Last Updated November 30, 2012
1. Our Commitment To Your Privacy
The TRUSTe program certification covers our collection, use and disclosure of information we collect through our Site and our service platform. The use of information collected through the Site and service platform shall be limited to the purpose of providing the service for which the Customer or Reseller has engaged Skillsoft or as otherwise set forth herein.
2. Our Role With Respect To The Customer or Reseller And Users
In some cases, the Site and related Services are provided to each User pursuant to a written agreement either directly between Skillsoft and the individual User or through an agreement between Skillsoft and a Customer or Reseller of Skillsoft, where the Customer or Reseller in turn makes the Services and Site available to individual Users authorized by the Customer or Reseller (collectively "Services Agreement").
3. The Information We Collect And How It Is Used
If you are a User who is not associated with a Customer or Reseller, we may sometimes, such as when you register for a service, order a product, or make other inquiries, ask for specific information about you in order to provide that product or service to you. If you purchase a subscription using a credit card, we may need certain personally identifiable information such as contact and billing information, including name, a physical postal address, and credit card information.
For all Users, because we value your opinions and comments, we frequently conduct online surveys which may request personally identifiable information. In general, we will use personally identifiable information for the purpose for which such information was provided to us. We may also use personally identifiable information to contact you, for example, to send you marketing materials or other information about our company and Services. You may opt-out of receiving future communications from us by following the instructions set forth below under Choice. Any financial information that is collected is used only to bill you for products and services.
Aggregate / Non-Personally Identifiable Information. We may gather, extract, analyze, use, reproduce, publish, display or disclose data from the Site in a manner that does not personally identify individual Users, including for example, Site metrics and textual responses provided by Users through survey responses or evaluations that do not identify the Users. We use this information to provide, maintain or improve the Services and administer and operate the Site and our business, including, without limitation, analyzing trends, tracking Users' movements around the Site, and gathering demographic information about our User base as a whole, and for other reporting, compliance and marketing purposes.
A SPECIAL NOTE ABOUT COOKIES
We and our third party partners may also employ web beacons or clear gifs (a.k.a. web beacons/web bugs), images and scripts that help better manage content on the Site. Web beacons are tiny, clear graphics that are embedded invisibly on web pages. They are used to understand and monitor online movements of Users so that we may better understand and improve their experiences on the Site. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are not stored on a User's computer or device. We do not tie the information gathered to your personally identifiable information.
Like other aggregated information from the Site that does not identify individual Users, we may analyze and share non-personally identifiable information collected through cookies with third parties, such as Skillsoft subsidiaries, affiliates, business partners, service providers, in marketing materials and in public disclosures. For example, we use information collected through cookies to provide publishing partners with information about their books, such as number of times a title has been viewed, most frequently viewed titles, and other information that helps them determine the usage of their titles.
If a Customer or Reseller requests that we use personally identifiable information for log-in credentials, we may share personally identifiable information collected through cookies with third parties, such as Skillsoft subsidiaries, affiliates, business partners, and service providers. For example, cookies help us measure and report individual session information to Customers or Resellers, such as number of active minutes and number of sessions by user, and at the Customer or Reseller's discretion, additional individual information such as a list of titles read.
If you are an authorized user of a Customer or Reseller, the Customer or Reseller will determine whether and how you express consent for the use of these cookies.
When you click on a link to an external website or third party resource (including embedded widgets similar those provided by Facebook and Twitter), the third party may place a cookie from its own site. These embedded widgets may also collect a User's IP address. Skillsoft does not control the dissemination of these cookies. You should check the relevant third party website for more information about these cookies.
If you are a User who is not associated with a Customer or Reseller and you do not wish to receive information and promotional material from us, you may "opt-out" of receiving these communications by either sending us an email at firstname.lastname@example.org, clicking the unsubscribe link at the bottom of the email or setting your preferences on the Site to, for example, not receive email notifications on new books added to the Service.
If you are a User who is accessing the Site as an authorized user of a Customer or Reseller, you may be able to set certain preferences regarding the use of your personally identifiable information on the Site, such as the option to change your login and password to non-personally identifying codes or to set other preferences internally through your organization, depending on controls selected by the Customer or Reseller. As described above, under such circumstances we process personally identifiable information only under the direction of our Customers and Resellers and generally have no direct relationship with the individuals whose personally identifiable information we process.
5. Sharing Of Personally Identifiable Information
We may also share or disclose personally identifiable information with the Customer's, Reseller's or your permission or if such disclosure is necessary to: (a) comply with legal process (such as a court order) or other legal requirements of any governmental authority; (b) protect our rights or property; (c) enforce an applicable Services Agreement; (d) protect the interests of Users of the Site or any other person; (e) protect the interests of the Site's content providers; or (f) operate or conduct maintenance and repair of our Services or equipment, as authorized by law. Notwithstanding the foregoing, we may transfer, sell or assign information obtained through your use of this Site, including without limitation, personally identifiable information, to third parties, as a result of the sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of all or part of Skillsoft.
We may share non-personally identifiable information with Skillsoft subsidiaries, affiliates and third parties including, without limitation, our business partners, service providers, in marketing materials and in public disclosures for any purpose.
In connection with some Services, such as inGenius, Users associated with a particular Reseller may be able to engage in discussions or communications with each other. In these situations, certain User generated content will be visible to other Users who may access the Site through the same Reseller. Information posted by Users associated with a Customer is generally available only to other Users associated with that Customer. Users can update the visibility of their contributions by updating their privacy settings, by undoing a recommendation or by deleting a note or comment.
7. Data Security And Integrity
We will take steps intended to safeguard personally identifiable information stored on our systems from unauthorized access or disclosure. If we ask you for a credit card number (or other sensitive financial information) to register you for our service, we encrypt the transmission of that information using secure socket layer technology (SSL). When you enter a password that information will also be encrypted.
Unfortunately, no security measures can be 100% effective. As a result, we cannot ensure or warrant the security of any information you transmit to us or via our online Services, and you do so at your own risk. Customers and Resellers are responsible for their own use of the Site and Services. We are not responsible for our Customers' or Resellers' actions nor their security controls with respect to information that they may collect via the Site or Services and we make no representation or warranty about the security of any information they collect.
8. International Transfer
Because Skillsoft is a global company, we may provide company information to our worldwide offices. The personally identifiable information you provide may be transferred to other Skillsoft offices or stored on servers around the world. Also, in certain countries, Skillsoft's service providers might undertake the collection, transfer, storage and processing of your personally identifiable information. At this time, Users' personally identifiable information is primarily stored on systems in the United States.
Skillsoft complies with the U.S. - E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of data from the European Union and Switzerland, respectively. Skillsoft has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program and to view Skillsoft's certification please visit: http://www.export.gov/safeharbor/.
9. How To Access And Correct Your Information
Most Users who wish to change or modify information previously provided to us, may do so by adjusting their settings on the Site or contacting us via email at email@example.com. If you are a User who is accessing the Site as an authorized user of a Customer or Reseller, options for accessing, correcting or changing your personally identifiable information collected via the Site may be available as specified by the Customer or Reseller.
10. Notification Of Changes
12. Comments And Concerns
Notice to California Residents
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personally identifiable information by Skillsoft to third parties for the third parties' direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org, or write us at Skillsoft, Attn: Skillsoft Legal Department, 107 Northeastern Boulevard, Nashua, NH 03062.
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