This
Privacy Statement is designed to tell you about the collection, use, and
disclosure of information related to, and your rights in respect of, the data Growth
Development Associates, Inc. ("Company", "We", or
"Us") collect and process related to your use of our salescoachondemand.com
website, mobile application and other electronic services that link to this
Privacy Statement (collectively the "Service(s)" and such locations
or applications, the “Sites”). Please be sure to read this entire Privacy
Statement before using the Service.
Background
and overview
The
Service contains
sales training information customized to specific employers and businesses. Designated
business partners, sales teams, and sales managers may use the Service’s
on demand content, including videos, slide presentations, textual material and
other multi-media content to develop and implement sales strategies, close sales of businesses’ products and services, and exchange
sales strategies, ideas, and comments.
General privacy
statement
We do not use information about you for contextual or
targeted advertising, we do not sell your personal information (more below) and,
except for relationship messaging from us, we do not share your contact
information with third parties except with your consent (opt in).
By registering for or
otherwise using the Service, you agree to the terms of this Privacy Statement.
Specifically, you authorize the collection, processing, retention, and
disclosure of Information about You by Company and its affiliates, business
partners, and service providers for the purposes described in this Privacy
Statement or as described to you during your interactions with the Service. For
example, We might clarify our practices when you register or when you use the
Service, or one of its functions, for the first time.
This Privacy Statement
is updated as of [●]. We reserve the right to update this Privacy
Statement. If We update this Privacy Statement, We will use reasonable
electronic efforts to advise you of the change, which may include posting a
notice of the change in the Service (for example when you login), or we may
send you an electronic notification of the change. If We notify you by an
electronic communication, We will provide these electronic messages to your
last known or provided electronic communication address (which may be for
example, a text message address, Twitter user name, or other site address). You
are responsible to review communications we send to those addresses, to
authorize communications from us, and to keep those addresses up to date. Use
of the Service after our notice of a change in the Privacy Statement is
acceptance of the terms and changes in the updated Privacy Statement, which
shall, unless expressly prohibited by applicable law (or unless expressly
stated in such changed Privacy Statement), be effective from the inception of your
use of the Service.
NOTICE
AT COLLECTION
THIS IS A NOTICE
TO YOU CONCERNING, AND BY USING THE SERVICE, YOUR CONSENT, TO THE COLLECTION
AND USE OF PERSONAL INFORMATION ABOUT YOU COLLECTED AND USED BY COMPANY.
Categories
of personal information we collect and the purpose for which we collect such
data:
The categories of personal information we collect and associated examples are
below:
|
Category
|
Examples (not exhaustive)
|
Purpose for which we collect and use this information
|
|
Personal
identifiers
|
Name
and email address
|
We
use personal identifiers to communicate with you, and to verify your identity.
We obtain personal identifiers manually directly from your employer
|
|
Device
information
|
Browser
user agent and internet protocol address
|
We
use Device information to monitor and improve the Services and user
experience. This information is shared with https://wistia.com/ our video service
provider and is not shared with other third parties except service providers
to Wistia, that use it to provide the video services
|
|
Device
information (shared with Google)
|
Internet
protocol address and other session data by fontawesome.com (icons)
|
Fontawesome
states that they use this data to: (a) optimize the website, so it's quick
and easy to use
diagnose
and debug technical errors; (b)
defend
the website from abuse and technical attacks; (c) associate your browsing
session with an affiliate, if you click through an affiliate's referral link;
(d)
associate
your account with an affiliate, if you buy after clicking through an
affiliate's referral link; (e) compile statistics on icon popularity; and (f)
compile
statistics on the kinds of software and computers visitors use
|
We use the information
about you to provide the Service, to fulfill your information requests, and
contact you as you have requested. We may also use information about you to
improve our programs or the content of our Service, and for our analysis.
Except as disclosed
above in the section “NOTICE AT COLLECTION” We do not share information about
you with third parties.
To keep the information
that you provide via this Service accurate, current, and complete, please
contact Us as specified below and We will take appropriate steps to update or
correct such information in our possession, or to make changes to the
Information about You so that we no longer contact you for certain purposes.
We may make some or all of these options available in the Service interface, in
which case you will manage your own preferences.
We may communicate with
you through electronic communications and through the Service, such as through
the use of notifications and alerts. You may manage certain other ways in which
We communicate with you. For example, you may subscribe or unsubscribe to
certain electronic communications from Us, such as for notifications and information
about updates to the Services. You may not unsubscribe from administrative
Service and electronic messages that We may send, such as to alert you of
changes in our Privacy Statement or Terms of Service.
The Service may provide
hyperlinks and references to other websites or allow you to connect your
information on this Service to such sites. Our Privacy Statement does not apply
to those websites, and we are not responsible for the content or function of
those websites. We encourage you to become familiar with the privacy practices
of the other websites that you use.
We are happy to hear
from you. If you have any questions about this Privacy Statement or the
practices of the Service, you may contact: privacy@salescoachondemand.com.
When you interact with
the Service, your browser or other device may communicate other technical information
that we use as part of our Services. For example, as you use the Service, your
browser or other device communicates with our technology, which in turn keeps
records of your interactivity and requests for services and content to assist
Us in managing and improving the utility of the Service, and to conduct
research and analysis on its use. The types of such interactive information may
include your Internet Protocol (IP) address, browser / device type, URL,
requests made, device identification information, and related technical usage
information. We and our service provider Wistia use cookies and other remote
side storage technology (such as clear gifs or web beacons) to authenticate you
to the Service, maintain your session, to analyze how the Service is used, to
keep track of your progress in viewing a video or other content, to link
information about how you use the Service with your account, and to help tailor
our Services. The Service may not function properly if your browser or device
is configured so it does not accept these associated cookies and other
technical means. The specific cookies and other information collected and
stored regarding your use of the Services is as follows:
|
Cookie
|
Source
|
Purpose
|
|
stripe_mid
|
.fontawesome.com
|
Icons required for menus
|
|
__RequestVerificationToken
|
aveva.salescoachondemand.com
|
Login validation
|
|
bc
|
aveva.salescoachondemand.com
|
Button count
|
|
MaxSid
|
aveva.salescoachondemand.com
|
Maximum topic display
|
|
language
|
aveva.salescoachondemand.com
|
Localization of language
for the user
|
|
MinSid
|
aveva.salescoachondemand.com
|
Minimum topic display
|
|
WBFileId
|
aveva.salescoachondemand.com
|
Video - Webinar ID
|
|
.DOTNETNUKE
|
aveva.salescoachondemand.com
|
Host software license information
|
|
SBFileId
|
aveva.salescoachondemand.com
|
Video - Sales Bite Id
|
|
dnn_IsMobile
|
aveva.salescoachondemand.com
|
Mobile or desktop?
|
|
cf_clearance
|
.fontawesome.com
|
Icons required for menus
|
|
Topic
|
aveva.salescoachondemand.com
|
Current menu topic
|
|
LastPageId
|
aveva.salescoachondemand.com
|
Navigate backwards
|
|
.ASPXANONYMOUS
|
aveva.salescoachondemand.com
|
Anonymous or validated user
|
The Service is not
intended for use by persons under the age of 16.
You may have additional
rights under state law to access certain information; for example California
residents may have rights under California Code Section 1798.83, users from Great
Britain may have rights under its privacy laws (The Data Protection Act, https://www.legislation.gov.uk/ukpga/2018/12/contents/enacted (link current as of February, 2023)) and users from
Europe or other locations may also have privacy rights under domestic privacy
laws. We honor those rights. We act solely as a Data Processor under these
laws, and not as a Data Controller. The Data Controller is your employer.
Company is a United
States of America business with its core operations in the United States.
Information about You may be processed by Us, our affiliates, business
partners, or service providers in the United States and elsewhere in the world
where privacy rules may differ from those of the country in which you reside.
If you are employed in the UK or in certain other parts of the world, We have
entered into either the Standard Contractual Clauses (link current as of February
2023), or an applicable International Data Transfer Agreement (link current as of February 2023), that permits the
transfer of your data to Us in the United States. We will comply with our
obligations under such clauses or agreements.
This section describes certain rights you
may have under the California Consumer Privacy Act of 2018 (CCPA) as amended by
the California Consumer Privacy Act (CPRA), other similar state laws applicable
in the United States, and under Regulation (EU) 2016/679 of the European
Parliament and of the Council of 27 April 2016 (“GDPR”). Collectively the
above referenced laws and regulations are referred to herein as the “Data Privacy Laws.”
For those users of our Services and Sites who
are residents of countries in the European Union (or that have equivalent
rights, such as residents of the Great Britain), the State of California, or
certain other states that have adopted laws similar to CCPA/CPRA, we have
created the following mechanisms and practices to provide you with the
following control over your personal information that comprises personal data
as defined under GDPR, or personal information as defined under the CCPA/CPRA (references
below to “Personal Data” are meant to also encompass the term “personal
information” under the CCPA/CPRA and similar laws):
A. What are your
rights?
If any of your Personal Data provided to Company is
subject to the Data Privacy Laws, you have a number
of rights. Further information and advice about your rights can be obtained
from the data protection regulator in your country (under the GDPR) or typically
from your state Attorney General, under CCPA/CPRA and other state laws.
IMPORTANT: When you contact Company to exercise your
rights it is very important for security verification and other purposes that
you use any email address that you know is associated with the Personal Data
about which you are contacting Company. Be aware that Company may use
reasonable efforts to verify your identity to ensure that it does not disclose
Personal Data to an impostor.
Please also be aware that we cannot
search, and therefore cannot locate, any encrypted stored documents or
information.
1. The
right to object to processing of your Personal Data (the right to opt
out)
You have the right to object to certain types of
processing, including processing for direct marketing (i.e. if you no longer
want to be contacted with potential opportunities from third parties).
HOW TO EXERCISE YOUR RIGHT: If you want to object to
certain types of processing, please direct your communication to privacy@salescoachondemand.com providing
specific and detailed information regarding your objection and requested
action.
Be aware that you cannot object to certain types of
processing of your Personal Data, which limitations are set forth in the Data
Privacy Laws. If Company determines that it is required to continue to process
your Personal Data it will provide you the basis on which it has made this
determination.
2. The
right to an accounting of the processing (the right to know)
You have the right to be provided with clear,
transparent, and easily understandable information about how we use and process
your Personal Data. This is why we are providing you with the information in
this privacy policy.
HOW TO EXERCISE YOUR RIGHT: If you have questions
about the privacy policy or how Company may be processing your Personal Data,
please direct your communication to privacy@salescoachondemand.com and please be
specific and detailed about your questions and Company will promptly address
those questions.
3. The
right of access
You have the right to obtain access to your Personal
Data (if we are processing it), and certain other information about Our
privacy practices with respect to your Personal Data (similar to that provided
in this Privacy Statement).
This is so you are aware and can check that we are
using your information in accordance with GDPR/CCPA/CPRA or any other
applicable data protection laws.
HOW TO EXERCISE YOUR RIGHT: If you have questions
specific to your Personal Data and how Company is using it in accordance with
GDPR, CCPA/CPRA or other applicable laws, please direct your communication to privacy@salescoachondemand.com and please be
specific and detailed about your questions and Company will promptly address
those questions.
4. The
right to rectification
You are entitled to have your Personal Data corrected
if it is inaccurate or incomplete.
HOW TO EXERCISE YOUR RIGHT: If you believe your
Personal Data processed by Company is incorrect and needs to be updated or
otherwise corrected, please check your settings with respect to your account,
and if you still believe your Personal Data is inaccurate, direct your
communication to privacy@salescoachondemand.com.
5. The
right to erasure (the right to delete)
This is also known as “the right to be forgotten” and,
in simple terms, enables you to request the deletion or removal of your
Personal Data where there’s no basis for us to continue to process it or to
retain it. This is not a general right to erasure; there are exceptions as
stated in the Data Privacy Laws.
HOW TO EXERCISE YOUR RIGHT: If you no longer want Company
to have and/or process your Personal Data, to the extent we do not provide a
self-service means of deleting your Personal Data, please direct your
communication to privacy@salescoachondemand.com.
(NOTE: Consistent with Data Privacy Laws Company may
retain a trivial amount of information, for example, to keep a record of its
compliance with your request.)
6. The
right to restrict processing
You may have rights to “block” or suppress further use
of your Personal Data that Company processes. When processing is restricted, we
can still store your Personal Data but may not use it further. We may keep
lists of people who have asked for further use of their information to be
“blocked” to make sure the restriction is respected in future, but also be
aware that upon making this request, we may terminate your account and delete
your Personal Data instead of restricting the processing of it.
HOW TO EXERCISE YOUR RIGHT: If you want to restrict,
or terminate restrictions, on Company’s processing your Personal Data, please
direct your communication to privacy@salescoachondemand.com.
7. The
right to data portability
You may have rights to obtain and reuse your Personal
Data for your own purposes across different services. For example, if you
decide to switch to a new provider of services like the Services from Company
that you subscribed to, this enables you to move, copy, or transfer your
Personal Data.
HOW TO EXERCISE YOUR RIGHT: Company may have or may
in the future provide you with the ability to download your Personal Data. If Company
has done so, please use these functions to obtain a copy of your Personal Data
. If Company has not enabled this functionality, and if you want Company to
export your Personal Data for portability, please direct your communication to privacy@salescoachondemand.com).
(NOTE: Company will retain and continue to process
your Personal Data unless you also request to be forgotten or request
restricted or blocked processing.)
8. The
right to lodge a complaint
You have the right to lodge a complaint about the way
we handle or process your Personal Data with your national data protection
regulator (GDPR/UK) or applicable state regulator (under CCPA/CPRA or other
state law). However, we hope you will contact Company first (privacy@salescoachondemand.com) so Company can
try to address your complaint directly.
HOW TO EXERCISE YOUR RIGHT: If you want to lodge a
complaint with Company, please direct your communication to privacy@salescoachondemand.com.
9. The
right to withdraw consent
If you have given your consent to anything we do with
your Personal Data, you have the right to withdraw your consent at any time.
This includes your right to withdraw consent to us using your Personal Data for
marketing purposes.
HOW TO EXERCISE
YOUR RIGHT: If you want Company to withdraw your consent to process your
Personal Data, please either use out functionality in the Sites to make such a
request, or if we have not enabled such functionality, direct your
communication to privacy@salescoachondemand.com).
10.
The right to be free from discrimination for exercising your rights.
We cannot deny goods or services, charge you a
different price, or provide a different level or quality of goods or services
just because you exercised your rights under Data Privacy Laws. However, if
you refuse to provide your Personal Data to us or exercise one of your rights,
for example, to delete your Personal Data or restrict its processing, and that
Personal Data or processing is necessary for us to provide you with services,
we may not be able to complete that transaction and we may terminate your access
to the Services.
You may report any claim that we have engaged in
discrimination against you to an applicable regulator, though we would prefer
that you first contact us at privacy@salescoachondemand.com so that we may
address your concern.
B. Notice regarding
costs to exercise rights.
First, to the extent Data Privacy Laws requires us to
take an action without charging you, we will comply with those legal
requirements. In some cases we may be permitted to charge for some of these
services. We usually act on requests and provide Personal Data free of charge,
but in such cases we may charge a reasonable fee to cover our administrative
costs of providing the Personal Data, which such costs can arise in one or more
of the following cases, which are not meant to express all the instances in
which we may charge a fee:
Baseless or excessive/repeated
requests, or
Further copies of the same Personal
Data.
Alternatively, we also may be entitled to refuse to
act on the request. Please consider your request responsibly before submitting
it. We will respond as soon as we can. Generally, this will be within one month
from when we receive your request but, if the request is going to take longer
to deal with, we will come back to you and let you know.
C. Company’s
Retention of Personal Data Under Data Privacy Laws.
We only retain your Personal Data for as long as is
necessary for us to use your information as described above or to comply with
our legal obligations and legitimate interests. Please be advised that this
means that we may retain some of your Personal Data after you cease to use our
Services. For instance, we may retain your data as necessary to meet our legal
obligations, such as for tax and accounting purposes.
Our service is not a backup service. We dot assume an
obligation to retain your information.
When determining the relevant period in which we
retain or establish/revise periods for retaining Personal Data, we will take
the following factors into account:
Our contractual obligations and rights in relation to
the information involved, including contractual obligations we may owe to our
customer;
Legal obligation(s) under applicable law to retain
data for a certain period of time or with respect to pending or anticipated
legal actions;
Our legitimate interest where we weigh your interest
in controlling your Personal Data and against our lawful purpose in processing
your Personal Data;
Statutes of limitations under applicable law(s);
If you have made a request to have your information
deleted; and
Guidelines issued by relevant data protection
authorities.
Otherwise, pursuant to Data Privacy Laws, we will
securely erase your Personal Data once there is no lawful basis or legal
obligation to store or process it.
D. Data Security.
We have implemented measures designed to secure your Personal
Data from accidental loss and from unauthorized access, use, alteration, and
disclosure. All information you provide to us is stored on our secure servers.
The safety and security of your information also
depends on you. Where we have given you (or where you have chosen) a password
for access to certain parts of our Sites, you are responsible for keeping this
password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the
Internet is not completely secure. Although we take reasonable effort to secure
your Personal Data, we cannot guarantee the security of your Personal Data
transmitted to our Sites or via our Services. Any transmission of Personal Data
is at your own risk. We are not responsible for circumvention of any privacy
settings or security measures contained on the Sites or via the Services.