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MindLeaders Privacy Policy

MINDLEADERS, INC. (“MindLeaders”)
Effective 2/2011, Updated 6/2012

Applicability of Privacy Statement:

We at MindLeaders recognize the importance of protecting the privacy of our customers and other visitors to our website. We collect the narrowest class of personal information required to effectively serve our customers and accomplish our mission; we protect this personal information according to the rigorous standards set forth by the European Union Safe Harbor Program.

MindLeaders has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s Program Requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at legal@mindleaders.com. If you are not satisfied with our response you can contact TRUSTe here.

This Privacy Policy sets out the privacy practices used by MindLeaders in the collection, processing, and storage of Personal information. This Privacy Policy covers www.mindleaders.com and other websites operated by MindLeaders (“Websites”), MindLeaders Product Platforms, and the MindLeaders Facebook Application.

MindLeaders complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. MindLeaders, Inc has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view MindLeader’s certification, please visit http://www.export.gov/safeharbor/.

If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by clicking here, or by fax at 415-520-3420 or mail to TRUSTe Safe Harbor Compliance Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, click here or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.

THE INFORMATION ABOUT YOU COLLECTED ON THIS WEBSITE, PLATFORM OR APPLICATION IS SUBJECT TO THIS PRIVACY POLICY. BY DISCLOSING INFORMATION TO US, YOU AGREE TO THE TERMS OF THE POLICY.

Information Collection and Storage of Personal Information

When you visit our websites, platform and applications, MindLeaders may collect information in two ways: through information automatically gathered from your computer or through information you voluntarily provide at a website, platform or application. As to automatically gathered information, MindLeaders collects navigational information about where visitors go on our website, how many visits are made to the site, when the site is visited and other non-personal information (for example, this can include domain type, browser version, service provider, IP address).

Voluntarily provided information is collected online when you register for our services or purchase our products. Whenever you register for our services or purchase our products, we will collect personal information such as your name, e-mail address, mailing address, company and phone number, as well as any billing information or specific comments or questions that you provide. Additionally, your contact information may be entered into our platform by a third party on your behalf in order to provide the service for you. This personal information will only be used for the purpose for which it was intended. We also offer general “contact us” features on our website, in which you will be asked to provide your name and e-mail address to request information or be contacted by a sales agent. We may also collect additional information in connection with events, special offers, contests, specialized products, or other promotions. As used herein, “Data” or “Personally Identifiable Information” refers to this class of information.

The following is a list of the Data that may be collected by automatic or voluntary means or in connection with events, special offers, contests, specialized products, or other promotions:

  • (a) name;
  • (b) gender;
  • (c) job title;
  • (d) profession;
  • (e) contact information such as email addresses and telephone numbers;
  • (f) demographic information such as post code, preferences and interests;
  • (g) financial information such as credit / debit card numbers;
  • (h) IP address (automatically collected);
  • (i) web browser type and version (automatically collected);
  • (j) operating system (automatically collected);
  • (k) a list of URLs starting with a referring site, your activity on this website, and the site you exit to (automatically collected);
  • (l) Cookie information (see “Cookies” section below);
  • (m) information about your interest in MindLeaders products or services;
  • (n) information about your interest in receiving newsletters or being contacted by a sales representative;
  • (o) information provided in connection with the registration of your organization for certain products and services provided by MindLeaders;
  • (p) information about other transactions that you or your organization may enter with MindLeaders;
  • (q) any other Personal Information you or your company may disclose to MindLeaders through an online form or email.

By voluntarily entering Data you enable MindLeaders to store, process and transmit this Data and provide you with the services you select. Please be aware that if you choose not to submit the information requested, you may be limited in your use of the website and its services.

Use of Collected Information:

The navigational information that is automatically gathered when you visit our website(s) is used on an aggregate basis to evaluate the effectiveness of the website(s), analyze trends and administer the site(s). This navigational information allows us to determine such things as which areas of our website are most visited and difficulties visitors may experience in accessing the site. MindLeaders does not associate any navigational information with individual users.

Any personal Data you submit will be retained by MindLeaders for as long as you use the Services and Systems provided by the website. We will retain your information for as long as your account is active or as needed to provide you services. Data that you may submit through any communications System that we may provide may be retained for a longer period. If you wish to cancel your account, delete your data or request that we no longer use your information to provide you services, contact us as described herein. We will respond to your request within 30 business days. You should also be aware that we may disclose specific personal Data if necessary to do so by law, or based on our good faith belief that it is necessary to conform or comply with the law, or if necessary to protect the users of our website, the site, or the public. All personal Data is stored securely in accordance with applicable principles of EU data protection legislation.

This information is used:

  • to deliver the service or product you requested;
  • to enable billing and shipping;
  • to provide you with information about related products and services;
  • to improve our website;
  • to better administer and troubleshoot our systems;
  • for internal record keeping;
  • to improve of our products / services;
  • to transmit by email or standard mail promotional materials that may be of interest to you;
  • for market research purposes which may be done using email, telephone, fax or mail (such information may be used to customize or update the website);
  • to process employment applications submitted via the website.

MindLeaders does not sell, rent or trade the information you voluntarily provide to us on this website to unrelated third parties for promotional purposes. We may use third parties to help us monitor site activity, and to respond to your requests for specific information or provide support for products. If personal information (for example, name, address, e-mail address, telephone number) is provided to any of these third parties, we will require that such information be maintained by them in confidence and according to the same standards set out in the EU Safe Harbor Program and US-Swiss Safe Harbor Framework. We will not share this information with any other person, company or organization, except to third parties providing products or services to you pursuant to your agreement with MindLeaders, and as may be required by law. Unless otherwise stated elsewhere, information concerning an individual’s usage of our sites will not be disclosed to third parties except in aggregate form such that your information will not be personally identifiable. For more details on processing and storage, see “Security” and “Location” sections below.

If you receive a promotional communication from us, you will be able to unsubscribe by following the instructions in the email.

External Sites/ Links:

As a service to you, our site may feature links to external websites. MindLeaders is not responsible for the privacy practices or the content of any external websites. Accordingly, we recommend that you review the privacy policy of any external websites that you may enter from our site.

Cookies and Tracking Technologies:

MindLeaders and third parties use a browser feature known as a cookie which assigns a unique identification to your computer. Cookies are typically stored on your computer's hard drive and are used by MindLeaders to help track clicks as you move through pages within the MindLeaders website. Cookies may also be used to determine browser plug-ins so that we may optimize your experience on our site. With most Internet browsers, you can erase Cookies from your computer hard drive, block all Cookies or receive a warning before a Cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. MindLeaders' cookies are linked to personally identifiable information.

We use a third-party tracking service that uses other tracking technologies such as web beacons, scripts, and images to track non-personal information about visitors to our site in the aggregate.

Sharing of Information:

If you choose to submit information to a website blog or discussion forum, the information submitted will be deemed public information and will not be considered confidential or treated by MindLeaders as other personal information you specifically provide to MindLeaders and which is subject to this Policy. We are not responsible for the personal information you choose to submit in these forums. We also have testimonials on our site, for which the individuals have given permission for us to post their personal information. To request removal of your personal information from our blog or community forum, contact us at legal@mindleaders.com.

Please refer to our Terms of Service for more information regarding user generated content.

Changes of Business Ownership and Control:

MindLeaders may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you. In the event of such transfer, sale or assignment, a notice will be posted on our website notifying all Users of the change.

Security:

MindLeaders limits access to the personal information collected at this website to employees and service providers with a valid business need for the information. Our employees are advised about the importance we place on privacy, and we hold our employees responsible for upholding our privacy standards. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. When purchasing an item from our storefront, we encrypt the transmission of that information using secure socket layer technology (SSL). In some cases, when you log into our platform, you may elect to have the transmission of that information using secure socket layer technology (SSL). In addition, certain types of data collected on our platform will always use secure socket layer technology (SSL).

Location:

Please note that your personal information will be transferred outside the European Economic Area for the purposes of processing by MindLeaders and its affiliates. MindLeaders has global hosting centers that store and process Personal information in various locations in the United States. MindLeaders takes reasonable precautions to protect Personal information in these centers and in other locations in the United States from loss, misuse and unauthorized access, disclosure, alteration, and destruction. MindLeaders also makes reasonable efforts to keep Personal information reliable for its intended use accurate, current, and complete. By using the MindLeaders website and providing your personal information, you consent to this transfer. If you are visiting MindLeaders from a location outside of the U.S., your connection will be through and to servers located in the U.S. Information you provide will be maintained in Web servers and internal systems located within the U.S.

Third Party Websites and Services:

MindLeaders may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising, email marketing and product support. The providers of such services do have access to certain personal Data provided by Users of this website. Any Data used by such parties is used only to the extent required by them to perform the services that MindLeaders requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with applicable data protection principles.

Users should always examine the privacy policies of third party websites before submitting personal data. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

Controlling Access to Your Data & Accessing Your Own Data:

Wherever you are required to submit Data, you will be given options to withhold information or restrict our use of that Data. This may include the following:

  • (a) use of Data for direct marketing purposes; and
  • (b) sharing Data with third parties.

You may access certain areas of the website without providing any Data at all. However, to use all Services and Systems available on the website you may be required to submit account information or other Data.

You may at any time object to the processing of Data for a particular purpose to which you had previously consented. In this case, please email legal@MindLeaders.com.

You may choose to stop receiving our newsletter by following the unsubscribe instructions included in these emails or you can click here to be removed.

You may review and approve the information about you collected upon registration in our customer database. Upon request, we will remove that information from our customer database or change/correct personal information that you state is erroneous. However, you should understand that information about you in our database might come from a number of sources, including orders placed by you and third party mailing lists.

You may access your account at any time to view, amend the Data, or to have any inaccuracies corrected. You may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and you may change this at any time by visiting http://www.MindLeaders.com/settings and following the instructions found there. MindLeaders strives to ensure that all information is accurate and up to date. However, should you discover any inaccuracies and wish to amend them, please contact us at legal@MindLeaders.com.

Notice, Access and Choice around Customer Data:

We assume that it is generally our customers, the “data controllers,” responsibility to notify individuals about the purposes for which they collect and use information about them, how they can contact you with any inquiries or complaints, the types of third parties to which they disclose your information, and the choices and means they offer you for limiting your use and disclosure. As your data processor, we make available to you this privacy policy so that you can better understand our data practices.

The U.S.-EU Safe Harbor and US-Swiss Safe Harbor requires that members offer end users a choice to opt out of uses and disclosures of their data that are incompatible with the purposes for which that data was originally collected or subsequently authorized. We operate under the assumption that it is the customer's obligation to obtain from their data subjects the appropriate consent to transfer their data to us and to process their data using our products for defined purposes. As your data processor, we will not share, sell, rent, or trade with third parties for their marketing purposes any data subject information shared with us.

The U.S.-EU Safe Harbor and US-Swiss Safe Harbor requires that data subjects must have access to personal information about them that an organization holds, and that they be able to correct, amend, or delete that information where it is inaccurate. We operate under the assumption that it is generally the data controller's obligation to provide their data subjects a means of accessing their data. If you would like the personal information we hold about you, the End User, deleted, please contact us as described below. We will respond to requests within 30 days of receipt. Also, please contact the data controller from whom you received the e-mail.

MindLeaders Facebook Application: Facebook Connect

If you are accessing MindLeaders through Facebook request for permission, you are authorizing us to store, collect, and use in accordance with this Privacy Policy any and all information that you agreed Facebook could provide to us through this action. The agreement takes place when you “accept” the application on Facebook.

The purpose of the application is to enable you to purchase and complete a training course, which has been developed in cooperation with Facebook. This training is embedded within an i-Frame on Facebook.

Personal Information such as name, email address, and credit card number are collected within the application is collected directly by MindLeaders. We share this information with third party service providers to provide payment services.

We do share information back with Facebook to perform this service such as:

(a) We will conduct a satisfaction survey of all users and these results will be shared with Facebook. For example, our survey will ask, “how satisfied are you with the training?” “how likely are you to recommend the training?” and “what suggestions do you have to improve the course?” These survey results will be shared with FB aggregated on country basis.

(b) We will provide basic user data for all users (e.g., email, attendance, completion status, price paid for training) to Facebook for internal use by Facebook. This data may be used by Facebook for its own internal purposes.

(c) We will ask you if you would like to post to your wall the fact that you have just completed the Facebook Trainer for Business course. By consenting to this request, you authorize MindLeaders to post and display your training completion status on your Facebook wall.

All of this information is shared to perform the function of taking the training course.

Questions/Changes in Policy:

If you have questions or concerns with respect to our Privacy Policy, you may direct those questions to us at the “Contact Us” section of this website. If elements of our Privacy Policy change, we will post the material policy changes in our Privacy Policy on this website prior to the change becoming effective. If you are concerned about how your personal information is used, please visit our site often for this and other important announcements about MindLeaders.

Questions regarding this policy should be directed to MindLeaders at legal@mindleaders.com, or write to MindLeaders, Inc. 5500 Glendon Court, Suite 200, Dublin, OH 43016, Attn: Privacy Officer.

ECDL and ICDL:

The European Computer Driving Licence® (ECDL) and the International Computer Driving Licence® (ICDL) are the registered trademarks of The European Computer Driving Licence Foundation Limited in Ireland and other countries. Presentation of the ECDL and/or ICDL logos above, signifies that the courseware material distributed through this website has been developed by MindLeaders and has received the approval of the ECDL Foundation Ltd.

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