connection with account registration or a download.
Subject to Your Rights and Choices, we may use the Identity Data, Device Data, Preferences Data, and Contact Data to improve our services and to create a personalized user experience, and in connection with promotional communications and use analytics.
SPECIAL PROMOTIONS AND OFFERS
We use this Identity Data and Contact Data as necessary to carry out special promotions and related transactions. Subject to Your Rights and Choices, we may also use this Identity Data and Preferences Data to improve our services and to create a personalized user experience, and we may process this Identity Data and Contact Data in connection with promotional communications and use analytics.
If you win a promotion, your acceptance of a prize may allow us to make certain Personal Information public, e.g. posting your name on a winner’s page. See the applicable program’s terms for details.
USER CONTENT & SOCIAL MEDIA
We use Identity Data and Contact Data as necessary to feature User Content and for integration with social media on our Sites. Subject to Your Rights and Choices, we may also use Identity Data and Preferences Data to improve our services and to create a personalized user experience and we may process Identity Data and Contact Data in connection with promotional communications and use analytics.
Any User Content you provide may be made public as soon as you post it on our Sites. We may review User Content before it is made public but make no guarantee that we will do so in every instance. All User Content posted is your sole responsibility. Ensure that if you submit any User Content containing photos or other personal information of other parties, you have that party’s consent to do so.
COOKIES AND SIMILAR TECHNOLOGIES
We, and certain third parties, may process Identity Data, Device Data, Contact Data, Preference Data, and certain User Content when you interact with cookies and similar technologies. We sometimes receive this data from third parties. Please note that the privacy policies of third parties may apply to these technologies and information collected.
Subject to Your Rights & Choices, we use this information as follows:
(i) for “essential” or “functional” purposes, such as to enable certain features of the Site, or keeping you logged in during your session on the Site;
(ii) for “analytics” and “personalization” purposes, consistent with our legitimate interests in how the Site is used or performs, how users engage with and navigate through the Site, what sites users visit before visiting our Site, how often they visit the Site, and other similar information, as well as to modify the content visible to you, the language in which our Site appears, and otherwise tailor the Site for your use. Our Site uses Google Analytics to obtain information about our Site’s users, and we may also link our Facebook app IDs to our Site to learn more about visitors to our Site and to see if you like or share our content.
Some of these technologies can be used by us and/or our third party partners to identify you across platforms, devices, sites, and services. Third parties may engage in use analytics using this data.
SPECIFIC PROCESSING PURPOSES
Consistent with our legitimate business interests, we may personalize our Sites. To do so, we may link together and analyze the Personal Data that we hold about you. Personal Data processed for personalization purposes, whether or not linked, may be augmented with Preferences Data. We may create Preferences Data, or obtain it from third parties, using Personal Data we hold about you. We process Preferences Data so that our communications and Sites are more relevant to you. For example, we may provide better recommendations to you, tailor content and communications to your interests, and use the information to guide overall improvements to our services. We may also use Preferences Data in connection with use analytics. See Your Rights and Choices for information about how you can limit or opt out of this processing.
We, and certain third parties operating on or through our Sites, may engage in use analytics by tracking and analyzing your interaction with and use of the Sites. This enables us to better understand how our users interact with our Sites. This process may include various parties and service providers, and may include Preferences Data, Device Data, Identity Data, and at times, Contact Data in order to more accurately monitor and analyze use of the Sites. The parties that control the processing of Personal Data for use analytics purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. These services may also track whether you view, interact with, or how often you have used certain services. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to direct services to, determine whether and how services you use are effective, and may augment your profile with information derived from these observations. See Your Rights and Choices for information about how you can limit or opt out of this processing.
Consistent with our legitimate business interests, we (or if appropriate, our affiliates or trusted third parties) may send you promotional communications to the extent allowed by law: if you sign up for such communications, download content from us, register on our Sites or for a promotion or contest with us or a partner, or in connection with your communications with, or submission of User Content to, us. These communications may be personalized. See Your Rights and Choices for information about how you can limit or opt out of promotional communications.
Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the following categories of recipients:
In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we may share your Personal Data with service providers who provide certain services or process data on our behalf.
In order to streamline certain business operations, improve personalization, share promotions and content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our users, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.
We may share your Personal Data with certain partners in connection with promotions, events, and services that are promoted, managed, supported, or otherwise undertaken with that third party.
In order to improve personalization, deliver more relevant information to you, and develop better products and services, we may share certain Personal Data with our affiliates and trusted third parties for promotional, advertising, or other purposes.
If you use any social media plugin, API, or other similar feature, use a hashtag or similar link, or otherwise interact with us or our Sites via social media, we may make your post available on our Sites or to the general public. We may share Personal Data or other information in the post to the extent permitted by the relevant social media service.
Your Personal Data may be processed if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
We operate and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. does not provide the same legal protections guaranteed to Personal Data in the European Union. Accordingly, your Personal Data may be transferred to the U.S. pursuant to the EU-U.S. Privacy Shield Framework, the Standard Contractual clauses, or other adequacy mechanisms, or pursuant to exemptions under EU law.
Your Rights & Choices
Subject to the rights granted to other individuals, and our rights to limit or deny access/disclosure under applicable law, certain individuals have the following rights in their Personal Data. Note, we may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to prove your identity. You may exercise your rights by contacting us:
You may receive a list of your Personal Data we process to the extent required and permitted by law.
You may correct any Personal Data that we hold about you to the extent required and permitted by law. For account data, you may be able to make changes via your profile page.
To the extent required by law, you may request that we delete your Personal Data from our systems.
To the extent required by law, we will send you a copy of your Personal Data in a common portable format of our choice.
Residents of California (and others as required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. This request must be written, signed, and mailed to us.
You have the right to contact or file a complaint with regulators about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.
It is possible for you to use some of our Sites without providing any Personal Data, but you may not be able to access certain features or view certain content. You have the following choices regarding the Personal Data we process:
If you consent to processing, you may withdraw consent any time, to the extent required by law.
You have the choice to opt-out of processing related to promotional or other communications or to withdraw your consent if communication was initiated through consent. You may exercise your choice via the links in our communications or by contacting us re: communications.
Profiling & Personalization
You may opt out of the creation or other processing of Preferences Data by automated means, and object to processing for personalization purposes, to the extent applicable law gives you the right to do so. Note that we may not be required to cease certain types of processing based solely on an objection (for example, where we must comply with applicable legal requirements).
Cookies & Similar Technology:
You may have the right under applicable law to object to our processing of your Personal Data for certain purposes. Note that we may not be required to cease processing based solely on an objection.
We follow and implement reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and we do not have control over third parties’ security processes. Please note, we do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.
We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate and requested.
Our Sites are neither directed at nor intended for use by minors under the age of majority in the relevant jurisdiction. Further, we do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it.
Feel free to contact us with questions or concerns using the appropriate address below.
555 17th St., Ste 960
Denver, CO 80202
List of Third Parties
We receive and disclose personal data to/from third parties. The following is a list of third parties with whom we may share data or which may engage in processing:
Google Analytics (Analytics providers)
Facebook, Twitter (Social media services)
Amazon (Content distribution and file storage)
MailChimp (Email services)