Last Modified: December 10, 2015
PRIVACY CERTIFICATION: U.S.-EU SAFE HARBOR FRAMEWORK
INFORMATION WE COLLECT
When you use our Services, you may provide GrowthPlay with two main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you use our Services. We collect information from you when you (a) use and/or access our Services, (b) open and/or respond to our emails, (c) contact GrowthPlay, (d) visit any page online that displays our content, (e) purchase assessments and/or services through our Services, and/or (f) provide information to any of our vendors.
Personally Identifiable Information You Choose to Provide
We may ask for certain personal information from you for the purpose of providing to you content and/or services that you request. We collect personal information such as your: (i) contact information (including name, telephone number, email, title, and job position); (ii) employment content (including information, text and/or other materials) submitted by you; (iii) financial information (such as credit card number, expiration date, verification number and billing address); (iv) data from assessments and responses to questions related to individual competencies (including performance); (v) contact information of employees or others you share with us; (vi) demographic information (including age, birthdate and gender); (vii) location information (such as geographic location of the device you are using) and (viii) preferences, feedback and behavior (such as reports and performance rates). Once you register, you have opted in to receive electronic communications from GrowthPlay. GrowthPlay may also provide you with the opportunity to participate in surveys through our Services. If you participate, we will request certain personally identifiable information. Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.
Non-Personally Identifiable Information We Collect
Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
Aggregate: We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual. We may share user information in the aggregate with third parties.
Analytics: GrowthPlay uses analytic software to gather statistics and usage trends for product and service improvement purposes. Our Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.
Other Tracking Technologies: We may supplement information you provide to us with information from other sources, such as information to validate and/or update your address and/or other demographic information. This information is used to maintain the accuracy of information on our Services and for internal analysis. We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further used to track online movements of our users. In contrast to Cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to your personally identifiable information.
HOW WE USE THAT INFORMATION
- operate, maintain and improve our Services;
- answer questions and respond to your requests;
- perform analytics and conduct research;
- send you reminders, support and marketing messages;
- manage our administration of the Services;
- improve the design and content of our Services
- participate in one of our surveys or other forms of customer research;
- facilitate and process employment assessments; and
- analyze programs, products and services we offer.
The information collected in the aggregate enables GrowthPlay to better understand your use of the Services and to enhance your enjoyment. We may use financial information to process payment, enroll you in one of our accounts and/or other related services in which you elect to participate. If you use the Services, you agree to receive certain communications from us including but not limited to the following:
Special Offers, Newsletters and Updates. We will occasionally send you information on products, special deals, promotions and newsletters. You can sign up for these emails from us at any time. Out of respect for your privacy, you may elect not to receive these types of communications by contacting us or replying to our emails.
Blogs. Our Service may have links or access to publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect.
Parties with whom we may share your information:
What happens in the event of a change of control:
If we sell or otherwise transfer part or all of GrowthPlay or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.
YOUR INFORMATION CHOICES
Depending on the situation, GrowthPlay may obtain consent to the collection of personal information in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of our assessments and related services, or when you approach us to obtain information, inquire about or request services from us. We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to GrowthPlay, and you can limit the communications that GrowthPlay sends to you. If you visit our Services and volunteer personally identifiable information, you can opt out of receiving notifications, and you may review, modify, update, and/or delete such personally identifiable information by contacting and/or by changing your preferences on the Service. Please be aware that even after your request for a change is processed, GrowthPlay may, for a time, retain residual information about you in its backup and/or archival copies of its database. Please be aware that we may still email you non-commercial emails related to your account and your transactions through our Services. Following termination of Services, GrowthPlay may retain information (including without limitation your profile information) for a commercially reasonable time for backup, archival, and/or audit purposes. In some cases, if you choose not to provide GrowthPlay with requested information, you may not be able to use and/or access all of our Services.
Your California Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to receive: (a) information identifying any third party companies to whom GrowthPlay may have disclosed personal information to for direct marketing, within the past year; and (b) a description of the categories of personal information disclosed. To obtain such information, please email your request to email@example.com and we will provide a list of categories of personal information disclosed within thirty (30) days of receiving such a request. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above.
SERVICE ELIGIBILITY AND CHANGES
Children and Minors. GrowthPlay does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information, please contact us at firstname.lastname@example.org. By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Services.
We work hard to secure your personal information from unauthorized access to and/or unauthorized alteration, disclosure and/or destruction of information we hold. GrowthPlay has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Because the internet is not a completely secure environment, GrowthPlay cannot warrant the security of any information you transmit to GrowthPlay or guarantee that information on the Services may not be accessed, disclosed, altered and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. Please do your part to help GrowthPlay. You are responsible for maintaining the secrecy of your account information, and for controlling access to emails between you and GrowthPlay, at all times. Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing our Services. We are not responsible for the functionality, privacy and/or security measures of any other organization.
OTHER WEB SITES AND SERVICES
SAFE HARBOR COMPLIANCE
Personal information may be transferred abroad (including outside the EU for our users in the EU) in connection with GrowthPlay’s provision of hosted application services and related support services to our customers. GrowthPlay strives to collect and use personal information in a manner consistent with the laws of the countries in which we do business and is self-certified to U.S. – EU Safe Harbor Frameworks developed by the U.S. Department of Commerce in coordination with European Commission. For more information, see http://www.export.gov/safeharbor/. GrowthPlay is committed to cooperating with the European Data Protection or their authorized representatives in accordance with applicable law.
DATA INTEGRITY AND ACCESS
GrowthPlay will only process personal information in a way that is set forth herein and relevant for the purpose for which it was collected and/or authorized by you. Upon request, we will grant you reasonable access to personal information that we hold about you. For security purposes, GrowthPlay may require verification of identity before providing access to personal information.
GrowthPlay will offer users in the E.U. whose personally identifiable information has been transferred to the United States the opportunity to opt out from: (a) the disclosure of personally identifiable information to a non-agent third party; and (b) the use or disclosure of personally identifiable information for a purpose other than the purposes for which the information originally was collected or subsequently authorized by the individual or a compatible purpose. If GrowthPlay were to receive “sensitive personal information” (which includes, without limitation, personal information specifying medical and/or health conditions, racial and/or ethnic origin,), GrowthPlay will request and obtain affirmative consent before disclosing such information to a non-agent third party and before using such information for a purpose other than the purpose originally disclosed and/or a compatible purpose. GrowthPlay will provide you with reasonable mechanisms to exercise your choices should such circumstances arise. GrowthPlay will make sure that any third party receiving personal information subscribes to the Safe Harbor principles and/or is subject to law providing the same level of privacy protection as is required by GrowthPlay and agree in writing to provide an adequate level of privacy protection.
HOW TO CONTACT US