Effective March 2, 2020.
CBT Nuggets complies with the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and Switzerland to the United States in reliance on Privacy Shield. CBT Nuggets has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information.
By using or interacting with our services, you are agreeing to:
- The transfer of your data from, within, and between:
- the European Economic Area ("EEA")and the United Kingdom and Switzerland;
- the United States, Mexico, Australia; and,
- countries that have received an adequacy determination by the European Commission under Article 45, as well as other countries subject to appropriate safeguards under Article 46, of Regulation (EU) 2016/679;
- The use of e-mail notifications as a primary source of communication between you and CBT Nuggets.
INFORMATION WE COLLECT
We will NEVER share your personal data with third-party partners for their direct marketing purposes.
CBT Nuggets and our partners collect data from Learners (individuals who utilize our instructional services) in the following circumstances:
When you use or interact with the services, we and our partners may use a variety of technologies that collect information about those interactions. These technologies include cookies, web beacons, tracking pixels, and similar technologies. Learn more about cookies at www.aboutcookies.org. We use these technologies internally to customize your learning experience, such as keeping you in a logged-in state or providing you with the most relevant content. Disabling these technologies on your web browser may negatively impact your user experience.
We also have partners that use these technologies to provide us with measurement services of our website and deliver advertisements to you as well as optimize your experience. These third-party partners may collect your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and attempt to aggregate data to deliver content and optimize your experience based on overall web browsing activity.
We may use vendors, who use first-party and third-party cookies together to inform, optimize, and serve ads based on your past visits to our websites. Google Analytics offers tools to manage your cookie settings at tools.google.com/dlpage/gaoptout and Google's Ads Settings has additional instructions at adssettings.google.com. On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests. Additional information for mobile users can be found at: https://youradchoices.com/appchoices.
Our website does not respond to Do Not Track signals. You may visit aboutads.info to receive more information about the collection and use of information about your online activities for online behavioral advertising or to learn how to opt-out of having your data used for online behavioral advertising by Digital Advertising Alliance (DAA) participating companies. Canadian users can also visit youradchoices.ca. European users can also visit youronlinechoices.com to learn how to opt-out of having their data used for online behavioral advertising by European Interactive Digital Advertising Alliance (EDAA) member companies.
In order for you to access the CBT Nugget content (training videos, quizzes, practice exams, virtual labs, and other tools), you must first register for a CBT Nugget Learner Account by providing personal data. We and our third-party partners must process your personal data in order to make that content available to you as you have requested and pursuant to the terms of your access. The particular data that is processed, and by whom, is relative to the particular content you access and the particular service you interact with. We also collect Learner activity data which we use internally to keep track of your learning progress and ensure our services are operating as expected for all Learners.
Account Administrators may access the information for all Learners in their group. Account owners and billing and coaching contacts similarly have access to their group's Learner information.
When you register for a Learner or Administrator account with CBT Nuggets we collect information about you for the following purposes. We collect your email to function as your username and provide a means of communication for important notices. We collect your first and last name in order to facilitate our licensing model of one license to one named individual. This allows us to provide a personalized Learning experience and comply with various reporting and recordkeeping obligations. We optionally collect your company/organization/school name, as well as other provided information, in order to enhance your Learner experience.
When registering on our site you may be asked to enter payment information, such as PayPal or a credit card. We collect your payment information, as well as your billing address and telephone number for validation, compliance, and recordkeeping purposes. Payment processing is securely handled by third parties. All information entered into the secure webform is done so via an encrypted session.
We may offer you the ability to link a third-party profile or identity provider for registration, authentication, or other account activities. You will be directed to that third party's page, where you can log in with your third-party account details and authorize the processing of your information for such account activity as described by that third party.
When you access the certification practice exams through the services, you are accessing proprietary materials which have been provided to Learners through an agreement with our test provider. Your information is stored by the test provider and used to create a unique authentication token which provides you access to the practice exams. Your information is only transmitted to our test provider when you access the practice exams.
When you access the virtual labs through the services, you are accessing our proprietary instances on a virtual computer hosted by our labs provider. Your information is used to create a unique authentication token which provides you access to the virtual labs. Your information is only transmitted to our labs provider when you access the virtual labs.
When you participate in the Learner Community, the Quiz Points Leaderboard, or when posting comments, you are placing your information public forum. Once you publish in any of the above forums, it becomes publicly available and we are restricted in our ability to delete that information. Before posting in a public forum, you should carefully review the Privacy Policies of the relevant third-party partners. Our Learner Community is a third-party hosted forum. The Quiz Points Leaderboard is a semi-public forum hosted by CBT Nuggets and available to available to view by other CBT Nuggets Learners. If you choose to edit your Leaderboard profile picture, you are creating an account with that third-party. By default, your Quiz Points are not displayed on the Public Leaderboard, you can opt-in via your Learner Account settings.
User Experience Research
We may provide Learners or website visitors with the opportunity to participate in user experience research, and we may announce such opportunities, through our marketing email list or by invitation to our Learners. Additional details, as appropriate, of the data processing will accompany any such opportunity for feedback and engagement. Unless otherwise specified, the personal data collected during such surveys will be retained consistent with our data retention schedule. As with any consent, you may revoke this consent at any time. We may also provide Learners with customer feedback surveys for internal purposes only, or to follow up on prior activity with us.
When you sign up to receive marketing emails from CBT Nuggets, the personal information you provide is collected in order to identify you and personalize the email content we send to you. Marketing emails are sent out no more than a few times per week and contain information, news, resources, special offers, and promotions related to CBT Nuggets which you otherwise have requested to receive. We may use Multipurpose Internet Mail Extensions in our emails to help inform us of the effectiveness of our content as well as provide an indication as to your level of interest in continued marketing.
You may unsubscribe from the marketing email list at any time by navigating to your Learner Account settings or by using the “Unsubscribe” link in the email. Please note that this does not cover System/Transaction Emails such as subscription notices, receipts, follow up communications, or other compulsory commercial or legal correspondence.
Communicating With Us
When you contact us for Learner Support, or otherwise communicate with us, we will attempt to connect that email, telephone call, or chat with your Learner account. If we are able to connect the communication to the account, this means your method of communication and the substance of the communication will become associated with your information. When you contact an Accountability Coach, we connect those communications to your Learner account as well.
CBT Nuggets expressly discourages any customers from sending or transmitting any sensitive data via any unsecured networks or channels, including, but not limited to, any customer primary account number (“PAN”) or other credit card or payment data. You assume any and all risk associated with such transmissions.
Accessing Services Via Apps
When you download our app and use our services, we automatically collect information on the type of device you use and the operating system version, so we know the best application version to provide you with. During your use of the app, we and our partners may further collect data regarding your device, operating system, and location in order to optimize the services we provide to you. Our mobile apps require Account Registration for full functionality, and the data collected during registration is described in the previous sections. Please note that your subscription may be managed through a mobile application store such as iTunes or Google Play Store, etc.
INFORMATION WE SHARE
We will NEVER rent, sell, share, or otherwise disclose your personal data with third-party partners for their direct marketing purposes. Before sharing your data with third-party controllers, we will provide you with notice and an opportunity to opt-out.
We may share your personal information with:
- Our contractors, service providers and other third parties we use to support our business and to fulfill services requested by you, including, without limitation, content delivery, payment processing companies, marketing services providers, as well as learning resource features.
- To your Account Administrator or owner or billing or coaching contact, if any.
- To other third parties with your express consent or that of your Account's contacts, if any.
We may also disclose your personal information:
- To comply with a lawful request by public authorities, including valid court orders or to meet national security or law enforcement requirements.
- To enforce our agreements with you, including for billing and collection purposes.
- To prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity; this may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
As a Privacy Shield organization, we accept full responsibility for any and all transfers of your personal data to third parties acting as our agents unless we can prove we were not a party giving rise to the damages.
WHERE WE KEEP YOUR DATA
The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff both within and outside the EEA who work for us or for one of our service providers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and/or the provision of support services. Your data is maintained in servers that are located in the United States, and your data may be processed in the United States, Mexico, Australia, United Kingdom, and countries for which there has been an adequacy decision and/or with appropriate safeguards. Not all of these countries are considered by the European Commission to offer adequate protection of your personal data. For these cases, CBT Nuggets has put into place appropriate safeguards to ensure adequate protection of your data, such as Privacy Shield certification, and other technical and organizational safeguards.
We retain personal data for seven years from a Learner’s last system access or termination of last subscription period, whichever is later, unless such data must be retained for the establishment, exercise, or defense of legal claims.
Through the website you can access information regarding your recent orders, your personal information, marketing preferences, and payment settings. With respect to your marketing preferences, you can unsubscribe from CBT Nuggets marketing emails by following the unsubscribe link in any marketing email you receive or you can navigate to your Learner account and update your preferences there. We offer marketing email recipients the opportunity to unsubscribe from further communications in every email, with the exception of non-commercial service emails, such as service orders, system updates, or support issues.
If your password or username is compromised, please notify us as soon as possible by using the contact information below. We reserve the right to reset passwords for inactive accounts or due to suspicious account activity.
CBT Nuggets acknowledges that individuals have the right to access the personal information that we maintain about them and to correct, amend or delete any data that is incorrect or has been processing in violation of the Privacy Shield Principles. Any individual who seeks to access, correct, amend, or delete their data should direct their query to Learner Support:
Unfortunately, no online data transmission can be fully guaranteed to be secure. Thus, by accessing the Website and/or utilizing the services, you acknowledge that: (a) there are online security and privacy limitations that are beyond CBT Nuggets’ control; (b) the security, integrity and privacy of any and all information and data exchanged between you and CBT Nuggets through the website cannot be fully guaranteed and we shall have no liability to you or any third party, unless otherwise provided by law, for loss, misuse, disclosure or alteration of such information not resulting from the direct fault or negligence of CBT Nuggets; and (c) any such information and data may be viewed or tampered with in transit by a third party.
Special Notice to EU, UK, and Swiss Residents
CBT Nuggets is subject to the investigatory and enforcement authority of the United States Federal Trade Commission. CBT Nuggets is obliged to disclose personal data pursuant to lawful requests.
CBT Nuggets, LLC
Attn: Data Privacy Officer
1550 Valley River Drive
Eugene, OR 97401
CBT Nuggets has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.