Last updated: January 28, 2019
IF YOU ARE A USER WHO HAS SUBSCRIBED AS PART OF A CORPORATE ACCOUNT PROVIDED BY YOUR EMPLOYER OR ANOTHER THIRD PARTY (“ADMINISTRATOR”) AND/OR WHO HAS PROVIDED US WITH EMERGENCY CONTACT DETAILS, WE MAY SHARE LIMITED PARTS OF YOUR PERSONAL INFORMATION TO SUCH ADMINISTRATOR OR EMERGENCY CONTACT AS EXPRESSLY SET OUT IN THIS POLICY.
The Service may include analysis of indicators of whether users are at risk of jeopardizing or harming their own safety. Where an emergency contact is specified in your account, that contact may be notified if the service indicates that you are or were at risk of jeopardizing or harming your own safety, and if you were referred to an appropriate service (EAP, national crisis line, etc.). Specific details about of your distress in those circumstances will not be communicated to the contact.
The Services are not intended for persons under 18 years of age and members of the Services must be 18 or older. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on this Site or on or through any of its features/register on the Site or App, make any purchases through the Services, use any of the interactive or public comment features of the Services or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of information from and about users of our Services, including information by which you may be personally identified (either directly or indirectly), and other information which is connected to that information. Together this forms “personal information” about you. We collect this information:
- Directly from you when you provide it to us (such as through the registration process, responses to questionnaires and surveys, interaction with the App etc.);
- Automatically through the use of the Services through the App; information collected automatically through the App may include usage details, operating system, type, duration, time, manner and location of usage, IP addresses, and information collected through cookies and other tracking technologies;
- Automatically as you navigate through the Site; information collected automatically through the site may include usage details, IP addresses, and information collected through cookies and other tracking technologies;
INFORMATION YOU PROVIDE TO US
The information we collect on or through the Services may include:
- Information that you provide by subscribing for courses, completing course materials, or responding to psychometric evaluations, wellness checks, survey or questionnaires on our Site or App. This includes information provided at the time of registering to use our Site or App, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with our Site or App.
- Records and copies of your correspondence (including email addresses), if you contact us or if you contact others through the Services (such as through messaging functions).
- Details of transactions you carry out through our Site or App (including without limitation ) and of the fulfillment of your orders. You may be required to provide financial information such as credit card details before placing an order through our Site or App (for example, through third party payment providers such as Stripe).
- Your search queries on the Site or App.
- Information you provide to us about other individuals
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with our Site or App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, geolocation and workplace usage patterns, including:
- Details of your visits to our Site or App and other communication data and the resources that you access and use on the Site or App.
- Information about your computer and Internet connection, including your IP address, operating system and browser type.
- We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
- When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, geolocation data, and other communication data and the resources that you access and use on or through the App.
- We may collect information about your mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
We and our third party service providers may collect information about you in a variety of ways. We and/or our third party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Service.
When you visit our website or otherwise interact with the Service we (or third party data or ad networks we work with) may send one or more “cookies” to your computer or other devices. Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites. Some features on this site will not function if you do not allow cookies. We may link the information we store in cookies to any Personal Information you submit while on our site.
Functional cookies, persistent and session type, store information to enable core site functionality.
Analytics cookies allow us to count
page visits and traffic sources so we can measure and improve the performance
of our site and our marketing campaigns.
Advertising cookies may be set through our website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.
We (or third party data or ad networks we work with) may use Web Beacons alone or in conjunction with cookies to compile information about our Service, or other information we or they have collected. Web Beacons are tiny graphic objects that are embedded in a web page or email and are usually invisible to the user but allow checking that a user has viewed the page or email. Web Beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by Web Beacons to our Users’ Personal Information. For example, we use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
Flash and HTML5 Storage
We use Local Shared Objects, such as Flash cookies, AND/OR Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
Do Not Track Signals
At this time we do not respond to browser ‘do not track’ signals.
We use this information to track and aggregate Other Information to analyze trends, administer the site, track users’ movements around the Service and to gather demographic information about our user base in the aggregate.
HOW WE USE YOUR INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where our Platform strongly indicates that there is a significant concern about your wellbeing for which external assistance may be advisable for your benefit;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us sing the contact details set out below
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new user||(a) Identity|
|Performance of a contract with you|
|To process and deliveryour order includin:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Identity |
(e) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to recover debts due to us)
|To monitor your satisfaction with your role and your mental health, which may include: Notifying your emergency contact or your Administrator if there is a significant concern regarding your mental health and wellbeing, in which case only limited information will be disclosed to such person, a may be determined by DoctoRevolution in accordance with good industry practice||Identity;Contact|
| To manage our relationship with you which will include: |
(b) Asking you to leave a review or take a survey
|(a) Identity |
(d) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity |
(e) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
|To administer and protect our business, Website and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity |
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) |
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity |
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||(a) Technical |
|Necessary for our legitimate interests (to define types of customers for our services, to keep our Website and App updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||(a) Identity |
|Necessary for our legitimate interests (to develop our services and grow our business|
|To register your presence in a Workplace|| (a) Identity |
|(a) Performance of a contract with you (b) Necessary to comply with a legal obligation|
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.
We may also use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria and may combine your information with other profile data it has obtained from other sources.
Lawful basis for processing.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us sing the contact details set out below.
Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.
- 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site or App users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us to you when you provide the information.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our terms of service https://doctorevolution.org/program-terms-conditions/
- and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CNK, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Service Provider – Articulate Online
TRANSFERS OF DATA
We use cloud-hosting service providers to provide hosting to us which means that your personal information may be available to foreign government or its agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your personal information. As privacy laws vary from jurisdiction to jurisdiction, the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident. However, we will ensure that a similar degree of protection is afforded to your personal information as is provided for under European Union law if you are located in the EU.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers. If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org or by following the opt-out instructions in any promotional communication we send to you. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to email@example.com.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.
TRANSFERS OF DATA
You can review and change your personal information by logging into the Site or App and visiting your account profile page.
You may also send us an email at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
SAFETY AND SECURITY
We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers.
If you make a purchase on our site, we use a third party payment processor such as Stripe. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.
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 Site or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site or App like message boards. The information you share in public areas may be viewed by any user of the Services.
Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site or App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or App.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal information. You may have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
CONTACT INFORMATION AND REQUESTS
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.