Pryor Learning, LLC Privacy Notice
Last Updated/Effective Date: August 1, 2023
Pryor Learning, LLC, its affiliates and its subsidiaries (“Pryor Learning”, “we,” “us,” or “our”) respect your privacy. This Privacy Notice describes the processing of Personal Information (defined below) that is provided, collected, or shared on the sites, applications, social media pages, other platforms that link to this Privacy Notice (collectively, the “Site”), or in connection with the provision of products or services to you (the “Services”). It also describes rights you may have under applicable laws.
1. Personal Information We Collect
We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.
The types of Personal Information we collect may include:
• Contact Information – If you submit an inquiry, register for an account, or provide information on our Site or through our Services, we may collect your contact information. This may include your name, address, email address, demographic information, and phone number.
• Commercial information – This includes information about purchases, information about subscriptions, products and services you have shown interest in, payment processing information, and other commercial information.
• Usage Information – When you use our Site or Services, our servers may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, or other information regarding your interaction with the Site or Services.
• Communication Information – We may collect the contents of your communications with us, whether via e-mail, chat functionality, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality. We also may engage a third-party chatbot service provider. The chatbot service provider has its own privacy policies and procedures with regard to the collection and processing of your Personal Information.
2. How We Collect Your Personal Information
• Directly From You – For example, if you choose to contact us or request or purchase products, Services, or information from us.
• From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.
3. How We Use Personal Information
To the extent permitted by applicable law, we may use Personal Information to:
• operate the Site, provide the Services, and provide support to our business functions;
• fulfill customer requests or provide customer support;
• protect against criminal activity;
• protect or enforce our legal rights;
• send you information about our company or the Services;
• respond to reviews, comments, or other feedback provided to us;
• enhance, support, and personalize the Site and our advertising or marketing efforts;
• protect the security and integrity of the Site;
• develop new products or services
• engage in benchmarking, data analysis, or audits;
• meet our contractual requirements;
• market users for upselling and cross-selling purposes, which includes selling Personal Information;
• comply with applicable legal or regulatory requirements and our policies; and
• the extent necessary for any other lawful purpose for which the Personal Information is collected.
4. Sharing of Personal Information
We may share your Personal Information in the following circumstances:
• Business Partners – We may share Personal Information with trusted business partners or corporate affiliates. For example, we may share your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with. Additionally, with our approval, certain organizations have access to our customer list for marketing purposes. These organizations range from training providers, office suppliers, office equipment providers, business publications and other business service providers.
• Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Pryor Learning, its users, or the public against harm.
• Merger or Change of Control – If we are involved in a merger, acquisition, or any other transaction involving a change of control in our business including but not limited to a bankruptcy or similar proceeding, Personal Information may be transferred along with the business. Where legally required, we will give you prior notice prior to such a transfer.
• Service Providers – We share your Personal Information with third party service providers as necessary to enable them to support the Site, the Services, or other aspects of our business.
5. Cookies and Other Tracking Technologies
We collect Personal Information and other data from cookies, pixel tags, and tracking technologies. We allow or enable third parties to collect Personal Information in order to provide their interest-based advertising services.
We use analytics services, including Google Analytics, to assist us with analyzing our website traffic. These services utilize cookies and other technologies that collect your Personal Information. We share this analytic information with HubSpot and GoogleAdwords.
In order to manage your preferences with respect to these technologies, please visit our preferences page. In addition, most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time.
6. How Long Do We Keep Your Personal Information
We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
7. How We Protect Your Personal Information
We use commercially reasonable efforts to protect the confidentiality and security of Personal Information we collect and process. However, we cannot guarantee the security of Personal Information during its transmission to or from us, its storage on our systems, or that our security measures will prevent third parties from accessing or acquiring Personal Information we collect.
8. Your Choices and Controls
Depending on where you live, you may have the following rights with respect to your Personal Information:
|Notice||You may have the right have the right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.|
|Access||You may have the right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.|
|Data Portability||You may have the right to receive a copy of your information in a portable and readily usable format.|
|Erasure||You may have the right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.|
|Correction||You may have the right to request that we correct any incorrect Personal Information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your Personal Information from our records, unless an exception applies. We may deny your correction request if (a) we believe the Personal Information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.|
|Automated Decision Making||You may have the right to request information about the logic involved in automated decision-making and a description of the likely outcome of processes, and the right to opt out. We do not currently engage in any automated decision making practices.|
|To Opt Out of Sales or Sharing of Personal Information||To the extent we sell or share Personal Information, you may have the right to opt out of the selling or sharing of Personal Information; you can do so here.|
|Limit Use of Sensitive Personal Information||We do not use or disclose Sensitive Personal Information other than to provide our Service. However, if we used or disclosed Sensitive Personal Information for other purposes, you would have the right to limit certain uses of Sensitive Personal Information.|
Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.
We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.
You may only make a request for access or data portability twice within a 12-month period. The request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
To exercise any of the privacy rights afforded to you, please submit a request to us by one of the following methods:
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Notice which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.
9. Marketing Emails
To opt out of marketing emails, please email us at firstname.lastname@example.org Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our Services to you.
10. International Use of the Site
This Site is hosted in the United States. As a result, the Personal Information that we collect and generate about you as you use the Site may be transferred, stored, or accessed in a destination outside of your country which may have less strict, or no, data protection laws, when compared to the laws in your country.
11. Children’s Privacy
We do not knowingly collect or solicit any Personal Information from children under the age of sixteen. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information.
12. Links to Third-Party Websites
We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s Privacy Notice.
13. Notice to California Residents
California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act: This portion of this Section applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.
The categories of third parties to which we disclose Personal Information for a business or commercial purpose or to whom we sell or share Personal Information are summarized in the chart below, as well as the following Personal Information Pryor Learning has collected and disclosed the following Personal Information within the 12-month period preceding the Effective Date of this Privacy Notice:
|Categories of CA Personal Information We Collect||Categories of Third Parties to Which We Disclose Personal Information for a Business or Commercial Purpose||Categories of Third Parties to Which We May Sell or Share Personal Information|
|Identifiers||Advertising Networks; Social Networks; Third-Party Business Partners.||We do not sell this category of Personal Information. We do share this category of Personal Information with Advertising Networks, Social Networks and Third-Party Business Partners.|
|Personal Information, as defined in the California customer records law||Advertising Networks; Social Networks; Third-Party Business Partners.||We do not sell this category of Personal Information. We do share this category of Personal Information with Advertising Networks, Social Networks and Third-Party Business Partners.|
|Commercial Information||Third party vendors||We do not sell or share this category of Personal Information.|
|Internet or other similar network activity||Advertising Networks; Social Networks; Third-Party Business Partners.||We do not sell this category of Personal Information. We do share this category of Personal Information with Advertising Networks, Social Networks and Third-Party Business Partners.|
|Inferences drawn from other Personal Information||Advertising Networks; Social Networks; Third-Party Business Partners.|
|Professional or employment-related information||Advertising Networks; Social Networks; Third-Party Business Partners.|
We do not knowingly sell or share the Personal Information of minors under the age of 16.
California Shine the Light Act: Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us using the information in the Contact Us section below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
14. Changes and Accessibility
Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We will provide you with notice as required by applicable law if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the Site.
This Privacy Notice is available to consumers with disabilities. To access this Privacy Notice in an alternative downloadable format, please click here.
15. Contact Us
If you have any questions about our practices or this Privacy Notice, please contact us at email@example.com. You may also write to us at:
Pryor Learning, LLC
PO Box 219468
Kansas City, MO 64121