Privacy Policy

Privacy Policy

1. Introduction

Purpose. The purpose of this Privacy Policy is to describe how Digital Revolver, LLC (“Digital Revolver”, “us”, or “we”) collects, uses and shares information about you (“Personal Data”) through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.digitalrevolver.com and the Digital Revolver mobile application (collectively referred to herein as the “Site”). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us. Personal Data includes all information that identifies you or allows you to be identified, directly or indirectly, by reference to the information.

Our Privacy Policy explains:

  • Information That We Collect
  • No Information From Children Under the Age of 18
  • Purposes for Processing and How We Use and Share Your Information
  • Lawful Basis for Processing Your Personal Data
  • Processing of Do Not Track Signals
  • Your Rights and other Choices
  • Security of Your Personal Data
  • Data Retention Periods
  • California Privacy Rights
  • Consent to Processing of Personal Data in United States
  • Changes to Our Privacy Policy
  • Communities, Forums, Chat Rooms, and Message Boards
  • Questions; Data Controller; and How Contact Us

Scope; Third Party Sites. This Privacy Policy applies only to Personal Data we collect at and through the Site. Our Site may also contain links to third party sites that Digital Revolver does not own or control. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

Terms of Use. Please note that your use of our Site is also subject to our Terms of Use.

2. Data Controller

Digital Revolver, LLC, is the data controller of your Personal Data. Digital Revolver, LLC’s will appoint a Data Protection Officer and a representative in the European Union before May 25, 2018. When this occurs, we will update this Privacy Policy to reflect such appointments. Digital Revolver, LLC, its Data Protection Officer, or its representative may be contacted in any manner set forth below.

3. Information that we collect

Information You Provide to Us.

We collect Personal Data directly from you, for example when you create or modify your account, register to use our Site, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. This Personal Data may include:

  • Name
  • Work and Billing Address
  • Email address
  • Telephone number
  • Truncated Credit or debit card number (solely for payment purposes). We use a third-party payment service provider (our “Payment Processor”), who collects and stores your complete credit or debit card information to process your payments. However, we will only receive and store truncated credit or debit card information and/or a unique identifier which may be used by our service provider to process additional payments.
  • Company name
  • Job function
  • Job title
  • Interests
  • Your Student ID, which may be your CCO ID or other ID assigned to you by your vendor

Generally speaking, we do not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.

You may also voluntarily provide information to be published or displayed (collectively “posted”) on public areas of the Site (such as blogs, forums, message boards, and the Digital Revolver community), or transmitted to other users of the Site using ‘sharing’ features (collectively “User Contributions”). Your User Contributions are posted and transmitted to others at your own risk. Digital Revolver cannot control the actions of other users of the Site with whom you may choose to share your User Contributions.

The Personal Data collected from you is required to enter into the contract (which may be in the form of the Terms of Use for our Site) for you to access our digital learning content and for us to perform under that contract. If you refuse to provide such Personal Data, then in some cases we may not be able to provide our services to you, fulfill our obligations to you, or you may not be able to access and use all of the features available to you on our Site.

Information We Collect Automatically Through Your Use of our Site

As you navigate and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (a) details of your visits to your Site, including traffic data, logs, and other communication data and the resources that you access and use on the Site; and (b) information about your computer or mobile device, including your IP address, operating system and browser type, and your mobile device’s unique identifier.

The information we collect automatically may include Personal Data, or we may associate it with Personal Data we collect in other ways or receive from third parties. It helps us improve our Site and to deliver a better and more personalized service, including enabling us to estimate our audience size and usage patterns; store information about your preferences, which allows us to customize our Site according to your individual interests; deliver our Site in a format that is appropriate for your device; speed up your searches; and recognize you when you return to the Site. We may also use this information to diagnose problems with our servers or software, to administer our services and to gather statistical information on the country of origin of our users.

The technologies we use for this automated data collection may include the technologies described below:

Google Analytics. We may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. We also use Thinkific, a web service provided by Thinkific Inc. that helps us provide you with our services. For more information regarding our advertising networks, please visit the relevant pages that describe their practices, such as www.google.com/analytics/learn/privacy.html for Google Analytics and https://www.thinkific.com/resources/privacy-policy/ for Thinkific.

To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites. Please note that if you choose to opt out, you will continue to see ads, but they will not be based on how your online activity.

Information Collected Through Cookies and Similar Technologies. We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. If you access our Site from the EU, we will not use any cookies without your express consent. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends, and providing relevant advertising to you. (See, “Advertising” below.)

4. No information from children under the age of 18

If you are under the age of 18, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 18, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 18, please Contact Us.

5. Purpose for processing and how we share your personal data

To Provide Products, Services, and Information. We collect Personal Data from you in order to provide products and services that you purchase using the Site; register and service your online account; provide information that you request from us; contact you about your orders; process credit card and debit card transactions; send you promotional materials or advertisements about our products and services, as well as new features and offerings; administer surveys, sweepstakes, promotions and contests; provide interest-based targeted advertising to you; provide information on billing and renewal; and in any other way we may describe when you provide the information.

Additionally, if you use the Contact Us form on our Site, we will keep a record of any information entered for internal purposes only. Digital Revolver does not provide this information to any third parties. Additionally, Digital Revolver will not use this information for marketing communications unless otherwise specified in an active account.

Sharing with Third Party Service Providers. We may provide Personal Data and other information to third party service providers that help us operate and manage our Site, process orders, and create and provide products and services that you purchase from us. For example, we use a third party payment processor who must have access to the financial card information to validate payment for the products and services. Our Payment Processor’s privacy policy may be found at http://stripe.com/us/privacy. Our third-party service providers will have access to your Personal Data and other information regarding you in order to provide these services, but when this occurs, we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

We may also share your Personal Data with third parties who may contact you about their products and services that may be of interest to you.

Advertising. We may use how you browse in order to show you ads for Digital Revolver or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our Site or third-party sites not owned by Digital Revolver.

We belong to ad networks that may use your browsing activity across participating websites to show you interest-based advertisements on those websites. You can opt-out of receiving interest-based ads from us by marketingoptout@digitalrevolver.com. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites. Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity.

Third Party Advertising & Marketing. From time to time with your prior explicit consent, we may disclose Personal Data to companies who may offer you products and services of interest. You may opt-into this sharing by signing into your account and going to the “My Account” section of our Site and selecting the appropriate boxes. You may subsequently opt-out by signing into your account and unselecting these boxes or by emailing us at privacy@digitalrevolver.com.

Your Consent. In addition to the sharing described elsewhere in this Policy, we will share Personal Data with companies, organizations, or individuals outside of Digital Revolver when we have your consent to do so.

Legal Proceedings. We will share Personal Data with third party companies, organizations, or individuals outside of Digital Revolver if we have a good-faith belief that access, use, preservation or disclosure of the Personal Data is reasonably necessary to:

  • Meet any applicable law, regulation, subpoena, legal process, or enforceable governmental request.
  • Enforce applicable Terms of Use, including investigation of potential violations.
  • Detect, prevent, or otherwise address fraud, security, or technical issues.
  • Protect against harm to the rights, property, or safety of Digital Revolver, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your Personal Data on the Site to the new owner. In such a case, unless permitted otherwise by applicable law, your Personal Data would remain subject to the promises made in the applicable privacy policy unless you agree differently.

Anonymous and Aggregated Data. We may use and disclose anonymized and aggregated information about you without restriction.

Automated Processing. Digital Revolver generally does not use your Personal Data with any automated decision making process that may produce legal effects concerning you or that similarly may significantly affect you. We may, however, use your Personal Data with automated decision making to further improve our business. We may also use automated decision making with your Personal Data to detect and prevent fraud. You have the right to avoid any decisions based on automated data processing where they can be characterized as “profiling,” however in such a case we reserve the right not to complete your transaction or to refuse you access to the Site.

6. Lawful basis for processing your personal data

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies) as described below:

  • Consent. By using our Site or otherwise submitting your Personal Data to us, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use this Site or submit your Personal Data through this Site.
  • Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests, such as to facilitate communication between the Digital Revolver and you, to improve our website and the digital learning courses available on and through our Site, and to safeguard the Digital Revolver’s IT infrastructure and intellectual property.
  • To Fulfill Our Obligations to You Under the Terms of Use. We process your Personal Data in order to fulfill our obligations to you pursuant to our Terms of Use as a user of our services. This includes for the purposes of invoicing you, collecting payments, making our digital learning courses available to you and reporting your progress towards completing these courses to your employer (when applicable).
  • As Required by Law. We may also process your Personal Data to respond to legal process such as subpoenas, or as necessary for us to protect our legal interests or otherwise pursue our legal rights or remedies (for instance, when necessary to prevent or detect fraud or criminal activities), defend litigation, and manage complaints or claims.

7. Processing of do not track signals

Currently, our Site does not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads.

8. Your rights and other choices

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

Access and Update. You can access and update certain Personal Data we have relating to your online account by signing into your account and going to the “My Account” section of our Site. You may also notify us through the contact information below of any required changes or errors in any Personal Data we have about you to ensure that the Personal Data we have about you is complete, accurate, and as current as possible.

In addition, you have the right to request access to all Personal Data that we hold about you. If you make such a request to access your Personal Data (other than through the “My Account” section of our Site), you may be charged a fee subject to a maximum set by applicable law.

Restrictions. You have the right to restrict our processing of your Personal Data if you contest the accuracy of the Personal Data, if our processing of the Personal Data is determined to be unlawful, or if we no longer need your personal data for processing but we have retained it for the establishment, exercise, or defense of a legal claim.

Lodge a Complaint. You have the right to lodge a complaint with the applicable supervisory authority in your country where you believe your rights under the applicable data protection laws have been violated. However, before doing so, please contact us directly as we are committed to working with you to help resolve any concerns about your privacy.

Withdraw Consent. To the extent that processing is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on consent before your withdrawal, and it will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data as described in Section 5.

You can close your online account by marketingoptout@digitalrevolver.com. If you close your account, we will you’re your account as inactive and make it unaccessible to you and we will no longer use your Personal Data or share it with third parties except as otherwise described in this Privacy Policy. You may request us to erase your Personal Data only after the closure of your account. We will only erase your Personal Data when we no longer have a lawful basis for processing your Personal Data or after a final determination that the Personal Data was unlawfully processed. In all other cases, we will retain your Personal Data as set forth in Section 8. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained in accordance to our disaster recovery policies.

How You May Exercise Your Rights. You may exercise any of the above rights by contacting us at privacy@digitalrevolver.com. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.

Marketing Choices. When you provide Personal Data, we may offer you a choice as to whether you would like to receive further marketing and related communication from us and our third-party partners. These communications could be in the form of direct mail, email, or telephone and will contain information to inform you of ours, or our third-party partners’, products and services. You can opt-out of receiving marketing and promotional emails from Digital Revolver by going to the “my account settings” section of our Site, and by using the opt-out or unsubscribe feature contained in the emails.

9. Security of your personal data

We use appropriate physical, technical and organizational security measures, and safeguards to protect the confidentiality and security of your Personal Data. All payment transactions are processed through our Payment Processor. Our current Payment Processor is Stripe, a payment platform used by some of the largest companies in the world. Communications between us and our Payment Processor are encrypted, and our Payment Processor stores information they receive in accordance with their security measures. You may access our Payment Processor’s security measures at http://stripe.com/help/security. Our Payment Processor as of the effective date of this Privacy Policy has represented that they are PCI compliant. We do not store, process, or transmit any other cardholder data or financial data in electronic format and we only receive truncated credit card and financial account information. Our systems, policies, and procedures are designed to comply with the SAQ A data security standards issued by the Payment Card Industry Security Standards Council.

However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that your information, including your Personal Data, may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

10. Data Retention Periods RETENTION PERIODS

Digital Revolver will retain your Personal Data for as long as you continue to have an online account with us. After you close your account, we may retain your Personal Data for the longer of: (a) three (3) years, (b) as long as necessary to comply with any other legal requirement, or (c) for as long as necessary for us to protect our legal interests or otherwise pursue our legal rights and remedies.

11. California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide Personal Data in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the Personal Data we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared Personal Data for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities).

To obtain this information, please send an email message to privacy@digitalrevolver.com and specify “California Privacy Request” in the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

12. Consent to processing of personal data in the United States

Our Site and its entire contents, features, and functionality is made available to you from the United States. If you are a resident of the European Economic Area (EEA) or other jurisdiction outside of the U.S., in order to provide our Site, products and services to you, we may store your Personal Data (commonly referred to as personal data) outside of the EEA, including to the United States. We do not transfer your information from inside the EEA to outside the EEA. Instead, any information we collect is originally collected outside the EEA. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and explicitly consent to the collection to and processing of Personal Data on servers located outside of the country where they reside, and that the protection of such Personal Data may be different than required under the laws of their residence or location.

13. Change to our Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

14. Communities, Forums, Chat rooms, and message boards

Any Personal Data that you voluntarily disclose on any Site communities, message boards, forums, and blogs may be collected, accessed, and used by third parties and may result in unsolicited messages from third parties. Digital Revolver is unable to govern any third party’s use of the information that you voluntarily disclose or publish. To request removal of your Personal Data from our blog or community forum, please contact us at privacy@digitalrevolver.com, however, note that although Digital Revolver can remove the Personal Data you posted or published to any such public or Site forum, Digital Revolver has no ability to delete any copy of the Personal Data made by any third party after your disclosure.

You acknowledge and accept that any submissions to chat rooms or other public areas on the Sites are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for all activity conducted by you via communities, forums, message boards, chat rooms, blogs etc.

15. Questions and how to contact us

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, please email us and our representative in the European Union at privacy@digitalrevolver.com and we will route your email to our personnel who can help you with your question, including our European Union Representative. Alternatively, you may contact us or our representative in the European Union by postal mail at one of the following addresses:

To Contact Digital Revolver, LLC (Controller)
Digital Revolver, LLC
Attn: Legal Department
1550 Valley River
Drive
Eugene, OR 97401

To contact our Representative
[To be provided upon appointment]

To contact our Data Protection Officer
[To be provided upon appointment]

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