PRIVACY POLICY

Effective: May 25, 2018

INTRODUCTION

Our privacy policy will help you understand what information we collect at TALENTED, what TALENTED does with the information collected, and what choices you have as a Client or User in regards to the information collected on TALENTED.

By using the Service, you are expressing your agreement to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Service.

DEFINITIONS

TALENTED

When we talk about “TALENTED,” “we,” “our,” or “us” in this policy, we are referring to TALENTED, LLC., the company which provides the services.

THE SERVICE

When we talk about The “Service” or “Services” in this policy, we are referring to our online learning and skill development tools and platform. Our Services are currently available for use via a web browser or applications specific to your mobile device.

CLIENT

When we talk about the “Client” in this policy, we are referring to an individual, company or organization that has purchased use of TALENTED Services on behalf of its Users.

USER

When we talk about the “User” in this policy, we are referring to the end users of TALENTED Services. You are a User even if you are using TALENTED Services by invitation of a Client.

COHORT

When we talk about a “Cohort” in this policy, we are referring to a specific grouping of Users.

PERSONAL INFORMATION

When we talk about “Personal Information”, we are referring to any information relating to an identified, or identifiable, living individual.

SUBMITTED DATA

When we talk about “Submitted Data”, we are referring to any submissions made by the User relating to the user of TALENTED services

GENERATED DATA

When we talk about “Generated Data”, we are referring to any information relating to the use of TALENTED services by a User.

TRANSACTIONAL EMAIL(S)

When we talk about “Transactional Email(s)”, we are referring to any email sent on behalf of TALENTED that is part of TALENTED’s Service.

NON-TRANSACTIONAL EMAIL(S)

When we talk about “Non-Transactional Email(s)”, we are referring to any marketing email sent on behalf of TALENTED that primarily contains a commercial message or content intended for a commercial purpose.

INFORMATION WE COLLECT

1. USER PERSONAL INFORMATION

When a User provides Personal Information, or has Personal Information provided on behalf of a Client directly to TALENTED or through a third party service, TALENTED collects that Personal Information. Personal Information collected by TALENTED includes:

  • First and last name
  • Email address
  • Cohort affiliations (if applicable)

This User Personal Information is collected in order to create accounts for Users and provide TALENTED Services. For additional information, please see section titled “How We Use Your Information.”

2. USER SUBMITTED DATA

Submissions made by the User while using TALENTED services are collected by TALENTED as User Submitted Data. These submissions collected by TALENTED include:

  • Answer selections for limited-choice learning activities, such as multiple choice questions, item matching questions, etc
  • Submissions of Real World Challenges, including open-text response submissions, image or audio submissions, or other file upload submissions.

This User Submitted Data is collected to be able to provide User and Cohort analytics to Clients and/or Users. For additional information, please see section titled “How We Use Your Information.”

3. USER GENERATED DATA

When a User uses TALENTED services, Generated Data is automatically collected about the nature of their use of TALENTED services. User generated data collected by TALENTED includes:

  • Log data, such as date and time of use of TALENTED services, duration of use of TALENTED services, completion of TALENTED services, IP addresses, and cookie data
  • Device information, such as type of device used, operating system, device settings, application IDs, unique device identifies, and crash data (note: whether we collect some or all of this information often depends on what type of device you are using and its settings)

This User Generated Data is collected to be able to provide User and Cohort analytics to Clients, as well as to improve TALENTED services. For additional information, please see section titled “How We Use Your Information.”

4. CLIENT INFORMATION

Clients who pay for TALENTED services may need to provide additional information to TALENTED. TALENTED may also collect the following information:

  • Billing and other information, such as payment processing information
  • Services usage information, such as administrative and support communications with TALENTED and information about the teams, people, features, content, and links the Client interact with, etc
  • Service integrations, such as third party services used by the Client that TALENTED would need access to in order to provide a service.

This Client information is collected to be able to fulfill service agreements. For additional information, please see section titled “How We Use Your Information.”

(Note: For Clients that purchase a paid version of the Services, TALENTED’s corporate affiliates and third party payment processors may collect and store billing address and credit card information on our behalf or we may do this ourselves.)

5. ADDITIONAL INFORMATION

TALENTED may also receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which zip codes, or it might be more specific information, such as how well an online marketing or email campaign performed.

HOW WE USE YOUR INFORMATION

1. USER PERSONAL INFORMATION

The main reason we collect User Personal Information is so we can create accounts for Users of TALENTED Services. In addition, User Personal Information is used to:

The main reason we collect User Personal Information is so we can create accounts for Users of TALENTED Services. In addition, User Personal Information is used to:

  • Send important Transactional Emails regarding TALENTED Services
  • Send Non-Transactional Emails regarding TALENTED Services
  • Communicate back and forth with Users about technical issues
  • Correlate User Submitted Data and User Generated Data to individual Users

(Note: In order to help resolve an issue, TALENTED may share User concerns with the Client.)

2. USER SUBMITTED DATA

The main reason for collecting User Submitted Data is to be able to provide User and Cohort analytics to Clients and/or Users. In addition, User Submitted Data is used to:

  • Provide TALENTED Services to Users

(Note: When TALENTED sends User Submitted Data to the Client for a User and/or Cohort, the Client determines its own policies regarding use, storage, access, modification, deletion, sharing, and retention of Submitted Data which may apply to your use of the Services. Please check with the Client about the policies and settings it has in place.)

(Note: We may aggregate or de-identify information collected by use of TALENTED Services so that the information does not identify Users or Clients. This Privacy Policy does not restrict our use or disclosure of aggregated or de-identified information.)

3. USER GENERATED DATA

The main reason for collecting User Generated Data is to be able provide User and Cohort analytics to Clients, as well as to improve TALENTED Services. In addition, User Generated Data is used to:

  • Provide TALENTED Services
  • Maintain and improve Services
  • Prevent or address technical issues and security issues

(Note: We may aggregate or de-identify information collected by use of TALENTED Services so that the information does not identify Users or Clients. This Privacy Policy does not restrict our use or disclosure of aggregated or de-identified information.)

4. CLIENT INFORMATION

The main reason for collecting Client Information is to be able to fulfill service agreements. In addition, Client Information is used to:

  • Share reports with Clients regarding Submitted Data and User Generated Data
  • Communicate with Clients about other data collected according to this Policy
  • Create “Admin” accounts for Clients to view User data collected according to this Policy
  • Track billing and payments, and perform other account management activities
  • Send Non-Transactional Emails

YOUR CHOICES REGARDING YOUR DATA

1. USERS

Users who were not registered on behalf of a Client may review, correct, amend, or delete the Personal Information provided to TALENTED by contacting us at privacy@talentedapp.com. If you would like us to delete your account and records in our system, please contact us at privacy@talentedapp.com with a request that we delete your Personal Information from our database. If your User account was provisioned by a Client, the Client is a “data controller” of your information, and if you seek to correct, amend, or delete data associated with your account, you should also direct your requests to the Client.

TALENTED may retain an archived copy of your records as required by law or for legitimate business purposes. However, Users from European countries have the right to be forgotten according to General Data Protection Regulation.

Subject to applicable law, you also have the right to (i) restrict TALENTED’s use of Other Information that constitutes your Personal Information and User data and (ii) lodge a complaint with your local data protection authority.

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Client is the controller of User and Client data. In general, TALENTED is the processor of User data and the controller of Other Information.

In addition, the browser you use may provide you with the ability to control cookies or other types of local data storage. Your mobile device may provide you with choices around how and whether location or other data is collected and shared. TALENTED does not control these choices, or default settings, which are offered by makers of your browser or mobile device operating system.

If you have any questions or concerns about your information, our use of this information, or your rights when it comes to any of the foregoing, contact us at privacy@talentedapp.com.

2. CLIENTS

The Client will provide TALENTED with instructions on what to do with User data as described in this Policy. A Client has many choices and control over this User data. For example, the Client may provision or deprovision access to the Services, enable or disable third party integrations, manage permissions, retention and export settings, transfer or assign Cohorts, or consolidate cohorts with other cohorts. Since these choices and instructions may result in the access, use, disclosure, modification or deletion of certain or all User data, please contact support@talentedapp.com before requesting specific instructions.

ADDITIONAL POLICIES

1. COOKIE POLICY

TALENTED uses cookies and similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies.

Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit our website or use our desktop application. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.

Some cookies are associated with your account and personal information in order to remember that you are logged in and which teams you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things. If you access the Services through your browser, you can manage your cookie settings there but if you disable some or all cookies you may not be able to use the Services.

TALENTED sets and accesses our own cookies on the domains operated by TALENTED. In addition, we use third parties like Google Analytics for website analytics. You may opt-out of third party cookies from Google Analytics on its website.

What can you do if you don’t want cookies to be set or want them to be removed, or if you want to opt out of interest-based targeting?

Some people prefer not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. What this means is that you can disallow cookies from all sites except those that you trust.

Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information.

For other browsers, please consult the documentation that your browser manufacturer provides.

You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://youradchoices.com). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads.

If you limit the ability of websites and applications to set cookies, you may worsen your overall user experience and/or lose the ability to access the services, since it will no longer be personalized to you. It may also stop you from saving customized settings, like login information.

Our Sites and Services do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our TALENTED Services, and we do not alter any of our data collection and use practices upon receipt of such a signal.

2. EMAIL POLICY

We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties. We will maintain the information you send via e-mail (e.g. to support@talentedapp.com) in accordance with applicable federal law.

In compliance with the CAN-SPAM Act, all e-mails sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.

We provide Users the opportunity to opt-out of receiving Non-Transactional Email communications from us and our partners by replying “Unsubscribe” to any Non-Transactional Email communication they receive from us.

3. SHARING AND DISCLOSURE

There are times when information described in this privacy policy may be shared by TALENTED. This section discusses only how TALENTED may share such information.

TALENTED may share User data as described in this policy with the Client. The Client determines their own policies for the sharing and disclosure of User Generated Data and User Submitted Data. TALENTED does not control how Clients or their third parties choose to share or disclose User data as described in this Policy.

TALENTED may share User and Client data as described in this policy with third party service providers, agents, and integrations in accordance with our agreement with the Client and the Client’s instructions. TALENTED is not responsible for how the provider of an integration may collect, use, and share User Data.

TALENTED may share User and Client data as described in this policy during any merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of TALENTED’s assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).

TALENTED may share User and Client data as described in this policy to comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.

TALENTED may share User and Client data as described in this policy to protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.

TALENTED may disclose or use aggregate or de-identified information for any purpose. For example, we may share aggregated or de-identified information with our partners or others for business or research purposes like telling a prospective TALENTED Customer the average number of canvases created within a TALENTED team or partnering with research firm or academics to explore interesting questions about innovation practices.

4. SECURITY

TALENTED takes security seriously. We take various steps to protect information you provide to us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology.

5. CHILDREN’S INFORMATION

Our Services are not directed to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us at privacy@talentedapp.com

6. CHANGES TO THIS PRIVACY POLICY

We may change this policy from time to time, and if we do we will post any changes on this page. If you continue to use the Services after those changes are in effect, you agree to the revised policy.

CONTACTING TALENTED REGARDING THIS PRIVACY POLICY AND THE CONTENTS THEREIN

To communicate with our Data Protection Officer, or if you have any questions about TALENTED’s Privacy Policy or practices, please email privacy@talentedapp.com or contact us at our mailing address below:

TALENTED, LLC

228 Markham Dr,

Chapel Hill, NC 27514