Effective Date: (May 17, 2021)
This Learning Pool Privacy Policy (“Policy”) outlines the information that Learning Pool (“LP”, “we”, “us” or “our”) gathers, how we use that information, and the options you have to access, correct, or delete such information.
This Policy applies to the processing of personal information collected in connection with the digital learning environments (each a “DLE”) Learning Pool hosts on behalf of our clients, the LP website (remote-learner.com), LP’s Learning Spaces site (www.learningspaces.remote-learner.com), and the normal business operations and communications conducted with clients, end-users, and visitors (collectively, our “Service”). By using the Service, you consent to the privacy practices described in this Policy as well as the terms of any agreement you have entered into with LP (each an “Agreement”). Capitalized terms used but not defined in this Policy have the meaning given to them in the Agreement.
1. Policy Application. This Policy applies to LP’s collection, use, and disclosure of the personal information in the following categories:
- Attendees: Individuals who provide their information to LP representatives when they attend or register to attend LP-sponsored events or other events at which we participate.
- Website Visitors: Individuals who visit LP’s websites or Learning Spaces. For clarity, “websites” does not include any sites owned or operated by LP’s clients, partners, or services providers.
- Clients: Entities or organizations that have entered into agreements with LP for the Service.
- End Users: Individuals who visit a Client DLE and whose information we process in order to provide the Service to our Clients pursuant to our agreements with them.
- Data Sources: Encompasses Attendees, Website Visitors, Clients, and End Users.
This Policy does not apply to our partners and service providers who may have their own terms and privacy policies. Our Clients are solely responsible for establishing policies and ensuring compliance with all applicable laws and regulations, including those relating to the collection of personal information in connection with the use of our Service by End Users with whom our Clients interact.
2. Personal Information Collected. For the purpose of this Policy, “personal information” means any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier such as a name or email address. In connection with the Service, LP obtains personal information from various sources described below.
Information Attendees Provide:
LP may ask for and collect personal information such as name, email address, or organization when Attendees register for or attend a sponsored event or other events at which LP (and/or its representatives) participates.
Information Website Visitors Provide:
LP requests – at the discretion of Website Visitors – personal information via a contact form including name, email, phone number, and company. LP may also ask Website Visitors to submit similar personal information if they choose to use interactive features of the Website, including participation in surveys, promotions, webinars, requesting email notifications or otherwise communicating with us. LP sends such communications in accordance with applicable law.
As is standard practice with most websites, LP collects information provided by the Website Visitor’s browser including the visitor’s IP address, operating environment (such as browser type and version, browser plugins installed, operating system version, regional and language settings, screen size and/or resolution, windows size, and page size), access dates and times, and referring websites. Additionally, LP automatically collects information about Website Visitors such as the pages, features, and other materials accessed, the amount of data transferred, the links clicked, the amount of time spent interacting with each page, and other information about the Website.
Visitor’s interactions with the website:
Websites may use cookies, flash cookies, web beacons, and other technologies for a variety of purposes, such as saving and retrieving information about the Website Visitor and assisting in displaying relevant promotions and advertising to the visitor. LP may use such technologies to share non-personal Information with third parties or to retrieve non-personal Information from third parties.
Website Visitors should be aware that websites offer many interactive elements including forums, search fields, login data, and course activities. If Website Visitors choose to participate in any of these interactive elements, please be aware that any information posted or provided might be read, collected, and used by others who access it. If Website Visitors wish to remove their personal information from any of our interactive areas, please see the section below entitled “Data Rights.”
Information Clients Provide:
LP does not dictate the nature of the data collected by Clients nor is it responsible for the access to that data. Clients are responsible for the nature of data collected from, and stored about, End Users and are responsible for End User access to the DLE and their data within it. When using the Service, a Client may provide LP with a wide variety of information about itself and its End Users such as name, physical address, e-mail address, phone number, billing and payment information, transaction history for Client’s purchases from LP, Client’s search queries within the Service, messages Client sends us, and other types of information. LP will store and use such information only in accordance with this Privacy Policy.
Information End Users Provide:
LP has no direct relationship with End Users of a Client’s DLE. It should be understood that as a data processor, LP does not dictate the nature of the personal information collected nor is it responsible for the access to that information. The responsibility for information collection, types of information collected, and access to that information lies with LP’s Clients. LP is responsible for site-level access security and notifications to Clients. LP relies upon Clients to comply with the legal requirements that apply to subject access requests. Clients are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their DLE End Users.
As is standard practice with most sites, LP collects information provided by the End User’s browser including the End User’s IP address, operating environment (such as browser type and version, browser plugins installed, operating system version, regional and language settings, screen size and/or resolution, windows size, and page size), access dates and times, and referring websites. Additionally, LP automatically connects information about the End User’s visit to a Client’s DLE such as to the pages, features, and other materials accessed by the End User, the amount of data transferred by the End User, the links the End User clicks, the amount of time the End User spends interacting with each page, and other information about the End User’s interactions with the website.
A Client DLE may use cookies, flash cookies, web beacons, and other technologies for a variety of purposes, such as saving and retrieving information about the End User and assisting in displaying relevant promotions and advertising to the End User. LP may use such technologies to share non-personal Information with third parties or to retrieve non-personal Information from third parties.
3. How Personal Information is Used.
3.1 LP only stores and uses personal information as is reasonably necessary or appropriate in connection with the use of the Service, including: (a) to contact Clients in connection with the use of the Service, including to respond to Client inquiries; (b) for authentication and identification purposes; (c) to enable LP to provide the Service; (d) to process payments and to provide Clients with notices about their accounts and subscriptions; (e) to fulfill any other purpose for which Data Subjects provide such information to LP; (f) in any other way LP may describe when Data Subjects provide the information; (g) to carry out LP’s business and legal obligations and enforce LP’s rights related thereto; (h) to provide Data Subjects with relevant advertising and promotions; (i) to ensure compliance with the Agreements and/or to investigate any potential breach of the Agreements; and (j) to protect LP’s networks, data, software, or business interests.
3.2 LP will not sell or lease personal information to any third party, and RL will not knowingly disclose personal information to a third party unless specified in subsections A and C of this section. RL may use the information it has collected to enable it to display advertisements to its advertisers’ target audiences. Even though LP does not disclose personal information for these purposes without consent, if a recipient interacts with an advertisement, the advertiser may assume that the recipient meets its target criteria.
3.3 In addition to using and disclosing personal information in the manner described above and elsewhere in this Privacy Policy, LP may disclose personal information: 3.3.1 to any person, entity or organization which has a Data Subject’s consent for LP to disclose personal information to; 3.3.2 to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of LP’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by LP about its users is among the assets transferred; 3.3.3 to any of its business partners and agents who provide hosting services, and website and technical support providers, as is necessary or required in connection with the operation, maintenance, and support of the Service; 3.3.4 to any person, entity or organization in order to facilitate the provision of the Service, such as providing name and payment information to LP’s third party payment processors; 3.3.5 to comply with any legal requirements, subpoena, discovery requests, or court orders, to defend any legal or administrative proceedings, or as LP believes in good faith is necessary to comply with any laws or legal requirements; 3.3.6 as LP believes is necessary or appropriate in an emergency situation, including without limitation, to prevent criminal activity, personal injury or property damage; 3.3.7 to law enforcement, financial institutions or other appropriate authorities in connection with any investigation of suspected criminal or fraudulent activity by any person or entity; and 3.3.8 if LP believes it is necessary or appropriate to protect the rights, property, or safety of itself, its business partners, its users, or third parties (including, without limitation, to facilitate the enforcement of LP’s rights under the Agreements).
4. Use of Non-Personal Information. LP may use non-personal information (including, for example, aggregated information about its users or information that does not identify any individual) for any purposes whatsoever (including without limitation, advertising, marketing, enhancing, designing, or developing products and/or services, and research), and LP may share non-personal information with others, including its partners, affiliates, and service providers.
LP may, from time to time, use a tool called “Google Analytics” (including Google Analytics Demographics and Interest Reporting features) to collect information about the use of the Services, which helps LP provide content that is relevant to and optimized for the devices used (such as smartphones and tablets). LP respects and values privacy, and never combines the information collected through the use of Google Analytics with personal information. LP uses the information it receives from Google Analytics only to improve the Services and its content and marketing. Google’s use and sharing of information collected by Google Analytics about visits to the Service is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Data Subjects can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ad Settings tool. As an added privacy measure, Data Subjects can use the Google Analytics Opt-out Browser Add-on.
5. How Personal Information is Kept Safe. LP takes the security of personal information very seriously. LP has established and maintains administrative, physical, and technical measures to secure and protect personal information in our possession against accidental or illegal destruction, loss, theft, alteration, disclosure, access, misuse or any other form of data processing. LP also restricts access to personal information to employees who require it to provide Services and it takes measures to delete personal information when the information is no longer necessary for the purposes for which it was processed unless required by law or by an Agreement to keep the information for a longer period.
However, LP cannot guarantee that information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of LP’s security measures. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. Any transmission of personal information is at Client’s own risk. LP is not responsible for circumvention of any privacy settings or security measures contained in the Service.
If Data Subjects have any questions about the security of personal information, contact submit a ticket through Learning Pool’s Client Success Center.
6. Data Rights.
Attendees and Website Visitors
Subject to applicable law, Attendees and Website Visitors have the right to access, correct, update, export, restrict, anonymize, or delete their personal information. To make such a request, they may submit a ticket through Learning Pool’s Client Success Center and LP will respond within thirty (30) days. Please note that these rights may be limited in some circumstances by local law.
Device operating systems or browsers may include settings, options, or add-on components to control the placement and presence of cookies. If Attendees and Website Visitors choose to delete, modify, or alter cookies, they may not be able to utilize the full set of Service features and functionalities. Please be aware that it may take up to ten (10) business days to process a request to opt out of receiving commercial email from LP or otherwise modify the nature or frequency of promotional communications to be received.
Clients
Subject to applicable law, Clients have the right to access, correct, update, export, restrict, anonymize, or delete personal information. To make such a request, clients can submit a case in Learning Pool’s Client Success Center and LP will respond within thirty (30) days. In addition, Clients also have the right to lodge a complaint with a competent supervisory authority subject to applicable law. Please note that these rights may be restricted and subject to conditions under applicable law.
Device operating systems or browsers may include settings, options, or add-on components to control the placement and presence of cookies. If Clients choose to delete, modify, or alter cookies, they may not be able to utilize the full set of Service features and functionalities.
7. Third Party Sites. The Service may contain links to other websites that are operated by third parties. Once Data Sources click on a link connecting them to such third party website, they will leave the Service and be taken to a website that LP does not control. This Privacy Policy does not apply to any personal information (or other information) collected on a third party site, even if accessed through the Service. LP suggests that Data Subjects read the privacy policy of the third party site before providing any personal information on such third party site. LP is not responsible for any use by any person or entity of any information that Data Sources may provide while accessing or using any websites or services provided by a third party.
8. Information Transfers. LP is an international organization with affiliates, partners, and service providers in the United States and Canada. RL stores information in these regions but may transfer and/or access that information from around the world for the purposes of storage and processing of data, fulfilling Data Source requests, and otherwise operating the Service as described in this Policy, as is customary and unavoidable for cloud-hosted solutions transmitting data on the public Internet.
If Data Sources choose to use the Service from regions of the world with laws governing data collection and use that may differ from the laws in the United States or Canada, they acknowledge that they may be transferring personal information outside of those regions to the United States or Canada for storage and processing. By using the Service or otherwise providing information to LP, Data Sources agree to the transfer of personal information to the United States or Canada.
9. Children’s Privacy. LP does not deliberately collect the personal information of minors. If LP discovers that the personal information of a minor has been inadvertently acquired, it will take all necessary steps to remove and erase that information within ten (10) days.
10. Updates to Privacy Policy. LP may modify this Privacy Policy from time to time. When RL modifies this Privacy Policy, LP will give Data Subjects notice by posting the amended Privacy Policy on its website. The Privacy Policy will include an effective date, and the amended Privacy Policy will be effective on that date.
Contact Information
Learning Pool US, Inc.
1550 Larimer Street, Suite 785
Denver, CO 80202 USA
877-299-1293
Attention: Data Protection Officer
[email protected]
Learning Pool Canada, Inc.
180 Northfield Drive West, Suite 4
Waterloo, ON N2L 0C7 877-299-1293
Attention: Data Protection Officer
[email protected]
Summary of changes: Policy now includes an updated naming convention for Learning Pool (LP) (was Remote Learner and RL). Changes also include updated contact information to include the Learning Pool Client Success Center, updated links to related Learning Pool policies, and simple formatting and editorial updates that have no legal implications.