Effective Date: February 19, 2018
To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those Additional Terms shall govern such data collection and use.
In addition, please review our Terms of Service, which governs your use of the Service.
We collect and receive certain information about you as you interact with our Service, explained further in this section.
Information You Provide to Us
Information Collected or Stored As You Access and Use the Service
Usage Information. In addition to any Personal Information, Demographic Information, or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat it as Personal Information.
This Usage Information may include:
your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the URL that referred you to our Service;
the areas within our Service that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the time of day, among other information.
Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the Service. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).
Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:
Tracking Technologies Choices and Consent
We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.
Third Party Tracking and Do Not Track
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies go to Adobe’s website www.adobe.com. Please be aware that if you disable or remove these technologies some parts of our Services may not work and that when you revisit our Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Information Third Parties Provide About You
Interactions with Third-Party Services
Information You Provide About a Third Party
You may be able to send someone else a communication from the Service, such as sending information to your test sponsor. If so, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any such functionality on our Service, your contact information, name or user name and message may be included in the communication sent to your addressee(s). We will treat any such information as Personal Information.
We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this section including:
Contact Us. Please note that information submitted to any of the Services via a “contact us” or other similar customer inquiry function may not receive a response. We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.
Use of Information for Recruitment Purposes. Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this Personal Information or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.
We may share non-Personal Information, such as aggregated user statistics, Demographic Information and Usage Information, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities.
We do not share your Personal Information that we have collected directly from you on our Service with third parties for those third parties’ direct marketing purposes unless we have given you the choice to consent or withhold consent to such sharing at the time you provide your Personal Information, in which case we will honor your choice such as signing up for their email list or connecting via a social media platform such as Facebook, Instagram or Twitter.
When You Request Information From or Provide Information to Third Parties
You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
Providing Services on Behalf of Third Parties
We are often a service provider for third parties. If you are a test taker, we may share your information, including Personal Information, with your test sponsor which will use and disclose your information in accordance with its own privacy policies. LDW often acts as a processor for test sponsors, who are our clients. We may send your information and test results to the test sponsor so that it can use it for the purposes disclosed to you at the time the test sponsor requested that you take the test. We are not responsible for those third parties’ privacy practices or their use of any information that we may share with them.
Third Parties Providing Services on Our Behalf
We may use third-party vendors to perform certain services on behalf of us or the Service, such as hosting the Service, designing and/or operating the Service’s features, tracking the Service’s activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us.
To Protect the Rights of LDW and Others
To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of LDW or third parties (including through the enforcement of this Policy, our Terms of Service, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.
Affiliates and Business Transfer
We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates (“Affiliates”). We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets, bankruptcy or other corporate change, including, during the course of any due diligence process.
EEOC / Affirmative Action Reporting
In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
Your California Privacy Rights
Under California law, California residents who have an established business relationship with LDW or one of its Affiliates may choose to opt out of LDW’s disclosure of personal information about them to third parties for direct marketing purposes. Unless noted at the time of collection, our policy is not to disclose Personal Information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email LDW [dot] Privacy [at] ldw-w [dot] com or write to LDW at Leadership Development Worldwide, LLC, 76 Westminster Street, Providence, RI 02903, Attn: CA Privacy Rights.
We may provide your information, excluding your Personal Information, but including Demographic Information and Usage Information, including test answers and results, to researchers or others conducting various studies. By contract, we prohibit researchers with whom we share your information from re-identifying this data.
We may allow you to access third-party content on the Service, or to link to third-party applications and locations from the Service, but we are not responsible for your interaction with third-party content, apps, and locations.
The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Service are served to you. In addition, when you are on the Service you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Service onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies.
Third-party applications may also be available via the Service. The owners of these applications (“Third-Party Owners”) may collect Personal Information and other data from you and may have their own policies and practices. We are not responsible for how Third-Party Owners or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These Third-Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
We and third parties do not currently send you targeted ads based on your location, information and/or behavior.
Currently the Service does not use third parties such as network advertisers and ad exchanges to serve advertisements on the Service and does not use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Service and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your visits to the Service and other apps and sites you have visited.
You may change certain account information and communications preferences as more fully detailed in this section.
If you are from the European Union or the United Kingdom, upon request, free of charge, you have the right to:
access and obtain a copy of the Personal Information we hold about you;
obtain information about the purposes for which we process your Personal Information and the categories of Personal Information concerned;
obtain information on the recipients or categories of recipients (including international recipients) to whom your Personal Information has been or will be disclosed;
transfer of your Personal Information from us to another data controller;
in certain circumstances, erasure of all Personal Information we hold about you;
lodge a complaint to the supervisory authority in your jurisdiction in respect of our collection or use of your Personal Information; and
withdraw your consent to our collection, use, storage, and dissemination of your data at any time.
Please be aware that any request for withdrawal of consent above will not affect the lawfulness of Personal Information collected, processed, and transferred prior to the date of such withdrawal. You can exercise your right at any time by contacting us in the following ways: Postal Mail: Leadership Development Worldwide, LLC, 76 Westminster Street, Providence, RI 02903, Attn: Legal Department; By e-mail: LDW [dot] Privacy [at] ldw-w [dot] com.
We do not intend to collect Personal Information from children. If you think we have, let us know.
We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and do not use the Service to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. If you are a child under 13 years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.
In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at LDW [dot] Privacy [at] ldw-w [dot] com.
No data security is absolute, but we endeavor to take reasonable steps to secure data appropriately.
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Service and provide us with your information at your own risk.