At LearningBridge, your privacy and security is a top priority. We have therefore created and adopted the following policy for personal information received from our users. This policy describes why we collect the information we do and what we do with the information we collect.
LearningBridge is committed to acting in compliance with current data protection laws, including the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Scope of Policy
This policy applies to the entire staff of LearningBridge. It does not apply to our customers running a survey on our site. If you have privacy concerns outside of our scope, then you should contact the individuals responsible for running the survey.
Information We Collect
We collect the names and gender of our users to make our surveys more customizable and targeted. We use it strictly to determine how the text is displayed/sent for a survey or invitation. When you log in to our site, you will have access to update, change or withhold this information at any time.
At LearningBridge, we collect email addresses in two ways:
- By survey administrators and participants related to a survey at the request of a client.
- By individuals who access our marketing materials and opt-in to receive communication from LearningBridge.
Here is how we will use those email addresses in each case.
Emails Provided for Individuals to Complete a Survey
- Send you an invitation to take a survey that you are invited to.
- Send you reminders to take any surveys not yet completed.
- Store your email address in a database accessible only by the LearningBridge staff.
- Make your email address available to individuals responsible for administrating the survey.
- Store the encrypted password you set for use in any future surveys you are invited to.
LearningBridge will not:
- Sell or otherwise distribute your email address or any individual user information beyond LearningBridge.
- Send you email advertisements.
Emails Provided by Those Who Opt-in to Receive Communication from LearningBridge
- LearningBridge may send you email about our services and offerings. You can unsubscribe at any time, at which point we will no longer send you those emails.
- LearningBridge will not sell or otherwise distribute your email address or any individual user information beyond LearningBridge.
We need to identify you when you log in to our site. We need a password to keep other people from impersonating you on our site.
When you are invited to the survey, a randomly generated password is generated for you. Should you choose to, you can change your password to something that is easier for you to remember. Passwords are encrypted using industry best practices and stored in a database available to the LearningBridge staff only, which is housed in a secure area and protected by a number of network security implementations.
The only time LearningBridge sends a password by email is when we provide an initial randomly generated password, or when users forget their passwords and we again send a new, randomly generated password. LearningBridge never transmits or discloses user-selected passwords, and nobody outside of LearningBridge has access to your password*, including Survey Administrators and Survey Respondents. We will not give your password to anybody.
LearningBridge does not sell or otherwise distribute your personal information to third parties. If our policy changes in the future and we do share personal information individuals will be offered an opportunity to opt-out. If there are cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US and Swiss-US Privacy Shield, LearningBridge is potentially liable. Note that LearningBridge may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Cookies are used to store information about a user on a website. Each time the user returns for a visit the site has access to the stored information. Cookies can be very useful to enhance a user's browsing experience. They are used on pages that are not designed solely for logging into the site. For example, the chat feature on the LearningBridge website saves the user's information and conversation to ensure the issue is resolved and details about issues are not forgotten.
3rd Party Advertising Cookies
LearningBridge uses third-party advertising vendors to place advertisements on other sites that users visit. Only the information about the user's IP address is shared, (see IP Addresses privacy information below). The collected information about the user's use of the LearningBridge site may be used to create online behavioral advertising to generate a personalized online experience for the user.
Every time you access our site, your computer sends us your IP address. When our server talks back to your computer, we send you our IP address. It's a reciprocal process.
When you log into our site we store the information in our "login" log file for security measures. We also use this number to count how many people visit our site. IP addresses are not linked to personally identifiable information.
LearningBridge will retain PII in our assessment database indefinitely, or until you or your employer request that we remove it. This policy allows Participants to do follow-up assessments to evaluate progress over time, and allows employers to do analysis of company trends.
Security Measures Taken
Our servers are hosted in a secured server room, and are always running with the latest available software patches installed. We have a firewall to prevent unauthorized access to our servers. Our administrative passwords are changed regularly. For more about how your data is protected on our servers, visit our web-hosting provider's web site at www.rackspace.com.
Submitting information to our website
When you submit information to our web site (such as submitting your login information to log in to the site or answering a question in a survey), your information is secure, all communications between your computer and our website are encrypted using industry standards.
GDPR for EU Individuals
Your Rights as a Data subject
The General Data Protection Regulation has been enacted within the European Union to provide specific protections for those individuals who provide personal data from those jurisdictions.
- LearningBridge will use PII data ONLY for the intended purposes.
- LearningBridge will notify you in the event of a breach or incident in which your PII data security is compromised.
- You have the right to contact LearningBridge to request the review, correction, or erasure of your PII data or to request the limitation of use and disclosure of your PII data. (see contact info below)
- You have the right to file a complaint directly with the appropriate Data Protection Authority. Please go to http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htmfor information on the identity and location of any specific EU Data Protection Authority.
LearningBridge welcomes contact and inquiries from any EU individuals with a question or complaint regarding the handling of their personal data. We can be reach at +1 801 492 1007 or firstname.lastname@example.org.
EU-US and Swiss-US Privacy Shield
LearningBridge is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). In response to a lawful request by public authorities, including to meet national security or law enforcement requirements, LearningBridge may be required to disclose an individual's personal information.
Right to Access
European Union and Swiss individuals have a right to access the personal data collected by LearningBridge. Incorrect information held by LearningBridge may be corrected or deleted by the individual. This is typically done at the LearningBridge website via the user's personal account. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his/her query to:
27 N 470 W, American Fork, UT 84003
+1 801 492 1007
If requested to remove data, we will respond within a reasonable timeframe.
27 N 470 W, American Fork, UT 84003
+1 801 492 1007
LearningBridge has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, 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. The Federal Trade Commission has jurisdiction over the LearningBridge compliance with the Private Shield. 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-eu-consumers/ 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.