Effective Date: May 12, 2021 (version 1.1.0)
When users access our Website and view information about us and our technology, communicate with us, download whitepapers, and register for events etc., we are the data controller.
- the user’s employer is the data controller with respect to the user information it provides to us. This information typically includes first name, last name, and business email address. Where your employer is data controller in this way, we act as a data processor under data protection laws, meaning we use the information to provide a service to your employer.
- LEADx is the data controller for information provided directly by the individual or as a result of interacting with the Platform, including assessment data, a secondary email address, additional profile details such as job title, personal website URL, a short bio, social platform handles, and demographic information such as your gender, year of birth, and your work industry. To be clear, none of these additional profile details are required to utilize our Site, but we can offer you an enhanced experience if you provide it.
The information we collect about you
We collect and process the following personal information from you:
- Information we collect about you from your use of our Site: We will automatically collect information from you each time you visit our Site. This includes technical information such as the type of browser you use, your IP address, and type of device you’re using; information about your visit including date and time; and information about your activity on our Site such as courses searched and viewed, page response times, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods to browse to and away from a page, and methods used to contact our sales and support teams. Technical information may also include the Internet protocol address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating systems, and device platform.
- Information we receive from other sources: This is information we receive about you from third parties that we work closely with to provide, promote, and improve our services. These third parties include business partners, vendors who assist in technical and payment services, advertising networks, analytics providers, and search information providers.
Exception for Enterprise Users
If you are using a LEADx account as an employee of a LEADx customer, you are considered an enterprise user. As such, provisions in this section related to data sharing and data transfer are superseded by written agreements between LEADx and your employer. Under no circumstances does LEADx use your Personal Data for any purpose other than as necessary to provide the services to you and your employer. Any questions about the provisions contained in the written agreements between LEADx and your employer may be directed to your company administrator. Further, LEADx does not act as the Data Controller for any Personal Data in relation to enterprise users. The terms “Personal Data” and “Data Controller” as used herein have the meanings given in the Regulation (EU) 2016/679 or also known as General Data Protection Regulation.
How we use the information we collect
- Information you give to us: We use your personal information to provide our services on our Site, including services arising from any obligations set forth in a contract between you and us. These services may include providing access to our course library, administration of your account, billing, and notifying you of changes to our service or your account. This data will also be used to allow you to participate in the interactive features of our Site or to provide you with information you may have requested from us, including whitepapers, access to webinars, or the like. We also use your personal information together with other personally non-identifiable information to help us better understand our users, to personalize and improve your experience with our Site, and to improve the content and functionality of our Site. This may include providing information about our goods and services that we feel may interest you and enhance your interaction with our Site. We will communicate with you about these goods and services via email, direct mail, telephone, or on our Site. These communications may include newsletters, promotional emails, product updates, or market research requests. We will use your information for this purpose only if you have given your consent to receive marketing material from us at the point we collected your information, where required by law, or otherwise in our legitimate interests, provided these interests do not override your right to object to such communications.
- Information we collect about you from your use of our Site: We will use this information in our legitimate interests (where we have considered these are not overridden by your rights), to administer our Site, and for internal operations, including troubleshooting, data analysis, testing, research, and statistical survey purposes. We will also use this information to keep our Site safe and secure, for measuring the effectiveness of how we present content and how we market and advertise. We use non-personally identifiable information in our log files to analyze trends, to administer our Site, to track users’ movements in and around our Site, and to gather demographic information about our user base as a whole. We also utilize unstructured machine learning technologies to understand user behaviors and to provide user-specific recommendations and other personalization of our Site experience.
Who we give your information to
We consider your personal information to be a vital part of our relationship with you and do not sell your personal information to third parties. There are, however, certain circumstances in which we may share your personal information with certain third parties, as follows:
- Agents, Consultants and Related Third Parties: We sometimes hire other companies to perform certain business-related functions, such as sending email on our behalf, payment processing, or conducting market research. We also share your email address with third parties, such as Facebook, LinkedIn, and Twitter in order to provide custom marketing materials for you on their platforms. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These companies are not permitted to use any personal information that we share with them for any other purpose aside from providing services to us.
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. Your personal information may be transferred to a buyer or other successor in the event of a corporate sale, merger, reorganization, dissolution, or similar event in which personal information held by us about our Site users is among the assets transferred.
- Legal Requirements: In certain situations, LEADx may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or similar legal process served on us or our Site. We will take reasonable steps to ensure that we only collect that personal information that is relevant for the purposes for which it is to be used. Furthermore, we will not process your personal information in a way that is incompatible with these purposes.
Control of your information
Your access to your information and how long we keep it
Upon request, LEADx will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at support@LEADx.org.
We will provide you with the means to ensure that your personal information is correct and current. If you have registered to use the Platform, we will provide a way for you to access and change your profile on our Platform. We will also allow you to completely delete your profile along with all personal information associated with that profile, although this option may significantly degrade your experience with our Platform. You may request deletion by accessing your profile and clicking on the link available there. Alternatively, you may contact us at support@LEADx.org. We will respond to your request within a reasonable timeframe. Requesting deletion of your account means your personal information is permanently deleted and cannot be retrieved.
If you would like to view your personal information that we hold at any time, you may access your profile from our Site.
We retain your information while your account is active or as needed to provide you services. Thereafter, we may retain certain personal information indefinitely as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain aggregate information for research purposes and to help us develop and improve our Site and services.
How we protect your information
The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our checkout page, your information is sent over an authenticated and encrypted connection using Transport Layer Security (TLS).
We store your personal information only on servers with limited access that are located in controlled facilities, and use a variety of technologies and procedures intended to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Nonetheless, no communication via the Internet can ever be 100% secure, and no security measures can ever be assured to be effective. Accordingly, you are advised to use caution and discretion when determining what personal information to disclose to us.
If you have any questions about security on our Site, contact us at support@LEADx.org.
Where we store your information
The data that we collect from you is transferred to, and stored at, a destination in the United States.
Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that. We also give you information about how to disable cookies in the table below. However, you may not be able to take full advantage of our Site if you do so.
A number of cookies we use last only while you are on our Site and expire when you close your browser or exit our Site Others are used to remember you when you return to our Site and will last for longer. We use these cookies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.
We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to our website. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We may also work with advertising networks that gather information about the content on our Site you visit and on information on other websites and services you visit. This may result in you seeing advertisements on our Site or our advertisements when you visit other websites and services of third parties.
The effect of disabling cookies depends on which cookies you disable but, in general, our Site may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our Site. If you disable all cookies, you will be unable to complete a purchase on our Site.
If you want to disable cookies on our Site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
Links to other websites
Information about enforcement and dispute resolution
Physical Address: 1601 Market Street, Philadelphia, PA 19102
Date Last Revised: 5/1/2020
Date Established: 5/1/2020