1. Policy
It is the policy of GeoLearning, Inc. (collectively, "GeoLearning") to comply with all applicable privacy and data protection laws. This policy reflects the importance we place on earning and keeping the trust of our employees, customers, and others who share their personal information with us.
2. Scope
This policy applies to all employees of GeoLearning and covers all personal information processed by www.geolearning.com, whether it relates to internal or external data subjects, and no matter where it is processed.
3. Effective Date
This policy is effective as of January 6, 2009.
4. Definitions
"Data subject" generally means a natural person who can be individually identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity. Note, however, that in certain countries, for example, Switzerland and Italy, the term "data subject" may also refer to legal entities.
"Personal Information" means an individual's first name or last name in combination with any one or more of the following data elements:
- social security number, drivers license number, or any other government-issued identification number
- birth date
- race/national origin
- sex
- address
Personal information does not include information that is lawfully obtained from publically available resources, or from federal, state, or local government records lawfully made available to the general public.
"Processing" of personal information means doing anything with personal information, whether or not by automatic means, such as collecting, recording, organizing, storing, adapting, altering, retrieving, consulting, using, disclosing, transmitting, disseminating, accessing or providing access to, combining, erasing, or destroying personal information.
6. Responsibilities of GeoLearning Employees
All GeoLearning businesses and functions must review their data practices in light of this policy and establish and maintain procedures to implement this policy.
All employees of GeoLearning must comply with all applicable privacy and data protection laws, this policy, and all related GeoLearning polices and procedures.
7. Adherence to U.S. Safe Harbor Principles
GeoLearning adheres to and will comply with the U.S. Safe Harbor Principles, including the relevant guidelines provided in the U.S. Safe Harbor Frequently Asked Questions.
8. Privacy Principles
Although privacy and data protection laws vary from country to country, most are based on the following privacy principles. Accordingly, to assure compliance with all applicable data protection laws and achieve consistency across the organization, GeoLearning will adhere to the following privacy principles at least to the extent required by applicable law:
Limitations on the Collection, Use and Disclosure of Personal Information
Notice and Consent — We will collect and process information fairly and lawfully, and where appropriate, with the knowledge or consent of the data subject. The type of notice or consent required will depend on the context and the circumstances, the sensitivity of the personal information, the data subject's reasonable expectations, and legal requirements.
- Specific Purpose — We will collect and process personal information only for specified, limited and legitimate purposes.
- Limitations on Use — We will not process personal information in a manner inconsistent with the purposes for which it was originally collected without first obtaining the data subject's consent. The type of consent required will depend on the context and the circumstances, the sensitivity of the personal information, the data subject's reasonable expectations, and legal requirements.
- Data Proportionality — The personal information we collect will be relevant, adequate and not excessive for the purposes for which it is collected or to which the data subject subsequently consents.
- Direct Marketing — We will not use personal information for direct marketing purposes without the data subject's consent. The data subject's consent may be express or implied, "opt-out" or "opt-in," depending on the circumstances and legal requirements.
- Automated Decisions — We will not make decisions based solely on automated processing of personal information except as permitted by applicable law.
- Transfers to Third Parties
- We will disclose personal information to third parties (including our affiliates) only for purposes consistent with those for which the personal information was originally collected or to which the data subject has subsequently consented. We will take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party.
- Before we transfer personal information to a third party to use for its own marketing purposes, we will obtain the data subject's consent. The data subject's consent may be express or implied, "opt-out" or "opt-in," depending on the circumstances and legal requirements.
- There may be exceptions to these general rules, depending on applicable law, if, for example, the disclosure is required by court order, to comply with a law, to prevent a crime, to enforce a legal right.
- Transfers to Other Countries — We will take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is transferred from one country to another, including transfers among affiliates. If required by law, we will first obtain the data subject's consent to the transfer. In such cases, the type of consent required will depend on the context and the circumstances, the sensitivity of the personal information, the data subject's reasonable expectations, and legal requirements.
Management of Personal Information
- Quality — We will take appropriate steps to ensure that personal information is accurate and reliable for its intended use and, where necessary for its intended use, kept up-to-date.
- Access — We will maintain procedures to give data subjects appropriate access to their personal information and, when appropriate, an effective means to have their personal information corrected or deleted.
- Security — We will implement reasonable administrative, physical and technological security measures to protect personal information from unauthorized access, unauthorized use, and unauthorized or accidental destruction, modification or disclosure. We will provide a level of security appropriate to the risks and the sensitivity of the personal information.
- Retention — We will not keep personal information in a form that permits identification of data subjects for longer than is necessary for the purposes for which it was collected or to which the data subject has consented, except for legitimate purposes permitted by law, such as regulatory compliance.
Accountability and Enforcement
- Accountability — We will designate data subjects within GeoLearning to be accountable for compliance with privacy and data protection laws, this policy, and related procedures.
- Enforcement — We will provide internal controls for verifying compliance with privacy and data protection laws, this policy, and related procedures.
- Complaint Process — We will provide a fair process for investigating and resolving complaints and objections regarding our data practices and will take appropriate steps to communicate our process to the data subjects who entrust their personal information to us.
GeoLearning Privacy Statement
Effective as of January 6, 2008
GeoLearning, Inc. ("Geolearning.com" or the "Company") is committed to protecting the privacy of your information. This Privacy Statement describes GeoLearning's information practices.
GeoLearning abides by the EU Safe Harbor Framework as outlined by the U.S. Department of Commerce and the European Union. For more information on the EU Safe Harbor Framework, please visit http://www.export.gov/safeharbor/.
GeoLearning.com will respond to your request to access or delete personal information within 30 days as is required under the EU Safe Harbor program.
TRUSTe
GeoLearning is a Participant in the TRUSTe Privacy Seal Program. TRUSTe is an independent organization whose mission is to advance privacy and trust in the networked world. As this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices monitored for compliance by TRUSTe.
If you have questions or concerns regarding this statement, you should first contact us at privacy@geolearning.com. If you do not receive acknowledgment of your inquiry, or if your inquiry has not been satisfactorily addressed, you should then contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with the Web site to resolve your concerns.
Questions regarding this Privacy Statement or the information practices of the Company's Web sites should be directed to GeoLearning Privacy by e-mailing privacy@geolearning.com or mailing GeoLearning Privacy, 4600 Westown Parkway, Suite 301, West Des Moines, IA 50266.
1. Web Sites Covered
This Privacy Statement covers the information practices of Web sites that link to this Privacy Statement: www.geolearning.com
GeoLearning's Web sites may contain links to other Web sites. GeoLearning is not responsible for the information practices or the content of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.
2. Personal Information Collected
GeoLearning offers a variety of services that are collectively referred to as the "Service." GeoLearning collects information from individuals who visit the Company's Web sites ("Visitors") and individuals who register to use the Service ("Customers").
When expressing an interest in obtaining additional information about the Service or registering to use the Service, GeoLearning requires you to provide the Company with contact information, such as: first name, last name, title, organization, address, city, state/province, zip/postal, country, phone, e-mail, total # of employees in your organization ("Required Contact Information").
As you navigate the Company's Web sites, GeoLearning may also collect information through the use of commonly-used information-gathering tools, such as cookies and log files ("Web Site Navigational Information"). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol ("IP") address, and the actions you take on the Company's Web sites (such as the Web pages viewed and the links clicked). For additional information about GeoLearning's collection of Web Site Navigational Information, please see Section 4 of this Privacy Statement.
3. Use of Information Collected
The Company uses Data about GeoLearning Customers to perform the services requested. For example, if you fill out a "Contact Me" Web form, the Company will use the information provided to contact you about your interest in the Service.
The Company may also use Data About GeoLearning Customers for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in GeoLearning's products, the Service, and to send you information regarding the Company and its partners, such as information about promotions or events.
GeoLearning uses Web Site Navigational Information to operate and improve the Company's Web sites. The Company may also use Web Site Navigational Information in combination with Data About GeoLearning Customers to provide personalized information about the Company.
In some instances, we share postal addresses of visitors with authorized partner organizations. However, we DO NOT share direct contact information such as e-mail addresses, phone numbers or fax numbers with any third parties. To request that your postal address not be shared with authorized partner organizations, send your request to
privacy@geolearning.com. Information concerning individuals' usage of our site will not be disclosed to third parties except in aggregate form such that your information will not be personally identifiable.
GeoLearning acts as a "data processor" with respect to much of the personal information it receives from the European Economic Area. A "data processor" is an entity that processes personal information on behalf of a data controller. A "data controller" is an entity that determines the purpose and means for processing personal information.
When GeoLearning receives personal information from the European Economic Area as a "data processor," GeoLearning protects the personal information in accordance with the terms of the contract between GeoLearning and the "data controller" and the relevant Safe Harbor Principles.
European Economic Area
Please note that your personal information will be transferred outside the European Economic Area for the purposes of processing by GeoLearning and its affiliates. By using the GeoLearning Web site and providing your personal information, you consent to this transfer.
For additional information about the Company's use of Web Site Navigational Information, please see section 4 of this Privacy Statement.
4. Web Site Navigational Information
GeoLearning uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company's Web sites ("Web Site Navigational Information") . This section describes the types of Web Site Navigational Information the Company may collect and how the Company may use this information.
Cookies
GeoLearning uses cookies to make interactions with the Company's Web sites easy and meaningful. When you visit one of the Company's Web sites, GeoLearning's servers send a cookie to your computer. Standing alone, cookies do not personally identify you. They merely recognize your Web browser. Unless you choose to identify yourself to GeoLearning, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a "Contact Me" or a "Send me a White Paper" Web form), you remain anonymous to the Company.
There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.
If you have chosen to identify yourself to GeoLearning, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Service, a session cookie containing an encrypted, unique identifier that is tied to your account is placed in your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Service and to process your online transactions and requests. Session cookies are required to use the Service.
GeoLearning does not employ the use of persistent cookies.
IP Addresses
When you visit GeoLearning's Web sites, the Company collects your Internet Protocol ("IP") addresses to track and aggregate non-personally identifiable information. For example, GeoLearning uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company's Web sites.
GeoLearning also collects IP addresses from Customers when they log into the Service as part of the Company's "Identity Confirmation" security features.
Third Party Cookies
From time-to-time, GeoLearning engages third parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit the Company's Web sites. GeoLearning may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it. This Privacy Statement does not cover the use of third party cookies.
5. Public Forums, Refer a Friend, and Customer Testimonials
We post customer testimonials on our web site, which may contain personally identifiable information such as the customer's name. We do obtain the customer's consent prior to posting the testimonial to post their name along with their testimonial.
If you want to remove your personal information that is being displayed on our website under public pages please send your request to unsubscribe@geolearning.com
6. Sharing of Information Collected
GeoLearning may share Data About GeoLearning Customers with the Company's agents so that these agents can contact Customers and Visitors who have provided contact information on our behalf. GeoLearning may also share Data About GeoLearning Customers with the Company's agents to ensure the quality of information provided. GeoLearning does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes.
GeoLearning reserves the right to disclose personally identifiable information of the Company's Customers or Visitors if required by law or if the Company reasonably believes that disclosure is necessary to protect the Company's rights and/or to comply with a judicial proceeding, court order, or legal process.
7. Communications Preferences
GeoLearning offers Customers and Visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking unsubscribe@geolearning.com or by clicking on the "unsubscribe" link located on the bottom of the Company's marketing emails. Additionally, you may send a request specifying your communications preferences to unsubscribe@geolearning.com.
8. Correcting and Updating Your Information
To discontinue marketing messages and information please contact GeoLearning at unsubscribe@geolearning.com. To update your information please e-mail webmaster@geolearning.com
9. Security
GeoLearning uses robust security measures to protect Customer Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Customer Data. GeoLearning implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Web sites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.
10. Changes to this Privacy Statement
If we decide to change our privacy policy or statement, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.
