Please read the information below:
- Information we collect about you
- How we use your information
- Disclosure of your information
- Updating or correcting your Personal Data
- Cancelling your account or deleting your Personal Data
- Choices regarding control of your Personal Data
- Children’s Privacy
- Information related to data collected through the Cortexa service
- Data Security
- Cookies and other technologies
- Mobile Analytics
- Direct Marketing
- How do you contact us with questions?
INFORMATION WE COLLECT ABOUT YOU
We collect several types of information about visitors and/or users of our Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Websites or App.
(a) We will collect and process your personal data when you register for a Service/create an account, register for training, complete an e-learning module, submit feedback, enter a contest, fill out a survey, or send us a communication. When ordering products or services on the Websites or App, you may also be asked to provide a credit card number and other payment-related information. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
We also collect your Internet Protocol (‘IP’) address. We use your IP address to diagnose problems with our servers and/or software, and/or to administer our Services and to gather demographic information.
(c) When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best version of the application to provide you. We do not ask you for, access, or track any location-based information from your mobile device at any time while downloading or using our App or Services.
(d) When you contact us for customer support we may collect additional information to resolve your issue.
We may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by Cortexa. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
- HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
- To present content from our Services in an effective manner for you and for your computer or mobile device
- To provide you with information, products or services that you request from us or which we feel may interest you
- To remember your information so that you will not have to re-enter it during your visit or the next time you visit the Service;
- To carry out our obligations arising from any contracts entered into between you and us, including for invoicing and collection
- If you pay for Services using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company
- To allow you to participate in interactive features of our Services, when you choose to do so
- To contact you about our Services and purposes directly related to the Services such as:
- marketing communications about products, services, offers, programs and promotions of Totara Learning and third parties (including contests, newsletters, surveys and any other marketing activities), and process and deliver entries and rewards in connection with promotions. You may have the right under applicable law to opt out of receiving promotional communications as described below under “Your Rights and Choices”.
- anonymizing Personal Information, including for data analytics purposes.
We may process your Personal Information for the above purposes when:
- You have consented to the use of your Personal Information;
- We need your Personal Information to provide you with services and products requested by you, or to respond to your inquiries;
- We have a legal obligation to use your Personal Information;
- We or a third party, have a legitimate interest in using your Personal Information, including to ensure and improve the safety, security and performance of our products and services.
- DISCLOSURE OF YOUR INFORMATION
(a) We provide and support some of our Services through contractual arrangements with service providers and other third parties. We and our service partners use your Personal Data to operate our Websites and to deliver Services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Websites; and provide order information to third parties that help us deliver the Services.
(c) In the event that Cortexa decides to sell all or part of its shares or assets or enter into a merger, we reserve the right to include your data, including Personal Data among the assets transferred to the acquiring or surviving company.
- UPDATING OR CORRECTING YOUR DATA
You may change your Personal Data associated with your account online by logging into your ‘Profile’ in accordance with instructions posted elsewhere on our Websites.
- CANCELLING YOUR ACCOUNT OR DELETING PERSONAL DATA
You may choose to let your subscription lapse, in which case we will retain your information for 3 years in case you choose to re-subscribe. You may choose to close your account in which case we will delete your information, including your learning history, within 30 days of your request. If you are using an enterprise-provided account, the data related to your learning activities will be retained for the period of time specified under the agreement between Cortexa and your enterprise sponsor or employer.
- CHOICES REGARDING CONTROL OF YOUR PERSONAL DATA
You can access some of the information that we collect about you. For example, by logging into your account, you can access information regarding recent activity on the Websites; certain Personal Data we maintain about you and your training records.
With respect to your communications preferences, you can unsubscribe from newsletters by following the instructions included in the newsletter you receive. If your email address has changed and you would like to continue to receive newsletters, you will need to access your account and update your email address information in your account and sign-up again for the newsletter. Occasionally we may send out service emails concerning website disruptions.
- CHILDREN’S PRIVACY
Our Site is a general audience site not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16 without parental consent. If you are under 16 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Information has been collected on the Service from a child under 16 years of age without parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has obtained an account on the Service, then you may alert us at firstname.lastname@example.org and request that we delete that child’s Personal Information from our systems.
- INFORMATION RELATED TO DATA COLLECTED THROUGH THE CORTEXA SERVICE
For certain services, we collect information under the direction of our clients (e.g., an organisation that subscribes to the Services for use by the organisation’s personnel). In this respect, we act as a data processor under applicable laws. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and fulfil our obligations under those agreements with the data controllers.
- DATA SECURITY
Access by you to your account is available through a password and/or unique user name which may have been autogenerated, provided by your employer, or selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone, that you change your password often using a combination of letters and numbers, and that you ensure you use a secure web browser. We cannot be held accountable for activity that results from your own neglect to safeguard the secrecy of your password and username. If you share a computer with anyone, you should always log out of your account after you are finished, in order to prevent access to your information from subsequent users of that computer.
Please notify us as soon as possible if your username or password is compromised at Customer Support.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.
In the unlikely event that we believe that the security of your Personal Data in our control may have been compromised, we will try to notify you. To the extent we have your e-mail address, we may notify you by e-mail and you consent to our use of email as a means of such notification. If you prefer for us to use another method to notify you in this situation, please email us at Customer Support with the alternative contact information you wish to be used.
- COOKIES AND OTHER TECHNOLOGIES
- DATA TRANSFERS
We use service providers that are located in various countries, including the United States, Ireland, and the United Kingdom. If you choose to use the Service from regions of the world with laws governing data collection and use that may differ from the laws in these countries, then please be aware that you are transferring your Personal Information outside of those regions to these countries for storage and processing. Also, we may transfer your data from these countries to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including Personal Information, on or to the Service, you consent to such transfer, storage, and processing.
We comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Information to countries outside of the European Union (“EU”). We may also rely on third parties’ certifications to the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield frameworks.
- MOBILE ANALYTICS
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the App, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any Personal Data you submit within the App.
- DIRECT MARKETING
We do not share personal data with third parties for their direct marketing purposes without your permission.
- HOW DO YOU CONTACT US WITH QUESTIONS?
If you have questions or complaints regarding this Policy, please first contact Cortexa online. You can also reach us by email at email@example.com or physical mail at the addresses below
Effective Date: 5 March, 2018