• provides an overview of how the Company collects and processes your personal data and tells you about your rights under the EU General Data Protection Regulation (“GDPR”);
• when we refer to “personal data” or “personal information” we mean data which identifies or may identify you and which may include, for instance, your email or IP address;
• when we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data; and
• when we refer to “sensitive data” we mean personal data which may reveal information about racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, genetic or biometric data.
1. Who we are
2. How we collect your personal data
We obtain your personal data mainly through any information you provide directly to us through our Website. Below is a list of ways we collect your personal data:
- when you visit and/or use our Website;
- when you complete our registration form,
- when you post materials or upload content;
- when you take part in surveys or report a problem with our Website; or
- when you contact us via email, post, or other ways of communication.
3. If you fail to provide personal data
Where we need to collect and process your personal data in order to provide you with our services and you fail to provide that data when requested, we may not be able to provide you with access to our Website and/or the services we offer. In this case, we may have to suspend your access to the Website or, if you are a Member, prohibit any access to non-public areas of the Website or restrict the operation of your account and the services we provide to you.
4. Personal data that we collect and process
a. Personal data we collect and process from various Browsers
i. Technical Data, including your Internet Protocol (IP) address, your browser type, and version, time zone setting and location, browser plug-in types and versions, smart device information, mobile phone network information, operating system and platform, and other technology on the devices you use to access this Website;
iii. Account Data, in order to use certain features (like enrolling in a course), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, phone number, occupation, skill interests, gender, race, ethnicity, government ID information, verification photo, age, and date of birth, and assign you a unique identifying number.
iv. Profile Data, you can also choose to provide profile information like a photo, headline, biography, language, website link, social media profiles, country, or other data. Your Profile Data will be publicly viewable by others.
v. Shared Content, Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a course page, asking or answering questions, sending messages to students or instructors, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.
vi. Course Data, when you enroll in and take courses, we collect certain data including which courses, assignments, and quizzes you’ve started and completed; your exchanges with instructors, teaching assistants, and other students; and essays, answers to questions, and other items submitted to satisfy course requirements.
vii. Student Payment Data, if you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code. For security, Insight Before Action does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
We may obtain certain information through your social media or other online accounts if they are connected to your Insight Before Action account. If you login to Insight Before Action via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday, and list of friends or contacts
ix. Data About Your Accounts on Other Services, those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
xii. User Submitted Data, including data collected for a specific function, for instance a contest or a survey; and
5. Automated personal data collection
6. Why we need your personal data and how we use it
We will most commonly use your personal data in the following circumstances:
a. where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests;
b. where we need to comply with a legal obligation; and/or
c. where you have given us your consent.
Below, we describe these circumstances in further detail.
d. Performance of our services to you
i. Provision of services (Members Only)
We may collect and process your personal data where it is necessary in order to present our Website and its contents to you, including any interactive features on our Website, and to provide you with information or services that you request from us.
Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide you with the services we provide to our Members.
ii. Customer management (Members Only)
We may collect and process your personal data where it is necessary in order to manage a Member’s account, to provide customer support and notices to Members about their account and subscription, including expiration and renewal notices, and notices about changes to our Website or any services we offer or provide through it.
e. Legitimate interests
i. Customisation of content (Members Only)
We may collect and process your personal data where it is necessary in order to perform research and analysis about your use of, or interest in, our Website content and/or services, so as to develop and display content and advertising tailored to your interests on our Website.
We may collect and process your personal data where it is necessary in order to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as the total number of visitors, pages viewed and demographic patterns.
iii. Functionality and security
We may collect and process your personal data where it is necessary in order to diagnose or fix technology problems, and to detect, prevent and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
iv. Other legitimate interests
In addition to the above, we may process your data, to the extent required for our business needs in order to:
- develop new services on our Website as well as analyse and target new markets;
- protect our legal rights and interests (including legal claims and preparing our defence in litigation);
- monitor, maintain and improve internal business processes, information, and data, technology and communication solutions and services;
- ensure network information security, including monitoring Browsers’ and Users’ access to our information technology for the purpose of preventing cyber-attacks, unauthorized use of Website and prevention or detection of crime;
- send you relevant marketing information (including details of other services provided by us which we believe may be of interest to you), but only where you are a Member of the Website;
- monitor the performance and effectiveness of our services and the Website; and
- assess the quality of our customer services.
f. For compliance with legal obligations
When you visit and/or use and/or register on our Website (and throughout your relationship with us), we are required to comply with certain legal and regulatory obligations which may involve the processing of your personal data. This may include processing to:
– perform checks and comply with laws relating to fraud;
ii. manage contentious regulatory matters, investigations and litigation.
g. You have provided your consent
We will only ask for your consent when we wish to provide marketing information to you in relation to our services which we believe may be of interest and of benefit to you, but only where you are a Browser.
You have the right to revoke your consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.
7. Who we share your personal data with
a. service providers;
b. governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings or investigations by such parties or in order to enable the Company to comply with its legal and regulatory requirements. We specifically reserve the right to disclose any and all information to law enforcement in the event that a crime is committed or suspected or if we are compelled to do so by lawful criminal, civil or administrative process, discovery requests, subpoenas, court orders or writs;
d. legal or other professional consultants.
We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any personal data and may be used to develop content and services that we hope you and other users will find of interest.
Please note that we have never sold and will never sell your personal data to third parties.
8. Members’ Profile
Members should be aware that all information directly provided on the Website when they create an account is public and can be viewed by all other Members and Browsers of the Website unless otherwise stated. Even if a Member’s profile does not contain any personal information, there is a possibility of identification by others through other information on the Member’s profile. Accordingly, Members should understand that they are in control of all of the information they upload on the Website and/or display on their profile and are fully responsible for any consequences arising out of such information.
9. Security of your personal data
We take appropriate security measures (including physical, electronic, and procedural measures) to safeguard your personal data from unauthorized access and disclosure. For instance, only authorized employees are permitted to access personal data, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your personal data between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal data. However, please be advised that we cannot fully eliminate security risks associated with the storage and transmission of personal data as we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining this information.
You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
10. Information we transfer
Some of our external third parties are based outside the European Economic Area (“EEA”) so the processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
– We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
a. Where we use service providers outside the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the European Union.
b. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the US.
We may additionally, in rare occasions, transfer your personal data to a party outside the EEA where we have your prior explicit consent to do so or where such transfer is necessary for the provision of our services to you.
11. Marketing information
We may process your personal data so as to inform you about existing and/or future services that may be of interest to you by sending you periodic announcements with details on existing and/or new services and/or programs.
You have the right to object at any time to the processing of your personal data for marketing purposes, by clicking at the opt-out link at the bottom of any marketing emails we send you.
We can only use your personal data to promote our services to you if we have your explicit consent to do so, or in certain cases such as for example when you are a Member of our Website, if we consider that it is in our legitimate interest to do so. You may also occasionally receive marketing communications from our affiliates, but only provided you have given your explicit consent in receiving such communications.
Even if you inform us that you no longer wish to receive marketing material, you will still receive from us system notices and other information specifically related to your account from time to time.
12. How long we keep your personal data for
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you have questions about our data retention practices, please contact us electronically by sending as an email at email@example.com .
13. Your data protection rights
We want to make sure you are aware of your rights in relation to the personal data we process about you. We have described those rights and the circumstances in which they apply further below.
• Access: This enables you to get access or receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
• Correction: If you believe that any of the information that we hold about you is inaccurate or incomplete, you have a right to request that we correct the inaccurate personal information.
• Erasure: You may request that we delete your personal information if you believe that:
– we no longer need to process your information for the purposes for which it was provided;
a. we have requested your permission to process your personal information and you wish to withdraw your consent; or
b. we are not using your information in a lawful manner.
As a result of deleting your personal information, you will lose access to most of our services.
Grace period: There is a 45-day grace period before we proceed with erasure. During this Grace Period, you will be allowed to restore your account. The grace period functionality allows you not to lose any important information and options by mistake. After the expiration of the grace period, however, your account will be deleted.
• Right to object: You have the right to object to the processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you exercise your right to object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedom or for the establishment, exercise, and defense of legal claims.
If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, where requested, delete your personal data. Please note that if you object us processing your personal data, we may have to suspend the services we provide to you.
• Restriction: You have the right to request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data if:
– it is not accurate; or
a. it has been used unlawfully but you do not want us to delete it; or
b. it is not relevant any more, but you want us to keep it for use in possible legal claims; or
c. you have already asked us to stop using your personal data but you are waiting for us to confirm if we have legitimate grounds to use your personal data.
Please note that if you request us to restrict processing of your personal data, we may have to suspend the services we provide to you.
• Right to portability: Where we have requested your permission to process your personal data or you have provided us with information for the purposes of entering into a contract with us, you have the right to receive the personal data you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provided to you.
If we ask for your consent to use your personal data, you can withdraw your consent at any time. Please note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of our Website and our services.
Please note that some requests to delete certain personal data will require the deletion of your account as a Member as the provision of Member accounts is inextricably linked to the use of certain personal data (e.g. your email address). Also, note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honour your request.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us electronically by sending us an email at firstname.lastname@example.org .
We endeavour to address all your requests promptly.
14. How to access or modify your personal data
We remain dedicated to the protection of your personal data and we want to be clear about the type of information collected, helping you make choices about your privacy. You may:
– access/modify/control the information provided during registration and who you disclose the information to through social networks, comments and PMs on the Website – – please refer to the profile editing page specific to you.
a. choose whether your profile/uploaded content is visible to everyone, or for Members or for friends only.
b. review videos you have watched or paused through watch history.
c. block cookies, including cookies associated with our services, by activating or deactivating the related cookies on your browser. Please note, however, that if you choose to disable all cookies (including essential cookies) you may not be able to access all or part of our Website.
15. Our communication with you
16. Right to complain
Upon receipt of your complaint, we will investigate it and respond to you within a reasonable time.
You also have the right to complain to the data protection supervisory authority of the country in which you reside, provided that such country is a Member State of the European Union or is located within the EEA.
17. Our policy towards minors
Our Website is not directed to individuals under the age of eighteen (18) or the applicable age of majority in the jurisdiction from which the Website is accessed and we do not knowingly collect personal data from minors. If you become aware that your child has provided us with personal data, please contact us electronically at email@example.com . If we become aware that a minor has provided us with personal data, we will take steps to remove such information and terminate that person’s account immediately.
18. California Consumer Privacy Act Notice
As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights we state under this policy and subject to the exceptions found under the CCPA, Consumers have the right to:
• opt-out of the sale of their personal information, should we sell their personal information;
• be informed of certain information concerning our collection and use of their personal information;
• request that we delete certain personal information we collected from them;
• appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
• Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality of services for exercising any of their CCPA rights, unless as permitted under the CCPA.
This Website does not sell nor has it sold in the past 12 months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers, and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the Website work properly. Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information. If the CCPA is applicable to you and you would like to record such preference, please send us an email at firstname.lastname@example.org .
19. Third-party links