Effective on: January 25, 2018
Collection of Personal Data
In order to provide our products, services and websites and for the other purposes set out in Use of Information below, we collect and process personal data from our customers and other users of our websites, products and services. We may collect information from you such as, but not limited to, your name, address, telephone number, email address, user IDs and passwords, billing and transaction information, credit card or other financial information, contact preferences, employment information, professional credentials, board membership and licensing information, and similar information provided ("Personal Data"). You are not required to provide us with all of the Personal Data listed above, but if you do not do so, we may not be able to effectively provide you with our products, services and information. In certain circumstances, you will need to provide us with specific categories of Personal Data (such as name, email address and payment information) in order to enter into a contract with us and for us to perform that contract.
From time to time and as permitted by applicable law(s), we may collect Personal Data about you and update any existing Personal Data that we currently hold from other third-party sources, including publicly available data sources, publicly available social networking sites such as LinkedIn, your employer or university/school, or data brokers such as Acxiom.
See “Use of Information” section below for details regarding the ways that we use and process your personal data.
Use of Information
Your Personal Data may be used in the following ways:
- To provide our products and services to you
- To enhance and improve our products and services, for example, by performing internal research, analyzing user trends and measuring demographics and interests
- To process payments from you
- To process payments to you (including, but not limited to, refunds or reimbursements)
- Internal purposes, such as website and system administration or internal audits and reviews
- To provide access to restricted parts of our websites
- To communicate with you regarding products and services that may be of interest to you
- To respond to your requests and inquiries
- To serve relevant advertisements to you when you visit our websites or other third-party websites (including social media platforms)
- To request your participation in surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and services
- To comply with applicable law(s) (for example, to comply with a search warrant, subpoena or court order) or to carry out professional ethics/conduct investigations
- From time to time we may provide statistics about the usage levels of our websites and other related information to reputable third parties, but these statistics will not include information which will allow you to be identified
- We may use the information you provide to us and which we obtain from other sources to better understand your interests so we can try to predict what other products, services and information you might be most interested in. This practice is called “profiling”, which involves making automated decisions about you based on this information in order to better enable us to tailor our interactions with you to make them more relevant and interesting. You may object to such profiling at any time by contacting us (see Contact Information/User Rights below).
We will process your Personal Data for the purposes identified above on the following bases:
- Our legitimate interests, which include processing such Personal Data for the purposes of providing and enhancing the provision of our products, services and information, as well as advertising further products, services and information to you;
- Where such processing is necessary to perform our contract with you or to take steps before entering into our contract with you; and
- As necessary to comply with our legal obligations, resolve disputes and enforce our contractual agreements.
Unless a longer retention period is required by applicable law, we will retain your information for as long as your account is active, as well as for a short additional period afterwards to cover any outstanding issues or queries that may arise in relation to your account (for example, outstanding payments). This period of retention is subject to our review and alteration.
Sharing and Disclosure to Third Parties
We may disclose your Personal Data to third parties from time to time under the following circumstances:
- You request or authorize the disclosure of your personal details to a third party.
- The information is disclosed as permitted by applicable law(s) and/or in order to comply with applicable law(s) (for example, to comply with a search warrant, subpoena or court order).
- The information is disclosed to your employer or education provider in the event they have an interest in your data (e.g. they have purchased a product or service on your behalf).
- The information is provided to our agents, vendors or service providers who perform functions on our behalf. See below for additional details.
- Hosting providers for the secure storage and transmission of your data
- Identity management providers for authentication purposes
- Database software providers for the management and tracking of your data
- Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
- Advertising partners, including social media providers, for the delivery of targeted advertisements
- Marketing providers who send communications on our behalf regarding our products and services
- Payment solution providers for the secure processing of payments you provide to us
- Technology providers who assist in the development and management of our web properties
- Fulfillment and postal vendors for the fulfillment of our products and services
- Survey and research providers who perform studies on our behalf
Collection of Information Through Cookie Use
The following types of cookies may be used on our websites:
- Essential Cookies: These cookies are necessary for our websites to work properly. They are usually only set in response to actions you take such as logging in or completing online forms. You can set your browser to block or alert you about these cookies, but some parts of our sites will not function if these cookies are blocked.
- Functionality Cookies: These cookies enhance the functionality of our websites by storing your preferences (such as your preferred language or the region that you are in) and allow us to provide enhanced features on our sites such as videos. These cookies may be set by us or by third-party content that we have placed within our pages. If you do not allow these cookies, some of the features on our websites may not function properly and you may not receive a personalized experience when visiting our sites.
- Performance Cookies: These cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our sites. They help us to understand which pages are visited most frequently and how visitors interact with our sites. Any information collected by performance cookies is aggregated and therefore not identifiable. If you do not allow these cookies we will not receive data related to your visits to our sites.
- Third-Party Cookies: These cookies may be set through our site by our advertising partners, such as Google or Adobe. They may be used by these companies to enable them to build a profile of your interests and show relevant advertisements on other sites. These cookies are based on identifying your browser and internet device. If you do not allow these cookies, you will experience a decrease in the targeted advertisements that you see online.
All major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage your preferences related to cookies, please consult the privacy features within your browser.
Further information about cookies:
We strive to provide you with relevant and useful information related to our products and services. However, any promotional emails that we send will include a link at the bottom of the email to unsubscribe. Additionally, you can contact us using the information listed at the bottom of this policy to make changes to your communication preferences.
Transfer of personal data internationally
By providing us with your personal data, you acknowledge and agree that we may from time to time transfer any of your personal data to any of our offices or to the offices of any of our affiliates, agents or appointed representatives located around the world. Please do not submit any personal data to us if you do not wish for your data to be transferred internationally.
Security and Other
We use reasonable measures to strive to safeguard and secure the personal data we collect. Any transmission of personal information is at your own risk. Technology, such as, but not limited to, Transport Layer Security (TLS) and Secured Socket Layer (SSL), is used to enhance security and reduce risk of loss. Our security practices, processes or technology do not guarantee absolute security of your information and you should take all normal personal precautions such as, but not limited to, not sharing passwords, closing browsers, and not using public networks (e.g., internet cafes, etc.).
Parents and Children
We strive to comply with the provisions of COPPA (the Children’s Online Privacy Protection Act) and do not knowingly collect personal information from children under the age of 13. Parents have the right to terminate the registration of a child under the age of 13 by contacting us using the information listed at the bottom of this policy.
Upon request we will provide you with information about whether we hold any of your personal data. We take reasonable steps to ensure that your personal data is kept accurate and up-to date for the purposes for which it was collected. We will provide you with reasonable access to your personal data in accordance with relevant laws, including by making reasonable efforts to provide you with online access and the opportunity to update your information. To protect your privacy and security, we will take steps to verify your identity before granting access or making changes to your personal information. You may access, delete and correct your personal information by accessing your online account within our websites or by contacting us using the contact information listed below. We will respond to your request within a reasonable timeframe.
You are encouraged to report any improvements, suggestions, or any suspected breaches of privacy or security to us by using the contact information listed below.
1345 Avenue of the Americas, 27th Floor
New York, NY 10036