Last Revised: 12/26/19
1. What information we collect from or about you and how we use it
2. What choices you have about how we use your information
3. How we protect your information
4. What we do about children visiting the Website and Online Services
5. Additional information applicable to California residents
6. How you can contact us
1. Information We Collect From You and How We Use It
ACTIVE INFORMATION COLLECTION
We generally collect and use personal information provided to us on the Website and Online Services for the following purposes:
‐ to establish, develop, and preserve our business relationships with our customers and other individuals with whom we conduct business, and to respond to your inquiries;
‐ to provide our products and services, including, as necessary, to establish or verify the credit of persons who use, or intend to use, our products or services;
‐ to allow individuals to apply for employment with us;
‐ to authenticate the identity and preserve the privacy of customers or potential customers who contact us by telephone, electronic means, or otherwise;
‐ to allow customers and Website visitors to register for and attend training sessions and classes;
‐ for quality assurance purposes;
‐ to manage our business and ensure the efficiency, reliability, and security of our systems;
‐ to meet legal and regulatory requirements and to allow us to meet contractual requirements relating to our products and services;
‐ to ensure our records are accurate and protect customers and our business from error and fraud;
‐ to understand and assess the interests, wants, and changing needs of our customers and Website visitors with a view to improving our products and services and developing new ones;
‐ to provide our customers and Website and Online Services visitors with personalized products and services as well as product recommendations; and
‐ to notify our customers and Website visitors about changes to the Website and Online Services or upcoming products and services offered or provided by us, our affiliates, or our business partners that may be of interest to our customers and Website visitors.
PASSIVE INFORMATION COLLECTION
Some of the information we collect depends on the settings on your web browser or mobile device. Please check your web browser or mobile device if you want to learn what information your browser or mobile device sends or how to change your settings. In addition to the information sent by your web browser or mobile device, as you navigate through a website or mobile app, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as navigational data collection.
“Cookies” are small text files that are stored on your browser or device by websites, mobile apps, online media, and advertisements. There are different types of cookies. Cookies served by the entity that operates the website or app you are visiting or using are called “first party cookies” (so cookies served by us while you are using our Website are first party cookies). Cookies served by companies that are not operating the website or app you are visiting or using are called “third party cookies” (so, a website analytics provider may set a cookie on your computer via our Website while you visit our Website). Cookies may also endure for different periods of time. “Session Cookies” last only as long as your browser or app is open. These are deleted automatically once you close your browser or app. Other cookies are “persistent cookies” meaning that they survive after your browser or app is closed (for example, they may recognize your computer when you re-open our online services).
“Local shared objects” (also called Flash cookies or HTML5 cookies) and any other successor technology refers generally to the collection of cookie-like data stored on a browser or computer by web sites, ads, or third parties.
“Pixel tags” (also called beacons or pixels) are small blocks of code installed on (or called by) a web page, app, or advertisement which can retrieve certain information about your device and browser, including device type, operating system, browser type and version, web site visited, time of visit, referring web site, IP address, and other similar information (including the small text file (the cookie) that uniquely identifies the device). Pixels provide the means by which third parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner. “Software Development Kits” (also called SDKs) function like pixels and cookies, but operate in the mobile app context where pixels and cookies cannot always function. The primary app developer can install pieces of code (the SDK) from partners in the app, thereby allowing such partners to collect certain information about user interaction with the app, information about the user device, and network information.
INFORMATION WE COLLECT FROM OTHER SOURCES
We may also receive information from other sources and combine it with information we collect through our Website and Online Services. For example, we may obtain information about you from commercially available sources such as data aggregators and public databases (for example, job applicant information received from LinkedIn in connection with our hiring decisions). This information may include your name, demographic information, interests, and public data (such as social media and shopping behavior).
RETENTION OF PERSONAL INFORMATION
We retain the personal information collected on the Website and Online Services as long as necessary to provide the services, products, and information you request or as permitted by applicable law.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information you provide to us via this Website and Online Services or that we collect through your use of the Website and Online Services as follows:
• to affiliates, business partners, service providers, and contractors who support our business, in which case we will limit the amount of information disclosed to that which is necessary in order for them to provide the services or products we have engaged them to provide. We will strive to protect personal information rendered accessible by contractual agreements requiring confidentiality and security practices that help keep data inaccessible to others;
• to respond to law enforcement requests, where required by applicable laws, court orders, or governmental regulations;
• to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful, and in situations involving threats of physical safety of any person or when we believe that disclosure is reasonably necessary to protect our rights and property.
We are not liable for disclosure of information obtained due to errors in transmission or the unauthorized intervention of third parties.
We may provide aggregate statistics about our customers, sales, online traffic patterns, and related information to reputable third parties, but these statistics will not include any personally identifying information.
The Website and Online Services may use social media plugins (for example, the Facebook “Share” button, “Share to Twitter”’ button) to enable you to easily share information with others. When you visit our Website, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Website. If you are logged into the social media website (for example, Facebook, Twitter, Google+) while browsing on our Website, the social plugins allow that social media website to receive information that you have visited our Website. The social plugins also allow the social media website to share information about your activities on our Website with other users of their social media website. For example, Facebook social plugin allows Facebook to show your comments on our pages to your Facebook friends. We do not control any of the content from the social media plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.
2. Choices You Have About How We Use Your Information
We strive to provide you with as many choices and as much control as possible regarding the personal information we collect about you.
You may send us an e-mail message at email@example.com to request access to, correct, or delete any personal information that you have provided to us. To protect your privacy, we will only respond to e-mail messages sent from the e-mail account you used to set up your account.
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 e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details in Section 6 below.
Our Website and Online Services may provide forums and other areas where you can communicate with others and publicly post information. You have no privacy rights in public postings. All information you post will be accessible to anyone with internet access, and any personal information you include in your posting may be read, collected and used by others. Please use caution when posting any personal information.
You can also generally opt-out of receiving personalized ads from third party advertisers and ad networks that honor such requests by visiting: www.aboutads.info/choices (if you are in the United States), http://youradchoices.ca/choices/ (if you are in Canada), or http://youronlinechoices.eu/ (if you are in Europe).
DO NOT TRACK: Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Our Website and Online Services do not currently respond to these “do-not-track” signals.
3. How We Protect Your Information
We work hard to protect your personal information. All information collected through the Website and Online Services is stored within a secured database that is not accessible to the outside world. Resumes are stored on file systems that are not publicly accessible. Our servers are protected behind both hardware and software firewalls. Low-level access to information is restricted to authorized support personnel only.
The safety and security of your information also depends on you. Never share your password with anyone else, notify us promptly if you believe your password security has been breached, and remember to log off this Website before you leave your computer.
4. What We Do About Children Visiting This Website
This Website is not intended for children under the age of 13. We will not knowingly collect information from Website and Online Services visitors in this age group. We encourage parents to talk to their children about their use of the Internet and the information they disclose online. If your child has submitted personal information and you would like to request that such information be deleted from our records, you may do so by writing us at the address in Section 6 below.
5. California Residents
You also have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of third parties with whom we shared the personal information, and the categories of third parties with whom we sold the personal information.
• Right of Access. You have the right to request that we disclose or provide you with access to the specific pieces of personal information we have collected about you in the preceding 12 months.
• Right to Deletion. You have the right to request that we delete the personal information we collect from you. However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our Website and Online Services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
• Right to Opt-Out of the Sale of Personal Information. We do not sell your personal information. If we sold your personal information to third parties, you would have the right, at any time, to direct us not to sell your personal information.
• Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above.
We value the security and confidentiality of your personal information. Therefore, if you exercise your right to notice, right of access, or right to deletion, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully and ask that you provide a scanned copy of a government ID along with your request for verification purposes.
6. How You Can Contact Us
Attn: Marketing Department
155 Harlem Ave
North Building, 4th Floor
Toll-Free (USA): 800-521 9790