ion Global Privacy Policy

LAST UPDATED MARCH 12, 2019

ion Global, Inc. and its group companies (“we,” “our,” or “us”) values the privacy of our users. This Privacy Policy covers the collection, use and disclosure of information that may be collected any time you interact with our websites, our online services or communicate with our employees (“Services”). Please read the following to learn more about what information we collect and how we use and share it. If you do not agree to this Privacy Policy, please do not use the Services.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, either through our websites www.ionlearning.com, www.inclusion360.com, www.womenevolution.com, www.womenevolution.org (“our sites”).

Information We Collect

How we collect and store information depends on how you interact with us. You can use some of the Services without providing any information other than that automatically collected as described below (for example, if you browse the Services without registering or signing in). Several categories of information are collected from you, as described below.

Information You Provide

We may collect information about you during your use of the Services, including your name, username, password, email address, phone number, other contact information, payment information, and other information you provide or post on our Services (such as your goals, job information and preferences) or allow us to access when you do certain things, such as:

  • Register to use the Services;
  • Request certain features (e.g., newsletters, updates, and other products);
  • Contact us with a question or for customer support;

The different categories of people across our sites and Services are:

  • Visitor – a person who is visiting our sites and who may fill out forms at our sites
  • User – a person who uses our Services as our customer to create or manage content
  • Learner – a person who takes a course through the ion Learning Cloud Service

Visitors:
If you are a visitor, we will only collect the information that you provide to us by filling in forms on our sites, providing us with your contact details, or by corresponding with us by phone, email, or otherwise. We maintain records of our correspondence for such period of time as we believe is reasonably required, except where you tell us otherwise.

We also use cookies on our sites, which may collect information as detailed further in the following section.

Users:
When you register for an account for one of our Services, we will collect relevant information to set up your account, such as your name, company name, and email address to be able to provide the Services.

We also collect user data on the web pages and application functionality that you access or visit as part of the Services to the extent required for the proper operation and functioning of the Services. This data is collected to deliver and improve Services and includes eLearning content tracking data generated by learners, as described below.

Learners:
When you take a course within one of our Services we will collect relevant information to set up your account, generally limited to your name, and email address, and phone number.

Where the course you take has tracking enabled (which is determined by our account owner), we will also collect data such as your quiz scores, the time you spent in training and other data related to your training performance.

Where you require information on what information of yours is collected by account owners and customers of ours and for what purposes such data is used and processed, please contact the relevant account owner and customer of our Services.

Automatically-Collected Information

Device/Usage Information.

We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, mobile device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, and the city, state and country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. As described further below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

What we do with information we collect

We want to give all of our, visitors, account owners and users the best possible services and a positive user experience. We use the information we collect from you in the following ways:

  • To provide, maintain, tailor and improve our Website and our service;
  • To provide you with customer support and troubleshoot problems;
  • To inform you about service updates and faults;
  • To request feedback or participation in online surveys;
  • To resolve disputes;
  • To verify your identity;
  • To allow you to participate in interactive features of our Services, when you choose to do so;
  • To customize, measure, and improve our software and our website;
  • To help you with questions you may have about this Privacy Policy.
  • To protect us, you and others who use our website and our Services.

Cookies and other electronic technologies.

Cookies are small data files that a web site you visit may save on your hard drive that usually include an anonymous unique identifier. Cookies do not contain information that is intended to identify you personally. When you use the Services, we use persistent and session cookies and other similar tracking technologies for various purposes, including: user authentication, keeping track of your preferences, keeping track of our audience size and traffic patterns, site administration, delivering relevant advertising, and analyzing trends. You can configure your browser to accept cookies, reject cookies or notify you when a cookie is being used.

Our sites use cookies to distinguish you from other visitors to provide you with a better experience and to help us improve our sites. By continuing to browse our sites, you are agreeing to our use of cookies as stated below.

A cookie is a small data file placed on the hard drive of your computer when you visit a website. A “session cookie” expires when you end your session (i.e. close your browser). A “persistent cookie” stores information on your hard drive so when you end your session and return to the same website at a later date, the cookie information is still available. A “web beacon” is a small string of code that represents a clear graphic image, a redirect URL or JavaScript and is used in conjunction with a cookie.

However, if you configure your browser to reject cookies, you may not be able to use our products or services that require you to sign in or take advantage of all their features.

Information from Third Parties

We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from or about you with information we obtain about you from such third parties or affiliates.

Anonymous or De-Identified Data

We may anonymize and/or de-identify information collected by the Services or via other means so that the information does not identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

How we share your information

We do not share, sell, rent or otherwise distribute your information to others, except as disclosed in this Privacy Policy. We may share your information with others outside of ion Global under any the following circumstances:

  • We have your explicit consent to share the information.
  • We need to share your information to fulfill your product or service request, such as with a service provider who is working on our behalf.
  • We wish to contact you with information about products and services from our business partners.
  • It is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service of the specific Service, or as otherwise required by law
  • As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets. In this event, we will notify you before information about you is transferred and becomes subject to a different privacy policy.

Our sites may, from time to time, contain links to and from the websites of our group companies, partner networks, clients, and/or affiliates. If you follow a link to any of these websites, please note that these websites are subject to their own privacy policies and that we do not accept any responsibility or liability for these sites and policies. Please check those policies before you submit any personal data to these websites.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US or Swiss-US Privacy Shield Frameworks, we are potentially liable.

Online analytics & tailored advertising

Online Analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in the Automatically-Collected Information section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on by clicking here.

Tailored Advertising

Third parties whose products or services are accessible or advertised via the Services may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to help them (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites. We may also allow other third parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising (i.e., not just for the Services), you may visit the Network Advertising Initiative’s Consumer Opt-Out Link and/or the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Links

The Services may contain links to other sites and services. ion Learning is not responsible for the privacy policy or other practices employed by sites and services linked to or from our Services nor the information or content contained therein. This Privacy Policy solely to information collected by our products and services.

How we secure your information

We understand that the security of any data we collect as part of you visiting our site and/or using our Services is of great importance to you. We therefore make sure it is well protected.

Although we own the code, databases and all rights to our software applications, you retain all rights to your own data. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personal information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

Children

The Services are not intended for persons under the age of 13. We require that only persons 13 years of age or older use the Services. By using the Services, you hereby represent that you are at least 13 years old. If we become aware of a user under the age of 13, we will make reasonable efforts to promptly delete that user’s information.

California do not track policy

We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes, and that is why we provide above the NAI “Consumer Opt-out” link, DAA opt-out link, and Google opt-out link. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.

Changes to this privacy policy

We reserve the right to change this policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this policy will mean you accept those changes. If we make any material changes to this Privacy Policy, we will post the updated Privacy Policy here and notify you by email or by means of a notice on our website prior to the changes becoming effective.

EU-US and Swiss-US Privacy Shield Framework

We comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. We have certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your information. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at: privacy@ionLearning.com

We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles through the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

If you are using our Services from within the European Economic Area or other non-U.S. territories, please note that any information we collect from and about you may be transferred outside the European Economic Area or those other non-U.S. territories for use by us for any of the purposes described in this Privacy Policy. In addition, because we operate globally, we may make information we gather available to worldwide business units and affiliates under the terms of this Privacy Policy. By providing us with information, you hereby expressly consent to such transfers of your data to the United States or other countries, except in the case of data transfers from the European Economic Area or Switzerland, which are covered under our EU-US and Swiss-US Privacy Shield Frameworks detailed above. For users from outside the US, Switzerland or the European Economic Area, please note that laws in the US or other countries may not provide the same level of protection for your information as the laws of your country of residence.

Your communication choices

Information collected by us is used for the purposes set forth in this Privacy Policy, and is subject to the choices discussed throughout this Privacy Policy. We also provides opt-out information in all marketing communications via an “unsubscribe” link in communication emails, which directly unsubscribes you from any further communication from us. Please note that it may take us some time to process your requests consistent with applicable law. Note that you do not have the ability to opt-out of non-marketing communications that we send if you are a registered user of our Services or if you have engaged in transactions with us. Upon request from you to correct or delete your data, we will make reasonable efforts to promptly correct or delete such data.

Your California privacy rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to privacy@ionLearning.com.

Federal Trade Commission

Ion Global, Inc is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Contact us

We welcome your feedback regarding this Privacy Policy. If you have questions, comments, or concerns about either one, please contact us by e-mail at privacy@ionLearning.com or postal mail at:

ion Global, Inc.
9191 Towne Centre Dr
Suite 310
San Diego, CA 92122

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