TRUSTe Privacy Certification

APERIAN GLOBAL ® PRIVACY POLICY

(Updated May 12, 2017)

This privacy policy applies to http://learning.aperianglobal.com/portal, owned and operated by Aperian Global ® . This privacy policy describes how Aperian Global collects and uses the personal information you provide on our web site: http://learning.aperianglobal.com/portal. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Aperian Global participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List.

Aperian Global is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Aperian Global complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Aperian Global is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Upon request and within 30 days, Aperian Global will grant individuals reasonable access to personal information that it holds about them. In addition, Aperian Global will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Please contact webtools@aperianglobal.com to change your personal information gathered on the Site.

Upon request Aperian Global will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at webtools@aperianglobal.com.

INFORMATION COLLECTED AND ITS USE

From the Aperian Global Learning Portal Registration page: When a User registers for the Aperian Global Learning Portal, the following information is collected:

  • User's internet protocol ("IP") address is collected for the purpose of system administration, to report traffic patterns through the Aperian Global Learning Portal and related webtools, and to audit the use of the Aperian Global and related web tools (e.g. GlobeSmart®, GlobeSmart Teaming AssessmentSM, The Collaborative ToolkitSM, Global Innovation OnlineSM, Assignment Readiness QuestionnaireSM, GlobeSmart Leadership Assessment SM, Learning Paths, Webcasts, etc.)
  • User's name and email address are collected in order to allow a record of their activities in the Aperian Global Learning Portal and related websites to be available to them upon subsequent visits. These activities include, but are not limited to:
    • Results from the GlobeSmart ProfileSM
    • List of whom the User has invited to take the GlobeSmart® Profile
    • Scores from Tests
    • Record of which Case Studies have been read
    • Shortcuts
    • Optional Contributions (including Share My Experience, Ask a Question, Upload Multimedia, Comments on other Contributions)
    • Optional Contributions to Discussion Forums
    • Password — generated by the User — is used to enable a secure log in procedure for the User when entering GlobeSmart from a computer other than the one on which the User initially registered for GlobeSmart.
    • Organizational Demographics are used by Aperian Global to provide Usage Reports to the User's organization broken down by the demographics selected by the organization (e.g. Business Unit, Region, Job Title, etc.)

From My Settings:
The following demographic information is collected either at the point of registration or prior to the use of one of our tools that makes use of demographic information as part of its function, such as the GlobeSmart Profile, GlobeSmart Leadership Assessment , GlobeSmart Teaming Assessment or the Ask a Question/Share My Experience features within GlobeSmart. This information also aids Aperian Global in its ongoing research efforts and is used for improvement of assessment tools.

  • Home Country
  • Current Location
  • Job Type
  • Age
  • Gender
  • Languages
  • Industry
  • Years of International Work Experience
  • Up to three Client-defined "custom demographics"

This information is kept completely anonymous. It is not linked with individual identities, and is displayed in collective form only. However, answers for the three Client-defined "custom demographics" may be reported back to your organization upon request, as this information is helpful for organizations to better understand their user population.

Invite a Colleague
If a user chooses to use the Invite Others feature to compare GlobeSmart Profiles with their colleagues, they will be asked to enter their colleague(s) email address(es). An email will then be automatically sent to their colleagues inviting them to visit the site, complete their profile and share it with the user. Aperian Global stores this information for the sole purpose of sending this email and enabling the user to compare their profile with that of their colleagues.

Any individual invited to share their profile can send a request to Aperian Global at webtools@aperianglobal.com to have their personal information deleted at any time.

Other Information Collected: Aperian Global may also collect certain information about a User's computer hardware and software automatically and store it in log files. This information may include: User's IP address, browser type, domain names, access times and referring Web site addresses.

IP addresses may be used to identify a User when Aperian Global or their service provider feel it is necessary to enforce compliance with the terms of use, terms of service or to protect Aperian Global's service, GlobeSmart, or other Users.

We do not link this automatically collected data to other information we collect about you.

We Aperian Global and our partners use cookies or similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Data Retention

Aperian Global will retain your information for as long as your account is active, as needed to provide you services and will use your information as necessary to comply with legal obligations, resolve disputes, and enforce agreements. Aperian Global will delete all client and associated User information in the month of January following the five-year anniversary of the last end date of client's subscription.

THIRD PARTY LINKS: Our site contains several links to third party web sites. If a User "clicks" on an external link the "click" will transfer the user off Aperian Global. These third party sites may include sites of the User's organization and/or Aperian Global partners that may use Aperian Global and/or its affiliates' logo as part of a co-branding agreement. These third party sites may send their own cookies, collect data or solicit information. Please note that if you click on social media links that are featured on our site, such links may collect your IP address, which page you are currently visiting on our site, and may set a cookie to function properly.

Please note — third party sites that are linked to GlobeSmart are not under the control of Aperian Global. Aperian Global and/or its affiliates are not responsible for the terms of use, policies or contents of any linked site, or any link contained in a linked site. Aperian Global has provided these links as a convenience. Aperian Global and/or its affiliates' inclusion of links to these sites does not imply any endorsement of the material on such sites or any association with their operators. Aperian Global's policy does not extend to anything that is inherent in the operation of the Internet, which is beyond Aperian Global and its affiliates' control.

Important — Aperian Global highlights the importance of Users reviewing the terms of use and privacy policy of any linked site before sharing any Personal Information with them as such information can be collected and used by unknown people. While Aperian Global and its affiliates strive to protect their Users' Personal Information and privacy, Aperian Global cannot guarantee the security of any information disclosed by Users online. Any information disclosed online is done at the risk of the User.

Single Sign-On: You may be able to log in to our site using an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.

Service Providers: Aperian Global's computer servers are hosted by third party providers which are SOC2 compliant and are prohibited from using personal information for any purpose.

PROTECTION OF USERS' INFORMATION: The security for all Information associated with GlobeSmart Users is of utmost importance to Aperian Global. Once Aperian Global receives a transmission from a User, it uses industry standard efforts to safeguard the confidentiality of the User's information. For example, Aperian Global stores and protects the personal information Users provide using computer systems with restricted access, located in controlled facilities using standard safeguards such as firewalls and secure socket layers.

Aperian Global and its service providers also exercise reasonable care in providing for secure transmission of information between a User's PC and Aperian Global's servers. Aperian Global cannot, however, guarantee that data transmission over the Internet is 100% secure. Therefore Aperian Global and its service providers cannot guarantee the security of any information transmitted to them from a User, nor can they guarantee the security of any information transmitted to the user from GlobeSmart or a third party link.

CONTROL OF USERS' INFORMATION: We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties. Aperian Global does not share personal information about Learning Portal and related web tool Users with parties outside the User's organization, Aperian Global and/or its affiliates and service providers. Aperian Global believes that Users should have control over the collection and use of their personal information. Therefore, Users have access to their information in the following areas of GlobeSmart:

  • My Settings: The My Settings page in the Aperian Global Learning Portal allows Users to view and change their account information. On this page, Users can change their email, password, demographic- and other information collected in the Registration process. Aperian Global will respond within thirty days to all offline requests to provide access to personal information.
  • GlobeSmart Profile: The GlobeSmart Profile page allows the User to re-take the survey at any time.
  • Choice/Opt-out: Wherever users are provided the opportunity to 'opt-in' to receiving specific Aperian Global emails (e.g. newsletters), Users can opt-out of these emails at any time from My Settings or by following the opt-out link at the bottom of the emails. There are certain system emails for which Users may not opt-out. These include the account activation email and invitations from colleagues or team members inviting them to share GlobeSmart Profiles.

WHOM TO CONTACT: If Users have any questions about this Privacy Policy, they may contact Aperian Global at privacydept@aperianglobal.com.

Disclosure: In certain situations, Aperian Global may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We reserve the right to disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site. If Aperian Global is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

CHANGES TO THIS POLICY: Aperian Global will occasionally update this Privacy Policy to reflect company and customer feedback. When Aperian Global posts changes to this Policy, you will see the word "updated" next to the Privacy policy link on the front page of the Aperian Global Learning Portal. If there are material changes to this Policy or in how Aperian Global will use your personal information, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. Aperian Global encourages you to periodically review this Policy to be informed of how Aperian Global is protecting your information. A User's continued use of GlobeSmart following the posting of changes to these terms will mean that that User accepts those changes.

Please Note — Nothing in the terms of this Privacy Policy or the act of subscribing to GlobeSmart shall form a contract between Aperian Global and any of the Users. Aperian Global further confirms that it does not give any warranties and does not accept any liability to any Users with respect to any advice or information provided in any part of the Aperian Global Learning Portal and related web tools.

Company Contact Information Attn: Privacy Officer, Aperian Global, 1 Kaiser Plaza, Suite 785, Oakland, CA 94612 privacydept@aperianglobal.com

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