1. TRANSPARENCY
WE ARE COMMITTED TO PROVIDING YOU WITH INFORMATION ABOUT WHAT DATA IS BEING COLLECTED ABOUT YOU, HOW IT WILL BE USED, AND TO WHOM WE DISCLOSE IT.
A. The data we collect
Personal data, or personal information, means any information about an individual from which that person can be identified, either directly or indirectly. The data we collect about you depends on the Services you use, how you use them, and the information you provide to us. We collect data (1) when you or your employer provide it directly to us, (2) automatically through technology when you use the Services, and (3) from other sources.
Data you or your employer provide directly to us
You or your employer may provide data to us when you use the Services, such as when you register for an account, participate in one of our programs, or communicate with us. This data may include:
- Identity Data includes first name, last name, username or similar identifier, title, and your employer.
- Contact Data includes business address, corporate or personal email address and telephone numbers.
- Marketing and Profile Data includes your interests and preferences in receiving marketing from us and select third parties, your communication preferences and survey responses.
- Customer Service and Inquiry Data, such as information you provide us when you contact customer support or ask us a question about our Services.
- User-Generated Content, such as information you provide to our instructors and coaches in connection with your participation in our business Services.
Data collected automatically when you use the Services
When you use our Services, we may automatically collect certain data using a variety of tools, including server logs, cookies, and other technologies. This data may include:
- Device and Network Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use the Services, such as which Services you use, content accessed within the Services, date and time of use, amount of time spent on the Services, navigation within the Services, and entering and exiting URLs.
Data from other sources
We may also collect data about you from other sources, such as information you post publicly on social media platforms.
De-Identified Data. We may also aggregate or de-identify personal data such that it does not directly or indirectly reveal your identity (“De-Identified Data”). For example, we may aggregate information about use of our websites to calculate the percentage of users accessing specific website features. We may use and disclose such De-Identified Data for any purposes. However, if we combine or connect De-Identified Data with your personal data so that it can directly or indirectly identify you, we treat the combined data in accordance with this Privacy Notice.
We do not collect any Special Categories of Personal Data about you – also considered sensitive data. Special Categories of Personal Data include, but are not limited to, details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, or political opinions. Nor do we collect any information about criminal convictions and offenses.
B. What we do with your data
How we use your data depends on your relationship with us and the Services that you use:
Data collected from Learners under an enterprise (employer) account
We process data collected from individuals in their capacity as learners associated with enterprise accounts in accordance with the relevant customer’s instructions and in fulfillment of the contractual relationship with such customer. This data may include the learner’s identity data, contact data, device and network data, and usage data. Consistent with our contractual commitments, we use this data to provide the Services to learners, support, and troubleshooting, to analyze and improve the Services, to secure our Services, and for legal and compliance purposes, or as otherwise requested by the customer.
Data collected from learners with a direct relationship with GenesisTeaching
We process data collected from individuals in their capacity as learners who have a direct relationship with us pursuant to our contractual relationship. This data may include the learner’s identity data, contact data, device and network data, usage data, and customer service and inquiry data. We may use this data to provide the Services, support and troubleshoot the Services, to analyze and improve the Services, to market our other Services to you, to communicate with you about the Services (such as updates or notices about changes to our terms or policies), to secure the Services, and for legal and compliance purposes, or for other purposes for which we seek your consent.
Data collected from website visitors and others
We process data collected from individuals outside of their capacity as learners (such as visitors to our website) for a variety of purposes. This data may include any of the data listed in Section 1.A above. We may use this data to provide the Services, support and troubleshoot the Services, to analyze and improve the Services, to provide you with information about our other Services, to communicate with you about the Services (such as updates or notices about changes to our terms or policies), to market and advertise our Services, to personalize the Services, to secure the Services, and for legal and compliance purposes, or for other purposes for which we seek your consent.
C. Disclosure of your data
We disclose your data in the following ways:
Within the GenesisTeaching family of companies: We disclose your data within the GenesisTeaching family of companies under common ownership and/or control to provide and enhance the Services and to operate our business.
With your employer. If you are a learner using a GenesisTeaching Business Services account provided by your employer, information about your activity on GenesisTeaching is accessible to, and may be disclosed to, your employer. Please note that this does not apply to information we collect from individuals who have established an independent relationship with us.
With our service providers. GenesisTeaching may share your personal data with vendors and other partners that provide services on our behalf. We require all service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Online advertising partners. We work with third-party online advertising partners that, where permitted by law and consistent with any consent or opt-out elections you have made, collect information both on our Services and on third-party platforms to help tailor and serve you advertisements online. These partners may use cookies, pixel tags and similar technologies on many online services, including ours, to collect information to serve you more relevant ads. You can learn more about how we and our partners use cookies and similar technologies, and about your rights and choices with respect to cookies, by reviewing our [Cookie Policy] and following the instructions in the “Individual Rights and Choices” section below.
Business transfers. We may also share your data with third parties to whom we may choose to sell, transfer, or merge all or parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
Legal, compliance, security, and safety. We may also disclose your personal data as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Please note that GenesisTeaching is a global company and serves customers and individuals around the world. As such, when we disclose data as described above, we may transfer data to other jurisdictions that may have data protection laws that differ from those in your home country. When we transfer, store, or process your data, we take reasonable steps to protect your personal data in accordance with this Privacy Notice and applicable laws. For instance, we may implement Standard Contractual Clauses to govern the transfer of your data, or other means recognized by applicable laws.
D. Using artificial intelligence (AI)
GenesisTeaching leverages AI technologies to improve our products and services, providing a better experience for our learners. The use of AI, and similar emerging technologies must be done in accordance with our code of conduct and AI-related policies and procedures – in compliance with applicable law and regulations. Our policies and procedures ensure that any use of AI is done in an ethical and responsible manner. Generally, and with the exception of a very limited set of circumstances, personal data is not used or processed using AI.