Effective Date 25 May 2018
Definition of Personal Information
(What is Personal Information?)
“Personal information” is any information that can be used to identify an individual, and may include, but is not limited to, for example, name, address, email address, phone number, login information (account number, password), marketing preferences, social media account information, IP addresses, location data (if combined with other identifiers), personal identification numbers (passport numbers, social security numbers, etc.), photos, video footage with your likeness, audio recordings, payment card number, criminal record, educational and professional records, and any form of biometric, health, genetic, racial, religion, political affiliation, gender-based, sexual preference, age-related, or other identifying personal data. If we link other data with your personal information, we will treat that linked data as Personal Information. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.
Collection and Use of Your Personal Information
(What Personal Information Do We Collect and Why Do We Need It?)
We may collect a variety of information, including Personal Information, about you as you use our Sites and Solutions and interact with us. For a complete listing of the Personal Information we typically collect and how we use it by Site and Solution family, please download the SU Personal Information Collection and Usage document. A summary of what we collect and how we use the Personal Information associated with our main Site and Solutions is compiled for your convenience below.
Community Membership Profile:
When you become an SU community member, we collect information about you including (but not limited to) your name, your employer’s name, your work address (including your country location), and your email address. We may also collect your personal email address, a personal mailing address, and a mobile phone number. We ask members to voluntarily provide additional information in their membership profile, such as information about their educational background, professional experience, interests in exponential technologies, a photo, social media identifiers, and some other information. Members may edit their profile at any time to change, add, or remove Personal Information.
We process your personal information for membership administration, to deliver member benefits to you, and to inform you of SU-related events, content, and other benefits or opportunities associated with your SU membership. We may also use this information to help us understand our members’ needs and interests to better tailor our Site and Solutions to meet your needs.
Members can participate in local SU chapter meetings organized by volunteers which take place at various locations. We may collect registration information from SU users, community members and their guests, which we may share with a sponsoring SU partner and location hosts for purposes of verifying registration and to ensure only registered guests are allowed attendance.
Personal Information Provided at Live or Web Programs and Events
SU hosts many events throughout the year. These include in-person and web-based conferences, summits, speakers’ series, and other in-person as well as virtual gatherings (collectively “events”). If you register for one of our events and you are a member, we will access the information in your member account to provide you with information and services associated with the event. If you are not a member and you register for one of our events, we will collect your name, telephone number, address, email address and select other information, which we will store in our database(s) and use to provide you with information and services associated with the current and future events, SU community membership and SU content.
If you are a presenter or speaker at one of our events, we will collect information about you including your name, employer, educational and professional background, contact information, and photograph. We may collect information provided by event attendees who evaluated your performance as a presenter. We may also make and store a recording of your voice and likeness in certain instances.
If you attend an in person SU event, you may be offered the option to download a mobile application to help you navigate the event and plan your schedule. This event app may require the device identifier associated with your device but does not collect or use any other personal data without your consent.
Some of our events are sponsored. We may provide an attendee list to certain sponsors. If you do not wish to have your information shared with a sponsor or to receive information from sponsors, you can express your preferences when you register for events.
Personal Information Provided to Acquire Content Access
We offer exciting content for SU’s community members and non-community members alike. In addition to producing original content, we also subscribe to news feeds and blogs produced by others, which we link to and from our website. This means you may find yourself on an SU site or reading SU content and we will offer you a link to another organization’s website where you will find content on exponential technologies or exponential thinking that we or our faculty find relevant and useful to you. At these times, you will be leaving the SU Site(s). SU is not responsible or liable for content provided by these third party websites or Personal Information they may happen to gather from you.
You may manage your SU subscriptions by subscribing or unsubscribing at any time. Please note that if you have set your browser to block cookies, this may have an impact on your ability to unsubscribe. If you have any difficulties managing your email or other communication preferences with SU, please contact us at [email protected].
We use Google Analytics to track how often people gain access to or read our content. We use this information in the aggregate to understand what content our community members find useful or interesting, so we can produce the most valuable content to meet your needs.
We also conduct surveys that we use to evaluate content quality and relevance to our SU community. We do not track individuals but look at information in the aggregate only. Participation in surveys is voluntary.
Personal Information Provided in Site or Solution Forums and Chat Rooms
Personal Information Provided for Training
You may sign up directly with us to participate in our in-person or on-line training courses delivered over a learning management system (LMS), in which case, we collect your name and contact information directly from you. Alternatively your employer or an SU partner may register you to participate in the training. Your Personal Information will be stored in our database (hosted by a cloud service provider) and may also be shared with a delivery partner or co-sponsor of the training program (to verify numbers and attendance rates), trainers (to determine the experience level, industry, and the demographics of the target audience(s)), and/or vendors supporting event delivery (to verify your identity).
Personal Information Provided in Correspondence with Singularity
If you correspond with us by email, the postal service, or other form of communication, we may retain the correspondence and the information contained in it and use it to respond to your inquiry and to keep a record of the complaint, accommodation, or other request.
If you ask us not to contact you by email at a certain email address, SU will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request.
Personal Information Provided to Process Payment
You may purchase Solutions using a payment card. Payment card information may be provided directly by users, via an SU Site or authorized third party event registration vendor site, into the PCI/DSS-compliant payment processing service to which SU subscribes. We do not process or store the card information. Occasionally, members or customers ask SU employees or SU event volunteers to enter payment card or other financial account information into the PCI/DSS-compliant payment processing service to which SU subscribes. We strongly encourage you not to submit this information by email. When SU employees receive payment card or other financial account information from customers or members by email, fax, phone, or mail, it is entered as instructed and then deleted or destroyed.
Personal Information Received from Third Parties
Periodically, SU receives Personal Information about individuals from third parties. For example, this may happen if your employer is participating in a corporate program and signs you up for an event, training, SU membership, or SU Solution access. SU may also collect Personal Information about prospective employees, faculty, vendors, contractors, and partners from due diligence vendors who conduct business and criminal history background checks on information available from the public domain.
Personal Information Collected Electronically
Personal Information Collected on Sites
We use automatic data collection tools on our Sites, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends back to our Site(s). Examples include:
- Browser type and version;
- Address of the website from which you arrived at our Site;
- Your Internet Protocol (IP) Address: this is a number automatically assigned to your computer or device whenever you connect to the Internet. It is a unique address assigned by your Internet service provider or IT department on a TCP/IP network. Among other things, the IP address allows web servers to locate and identify your device; and
- Clickstream Behavior: this includes the pages you view and the links you click. These tools help make your visit to our Sites easier, more efficient, and more valuable by providing you with a customized experience and recognizing you when you return.
Use of Google Analytics and Other Backend Analytics Tools
We use Google Analytics, a service that transmits our Site traffic to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with other data held by Google. We use reports and data provided by Google Analytics and other website traffic tracking services to help us understand our Site traffic trends and usage. For more information regarding how Google collects and processes data, please visit www.google.com/policies/privacy/partners.
If you use our Mobile App, we may collection information about the device on which the Mobile App is installed such as a device identifier (IMEI or UDID), subscriber identifier, mobile phone number, device name, type, and manufacturer, operating system type and version, wireless carrier, network type, country of origin, and IP address. We may also collect location data from the GPS on your device.
Do Not Track Option
To learn more about how to update your choices in relation to Cookies and other web browsing technologies, please go to the SU Cookies Policy.
Personal Information Use Summary
Personal Information you provide to us is used either to respond to requests that you make or to aid us in serving you better. For a more complete listing of the type(s) of Personal Information we typically collect and how we use it by Site and Solution family, please download the SU Personal Information Collection and Usage document. A summary of the ways we may use your Personal Information is set forth below:
- To create and secure your community membership account;
- To identify you as a user in our system;
- To optimize and improve our Sites, Solutions, and services;
- To deliver Solutions and services you request;
- To send you administrative email notifications;
- To respond to and track progress of your inquiries;
- To detect, investigate, and prevent illegal or non-compliant activities;
- To make phone calls to you, from time to time, to solicit feedback or provide secondary fraud protection; and
- To market SU and/or third party services of possible interest to you on our applicable Sites and Solutions.
Sharing Your Personal Information with Third Parties
(With Whom Do We Share Your Personal Information?)
We may share your Personal Information with third parties for the purposes of operating our business, delivering, improving, and customizing our Sites and Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent. We may share Personal Information in the following ways:
- Within Singularity and any of our subsidiaries or affiliates for purposes of data processing, storage, and/or marketing;
- With business partners, service vendors, or contractors to provide a requested Site content or enhancements, a Solution, a service or a transaction. Examples include, but are not limited to: processing of orders and credit card transactions, hosting websites, customer and faculty relationship management, hosting event and program planning and registration, assisting with sales-related efforts or post-sales support, delivering content, Solutions, or services, and providing customer support;
- With service vendors focused on the provision, payment, and auditing of employee, vendor, contractor, faculty and moderator benefits;
- With search engine, web analytics, and survey providers engaged to track trends and other statistics to enhance the user and member experience;
- In connection with, or during negotiations of, any merger, sale of SU assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;
- In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process;
- With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of Cisco, its business partners, you, or others; or as otherwise required by applicable law.
- In aggregated, anonymized, and/or de-identified form which cannot reasonably be used to identify you; and/or
- If we otherwise notify you and you consent to the sharing.
SU makes community member information available through its community directory, known as the SU Global Hub, using the SU Global Site. Community members are invited to opt-in to having their information shared in the SU Global Hub.
International Transfers of Your Personal Information
(Do We Send Your Personal Information Abroad?)
Singularity is headquartered in the United States and Personal Information we collect from you will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. We aim to collect and transfer Personal Information only: i) with your consent; ii) to perform a contract with you; or iii) to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
By providing us with your Personal Information, you acknowledge and agree that we may from time to time transfer any of your Personal Information to any of our offices, agents, partners, or appointed representatives located around the world. We are implementing appropriate safeguards for transfers of Personal Information originating from the European Economic Area (EEA) to countries located outside of the EEA. These safeguards include implementing standard data protection clauses that have been approved by the European Commission or (in relation to transfers from the European Union to the USA) transferring Personal Information to entities that have signed up to the EU-U.S. Privacy Shield. Please do not submit any Personal Information to us if you do not wish for your data to be transferred internationally.
Your Rights and Choices Regarding Your Personal Information
(How May I Access, Change, or Delete My Personal Information?)
SU encourages you to keep your Personal Information accurate and current. In addition, you have the right to ask us not to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.
Where you have consented to us using your Personal Information, you can withdraw that consent at any time. If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it. You may request that we erase that Personal Information or cease processing it, subject to certain exceptions. You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any Personal Information we hold about you.
You may also request information about: i) the purpose of the processing; ii) the categories of Personal Information concerned; iii) who else other than SU might have received the Personal Information; iv) what the source of the information was (if you didn’t provide it directly to us); and v) how long it will be stored.
Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.
Reasonable access to a record of your Personal Information will be provided at no cost on request made on our Personal Information Access Request Form. If access cannot be provided within a reasonable time frame, we will provide you with an estimated date when a record of the Personal Information will be provided. If for some reason we cannot supply you with a record of the Personal Information we have collected, used, and/or stored, we will provide an explanation as to why we cannot provide the record.
If you have a complaint about how we have handled your Personal Information, you may be able to ask us to restrict how we use it while your complaint is resolved. In some circumstances you can ask us to erase your Personal Information:
- by withdrawing your consent for us to use it;
- if it is no longer necessary for us to use your Personal Information;
- if you object to the use of your Personal Information and we don’t have a good reason to continue to use it; or
- if we haven’t handled your Personal Information in accordance with our obligations.
Security of Your Personal Information
(Is My Personal Information Safe with Singularity?)
We require you to enter a password to access Personal Information associated with your SU account. Please do not disclose your account password to unauthorized people.
Note, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we use reasonable efforts to protect your Personal Information, we cannot ensure or warrant the security of any Personal Information you provide to us.
Retention of Personal Information
(Does Singularity Retain My Personal Information?)
We will retain your Personal Information for the period required to fulfill the purposes for which it has been collected. These purposes may include the need to fulfill various commercial and legal requirements. Key requirements driving the need for collection, analysis and storage of Personal Information may include for example:
- Business strategy;
- Current and prospective SU community member outreach;
- Resource planning;
- Legal compliance;
- Financial reporting;
- Dispute resolution; and/or
- Asset protection and agreement enforcement.
Your Personal Information is stored by SU on servers of the cloud-based database management services we engage, located primarily in the United States. Unless you request otherwise, we will retain data for the duration of your business relationship with us or for as long as is required by law. For more information on where and how long your Personal Information is stored, please contact [email protected].
(Does Singularity Collect Information from Children?)
We encourage parents and guardians to take an active role in their children’s online activities. We do not knowingly collect Personal Information from minors under the age of eighteen (18) without appropriate parental or guardian consent. If you believe that we may have collected Personal Information from someone under the applicable age of consent in your country without proper consent, please let us know using the methods described in the “How to Contact Us” section and we will take appropriate measures to investigate and address the issue promptly.
Certain services and solutions provided by or through Singularity may be subject to additional privacy terms or Personal Information disclosures (collectively, “Additional Policies”). In the event of any direct contact between any Additional Policies and this Policy, the Additional Policies will control.
California Privacy Rights
Under California’s “Shine the Light” law, California residents may request once annually that Singularity disclose select information we have shared about them, if any, with other businesses for their own direct marketing uses. If applicable, responses will include categories of customer information and the names and addresses of the businesses with which we shared information for the immediately prior calendar year (e.g., requests made in 2012 will receive information regarding 2011 sharing activities, if any). Note that not all Personal Information or information sharing is covered by the “Shine the Light” requirements.
How to Contact Us
(How May I Contact Singularity about this Policy?)
Attn: General Counsel
Singularity Education Group
NASA Research Park
Building 20, S. Akron Road
Moffett Field, CA 94035-0001
Phone: (650) 200-3434
(How May I Contact Singularity to Request Access to My Personal Information or to Report a Suspected Breach of Personal Information?)
To Request Access to or Report a Suspected Breach of Personal Information
If you wish to engage your rights to access, correct, modify, or delete your Personal Information please complete our Personal Information Access Request Form.
If you want to report a suspected breach of your Personal Information, please complete the Suspected Breach Notification Form.
Singularity Education Group (“Singularity”, “SU”, “we”, “us”, “our”) takes your privacy very seriously, including your activities in browsing Singularity owned or controlled websites and mobile application(s) (collectively, “Sites”).
What Cookies Do We Use?
Cookies are text files containing small amounts of information. They are downloaded to your computer or device when you visit a Site. They don’t tell us who you are but they do enable us to recognize your device and where you have made various preferences or actions they enable us to remember them.
Cookies do lots of different jobs, like letting you navigate between web pages efficiently, remembering your preferences, and generally improving your experience of our Sites. They can also help to ensure that advertisements and content you see online are more relevant to you and your interests.
The cookies used on the Sites have been categorized based on function. Here are the main types of cookies we use and why we use them:
- Essential Cookies
These cookies are necessary in order to enable you to move around our Sites and use their features, such as accessing secure areas of our Sites. Without these cookies services you may have asked for, cannot be provided.
- Performance Cookies
These cookies collect information about how you use our Sites. For instance, they tell us which pages you visit most often, and if you receive any error messages from our web pages. These cookies do not identify you. All information they collect is aggregated and therefore anonymous. We use these cookies to measure and analyze how our customers use our Sites and to improve their functionality and the user experience.
- Functionality Cookies
These cookies allow our sites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, personalized features. These cookies can also be used to remember changes you have made to customizable parts of our Sites. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
- Targeting & Advertising Cookies
These cookies are used to deliver marketing and communications more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaign.