Last Updated: March 15, 2023
WHAT INFORMATION WE COLLECT
When you visit our sites, we collect personal information about you. “Personal Information” means information that identifies a particular individual including:
- Real name, alias, unique personal identifier, online identifier, Internet Protocol address, or account name;
- Education, employment, employment history or credit card number;
- Commercial information including products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic network activity information regarding a consumer’s interaction with an Internet website; and
- Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information also includes “personal data” as defined by the General Data Protection Regulation (GDPR) and “personal information” as defined by the California Consumer Privacy Act (CCPA). Personal Information is collected when you fill out forms, communicate with us through our sites, or create an online profile. We may collect Personal Information that you make publicly available, such as if you write a product review or make a comment on another user’s content.
We may also collect certain information from your employer including name, email address, and employment information (unique employee number, job title, job status, retail location).
When you create an online profile, you may choose to provide optional information such as your employer, training modules completed, purchases you make, product reviews,
COOKIES AND OTHER TRACKING TECHNOLOGY
Our sites also use “cookies” (small data files stored on your computer) and other tracking technologies to collect information about your visit to our sites. The cookies that may be used by ExpertVoice fall into the two categories described below. These descriptions can help you determine if and how you would like to interact with the sites.
- Essential Cookies: These cookies are absolutely necessary for the sites to function properly and cannot be switched off in our systems. This category includes cookies that ensure the basic functionality and security of the sites. These cookies do not store Personal Information.
- Non-Essential Cookies: These cookies may not be necessary for the sites to function and are used to collect Personal Information on users via analytics, ads, and other embedded content. These cookies often help us improve the experience of the website.Users may opt out of non-essential cookies by going to www.expertvoice.com/account. Once on the page, you will see a box labeled Cookies where you can toggle off Non- Essential Cookies.
Our sites and services do not respond to browser “Do Not Track” signals.
The cookies and tracking technologies we use do not capture Personal Information. The information that is captured about your visit may be used in a variety of ways, such as to monitor and maintain information about your visits to our sites, to help us identify and address problems, to improve our sites, to analyze web traffic trends, and to help protect the security and integrity of our sites. You may set your browser not to accept cookies or to notify you when you receive cookies, giving you the opportunity to decide whether to accept cookies. If you do not accept cookies, you may still use our sites, but your experience may be degraded. We may also use pixel tags (also known as “clear gifs,” “Web beacons,” or “1-by-1gifs”) on our sites. These may be used in connection with certain pages of our sites or with email messages to measure the effectiveness of our communications and our marketing campaigns, to compile statistics about usage and response rates, and to assist us in resolving issues that may arise on our sites.
Third-party vendors may collect Personal Information about your online activities over time and across different websites when you use the sites.
Our sites use Google Analytics, a web analytics service provided by Google Inc. (“Google”). On our behalf, Google will use the cookies to collect information to evaluate your use of the sites, compile reports about activity on the sites, and to provide other services related to the sites and Internet use. Learn more about Google Analytics and your choices by visiting this website: https://tools.google.com/dlpage/gaoptout.
You can also learn more about online advertising cookies and your ability to opt-out of certain online advertising cookies by visiting the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices. For your mobile device, you can understand which third parties have currently enabled cookies on your mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative's website at http://www.networkadvertising.org/mobile-choices from your mobile device. On your mobile device you may also select “Limit Ad Tracking” (on iOS devices) or “Opt out of Interest-Based Ads” (on Android). Even if you disable tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed and that you may still receive advertising from third parties, though such advertising may not be based on your interests and preferences.
HOW WE USE COLLECTED PERSONAL INFORMATION
We may use the Personal Information we collect for the following purposes:
- To respond to your inquiries and fulfill your requests;
- To send you important information regarding our sites, changes to our terms, conditions, and policies, and/or other administrative information;
- To send you marketing communications that we believe may be of interest to you, if you have agreed to receive such messages;
- To personalize your experience on our sites by presenting content tailored to you;
- To allow you to take and keep track of training;
- For our business purposes, such as data analysis, audits, developing new products, enhancing our sites, improving our services, identifying usage trends, furthering brand relationships, and determining the effectiveness of our promotional campaigns;
- For risk control, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements;
- To use information about your activities on the sites to communicate your training progress to your employers and in some cases to offer you retail discounts; and
- For other purposes which are disclosed to you and to which you consent.
We may also use information that we receive about you from your employer and data providers who assist us in processing requests, maintaining our data, and optimizing our services.
We may also use your Personal Information for business purposes such as:
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use, provided that the personal information is not disclosedto another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service ordevice that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
- For other legitimate purposes as permitted by law; and
- Any commercial purposes, including any purpose to advance your commercial oreconomic interests, such as by inducing you to buy, rent, lease, join, subscribe
to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
SHARING YOUR INFORMATION
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information. We may disclose your Personal Information for any other purpose with your consent.
When ExpertVoice receives Personal Information under the EU–US Privacy Shield Framework or the Swiss–U.S. Privacy Shield Framework (as explained in the Privacy Shield section below) and then transfers the Personal Information to third party services, we are liable for any processing of Personal Information by such third parties that is inconsistent with the Privacy Shield Principles, unless we are not responsible for the event giving rise to any alleged damage.
YOUR CHOICES FOR CONTROLLING YOUR INFORMATION
CORRECTING OR CHANGING YOUR INFORMATION
California users, please see the California Privacy Rights section below to find out how to exercise your rights. European users, please see the European Union section below to find out how to exercise your rights.
You may also contact us by writing to:
Attn: Expert Success
9 Exchange Place, Suite 1000
Salt Lake City, Utah 84111
We will respond to your access request within any legally required time period. We reserve the right not to allow access to your information if we believe in good faith that such disclosure is prohibited by law or if the rights of another individual might be violated.
You may cancel your registration to our sites and/or request the removal of your Personal Information from our visitor records by sending an email to email@example.com or visiting us at https://www.expertvoice.com/contact.
CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Privacy Act (CCPA), California residents have the right to:
• Request that a business delete any personal information about the consumer which the business has collected from the consumer.
- Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:
- The categories of personal information the business has collected about the consumer in the preceding 12 months.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for which it collected or sold the personal information.
- The categories of third parties with which the business shares personal information.
- The specific pieces of personal information it has collected about that consumer.
- Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:
- The categories of personal information that the business sold in the preceding 12 months, and for each category identified, the categories of third parties to which it sold that particular category of personal information.
- The categories of personal information that the business disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to whom it disclosed that particular category of personal information.
- Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.
We will not discriminate against you if you choose to exercise any of your rights as described in this section.
HOW TO SUBMIT A REQUEST
You may submit a request under the CCPA through the following methods:
- You may call us toll-free at 1-866-376-4685.
- You may e-mail us at firstname.lastname@example.org.
To submit a request, we are required to verify your identity. Users will be required to provide the primary email address listed on the account. A verification email will then be sent to that email address in order to verify your identify. We may need to contact you to confirm your request.
Consumers may use an authorized agent to submit their request. The authorized agent must be registered with the California Secretary of State and be authorized to submit requests on behalf of a consumer. If you are an authorized agent and a consumer has given you written and signed permission to submit a request on his or her behalf, please send a copy of your signed permission by the consumer to ExpertVoice. Failure to submit proof of signed permission may result in ExpertVoice denying the consumer’s request. ExpertVoice will require the consumer to verify his or her identity and directly confirm with ExpertVoice that the consumer has provided you with permission to submit the request.
LEGAL BASES FOR PROCESSING PERSONAL INFORMATION
ExpertVoice will only process your Personal Information when ExpertVoice has a lawful basis for doing so. ExpertVoice will collect and process your Personal Information as necessary for the performance of a contract to which you are a party or because ExpertVoice has another legitimate interest in doing so relating to ExpertVoice’s business purposes arising from your relationship with ExpertVoice. ExpertVoice may also seek your prior consent or rely on some other lawful basis to process your Personal Information.
RIGHTS OF USERS LOCATED IN THE EU
If you use our sites and are located in the EU or EAA you are entitled by law to access, correct, amend, or delete Personal Information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.
- The right to access. You have the right to ask us for copies of your Personal Information. When making a request, please provide an accurate description of the Personal Information to which you want access. We may charge a reasonable fee based on administrative cost.
- The right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- The right to erasure. You have the right to ask us to erase your Personal Information in certain circumstances, including your Personal Information must be erased to comply with a legal obligation under EU or member state law.
- The right to restrict processing. You have the right to ask us to restrict the processing of your Personal Information in certain circumstances, including: (i) when the accuracy of the Personal Information is brought into question, or (ii) when we no longer need the Personal Information for the purposes of the processing but you require such Personal Information for the establishment, exercise, or defense of a legal claim.
- The right to data portability. You have the right to ask that we transfer the Personal Information you gave us from one organization to another, or give it to you.
- The right to lodge a complaint with the supervisory authority. If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm.
- The right to withdraw consent. If ExpertVoice obtains your written consent to collect and process your Personal Information, you can subsequently withdraw such consent as to any further processing of information by contacting us at email@example.com.
- Automated decision-making. To the extent that ExpertVoice engages in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.
To exercise these rights please contact us at firstname.lastname@example.org. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available
RIGHT TO OBJECT TO PROCESSING
You have the right to object to the processing of your Personal Information that is based on legitimate interests. If you make such an objection, we will cease to process the Personal Information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests or which override your rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your Personal Information by contacting us at email@example.com.
CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION
Personal Information that you provide while in the EU, an EAA member state, or Switzerland will be transferred to the United States. The GDPR permits such transfer when necessary for the performance of a contract between you and ExpertVoice, if ExpertVoice obtains your explicit consent to such transfer, or if it is ExpertVoice’s legitimate interest to transfer the Personal Information. The laws in the United States may not be as protective of your privacy as those in your location. If we transfer Personal Information from the EU, UK, or Switzerland we will comply with the Privacy Shield Principles with respect to Personal Information transferred.
RETENTION OF YOUR PERSONAL INFORMATION
We will retain your Personal Information until the Personal Information is no longer necessary to accomplish the purpose for which it was provided. We may retain your Personal Information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.
We use a variety of technologies and processes to protect Personal Information collected on the sites, including physical, technological, and organizational security measures. For example, we use encryption technology whenever transmitting Personal Information. Unfortunately, no security technology is completely secure, and you should remember that email is not a secure means of communication. We retain Personal Information that we collect only as long as reasonably necessary to fulfill the purposes for which it was collected or to meet any legal requirements.
Some or all of the Personal Information we collect may be stored or processed on servers located outside of your country, including in the United States, whose data protection laws may differ from those where you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate security processes are in place to maintain protection over the Personal Information we collect.
LINKS TO OTHER WEBSITES
Our sites are not intended for use by children. We do not knowingly collect personal information from children under the age of 16. Children under the age of 16 are prohibited from creating an online profile.
PRIVACY SHIELD POLICY
Pursuant to the Privacy Shield Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
ExpertVoice’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, ExpertVoice remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless ExpertVoice proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, ExpertVoice commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact us at 1-866-376-4685, firstname.lastname@example.org, or visit https://www.expertvoice.com/contact.
ExpertVoice 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 http://www.bbb.org/EU- privacy-shield/for-eu-consumers for more information and to 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.
The Federal Trade Commission has jurisdiction over ExpertVoice’s compliance with the Privacy Shield.
You may also contact us by writing to:
Attn: Expert Success
9 Exchange Place, Suite 1000
Salt Lake City, Utah 84111