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Privacy Policy

What Data Do We Collect About YouHow We Collect This DataWhat Is the Basis for Our Personal Data CollectionHow We Use Your Personal DataOptional Voluntary InformationRegistration and Information Request FormsSharing of Voluntary InformationOpting OutPublic ForumsLinksChildrenSecurityYour ConsentPrivacy Policy UpdatesContacting the WebsiteSafe HarborIndependent Recourse MechanismPersonal Identification InformationNon-Personal Identification InformationWeb Browser CookiesHow We Use Collected InformationSharing Your Personal InformationLegal Basis for Processing InformationUser’s RightsSecurity, Storage, and Transfer of InformationThird Party WebsitesCompliance with Children’s Online Privacy Protection ActChanges to this Privacy PolicyYour Acceptance of these TermsContacting UsHow We Use Cookies and Usage DataHow Marketing Uses Personal DataHow You May Control, Rectify and Erase Your Information; Data PortabilityThird-Party WebsitesSecurityChildren’s PrivacyIntroductionInformation We Collect About You and How We Collect ItInformation You Provide UsInformation Provided to Us from OthersInformation We Collect Through Data Collection Technologies About Customers, Authorized Users, and VisitorsHow We Use Information About YouHow We Share Information About YouWhat We Will Not Do With Customer Learner Personal InformationYour Options And Rights Regarding Your InformationData SecurityData RetentionInternational UsersChildren Under The Age Of 13Changes To Our Privacy PolicyContact InformationJurisdiction-Specific Information

Who We Are: Welcome to the website of ELB Learning located at (the “Site”).  In this Privacy Policy, “ELB Learning” “we”, “us” and “our” all refer to ELB Learning, and “you” and “your” refers to you as a visitor to the Site or user of the software solutions of ELB Learning (“Products”).  ELB Learning is a developer and world leader in end-to-end eLearning software solutions consisting of authoring, reviewing, publishing and course management tools.  Our solutions are used by major organizations and governments around the world, which drive innovation and improve delivery of training and certification for employees, partners and clients, providing transformational courses for the digital world.  We care about your privacy, and strive to comply with applicable laws where we operate.

Authoring Tools Overview

What Data Do We Collect About You. This Privacy Policy explains what personal data we collect about you, which includes (a) identity data (first name, last name, maiden name, and could include title, date of birth, gender), (b) contact data (your physical address, billing address, delivery address, email address and telephone numbers). When you make purchases from ELB Learning or the Site, you also are asked to fill in some (c) financial data, such as credit card information, but that is not available to ELB Learning, and actually is collected on a third-party payment website that is compliant with credit card security standards (PCI-DSS). When you make a purchase on the Site, we also maintain (d) transaction data about products purchased from us and payments made. We may collect (e) technical data when you make use of the Site, such as your internet protocol (IP) address and browser, often using cookies, as well as (f) profile data (login information: user name and password) which you may enter for such purposes as when you create a Community account. We collect (g) usage data, retained in the aggregate and anonymized, about website usage, and certain (h) marketing and communications data, such as whether or not you want to join a User Group (requiring an opt-in to receive notices and announcements regarding meetings and other Group information), or to subscribe to the Blog or receive offers and discounts by email. Much of this, but especially information that identifies you personally, and financial information about you, is called “personal data” in this Policy.

We collect only personal data that we believe to be strictly necessary in order to provide you with the Site services to which you indicate a desire to subscribe, or the Products which you desire to purchase/license.  In each case, you are given the option of providing the personal data, if you wish us to fulfill delivery of the Site service or Product in question, or not provide it (except for certain technical data and website usage data, which are used to facilitate and enhance Site usage, and in most cases is only retained and used in the aggregate generally anonymized and de-identified).

How We Collect This Data. Much of the data we collect from you is collected on the Site. For example:


If you click the “Get in Touch” bar on the ELB Learning Complete webpage, regarding the Product ELB Learning Complete or another solution, we collect your Name, Email Address, Phone, Company, State if applicable, and Country.


If you click “Free Trial” on the Lectora Online channel on the Products webpages, we collect your Name, Email Address, Company and Phone.


If you click “Buy Now” on the Lectora Online channel or any other Product channel or the Shop webpage, you must fill in Name, Email Address, Company, Phone, Physical Address, and also the requested billing information, including Credit Card information.


If you click Upgrade on the Lectora Inspire or Lectora Publisher channel, in addition to Name, Email Address, Company and Phone, you must input your Lectora Product License Key.


If you already have an ELB Learning account, or a Product account (such as CourseMill), you will be asked to input your User ID and Password.


If you wish to participate in the ELB Learning Community, you will be asked to Register or Log In, and to Register you need to provide Email Address, Name, Company, Website or Linked URL, and to choose a Password.


If you wish to subscribe to the ELB Learning Blog or to get offers and discounts by email on the Shop channel, you will be asked to provide your Email Address.


In general, these options (Free Trial or Request a Demo, Buy Now, Upgrade, Log In) exist for most ELB Learning Products, and you drive what personal data you are asked to provide based on what you want to do relating to our solutions.  We seek what is necessary to fulfill a contract with you, or in the case of Free Trials, to contact you afterwards, based on your consent.

What Is the Basis for Our Personal Data Collection. We have explained what personal data we collect, how and why.  Under certain laws applicable to European residents who may use our Site services and Products, such as the General Data Protection Regulation (GDPR), we need to clarify the basis for the collection of your personal data.  In many cases of data collection described above, we collect the personal data we need to perform the contract we are about to enter with you, or which we have entered with you.


Contractual Basis: If you indicate that you want to purchase a Product from us, we need you to provide the identity, contact, financial and possibly transaction data described above, so that you can pay for the Product purchased and we can deliver it, although as mentioned, we do not retain any credit card data, which is provided and maintained on a third-party [payment processing] site with commercially appropriate security and data protection for such financial data.  Therefore, this has a contractual basis: we need this information to be able to perform a contract with you.


Legitimate Interests: If you indicate that you want to participate in the ELB Learning Community, or you want to receive special offers from ELB Learning, then you understand that it is reasonable for us to collect the personal data necessary to be able to provide you with the offer or item or participation you have requested, even if it falls short of a contractual requirement. Moreover, when we collect data analytics to improve the user experience, we believe that our users recognize that there would be legitimate interests in our doing so.


Consent: When we obtain your data so that we can make further contact with you, so that you might choose to buy/subscribe to a Product, but there is no requirement that we collect your data to achieve this result, such as when we ask for your Email address before you can open a Demo, we will seek your consent, and you will have the rights to revoke that consent as indicated below.  Often there is a marketing objective when we ask for your consent.  And we also seek your consent when persistent cookies are placed on your device to ensure a better user experience.

How We Use Your Personal Data. We primarily use personal data that you provide to us market, sell, license and deliver our Products or services to you, as described above, or to maintain, customize and add new resources and products and services that may be of interest to you, to enable you to participate in Site services such as the ELB Learning Community, and to allow communication and interaction between you and ELB Learning. In addition, we will share the personal data we collect from you under the following circumstances:


Protection of Rights. We will share personal data if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the Terms of Use for the Site, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Products or Site services, or (iv) such action is appropriate to protect the rights, property or safety of ELB Learning, its employees, customers, Site users, or others.


Asset/Equity Transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of ELB Learning’s assets or equity, information on customers and Site users, including personal data collected from you through your use of the Site and its services, could be included in the transferred assets, subject to applicable law. Users of the Site will be notified via a prominent notice on the Site prior to a change of ownership or control that would involve a transfer of your information held by us, subject to applicable law, including any statutory periods restricting disclosure.


Service Providers. In the event that we engage service providers as data processors on our behalf, then subject to appropriate confidentiality and security measures, including compliance with this Privacy Policy, we may share your personal data with them.  Any such third-party data processors are and/or will be subject to contractual agreements to ensure that they only process personal data provided by ELB Learning in a manner consistent with our obligations under GDPR requirements as more fully described and made accessible to you below. ELB Learning remains liable under such Principles if its agent processes your personal data in a manner inconsistent with the Principles, unless we can prove that we are not responsible for the event giving rise to any damage.


Marketing Purposes. We will occasionally use your personal data for our own marketing purposes, subject to applicable law, and subject to your clearly indicated right to opt-out of receiving any such communications from us. If you are a resident of the European Union, we will require your express consent in order to be able to send your marketing-related communications. See the expanded Marketing section below.


Usage Data. We may share Usage Data and other aggregated, anonymized information that shows patterns, trends, preferences, and other collective characteristics of our customers and Site users, with third parties. Disclosure of this information helps us and our marketing partners evaluate and tailor our communications, advertisements, services and general business practices to the needs of our Users.


Public Authorities. We may disclose your personal data in response to lawful requests by public authorities, including to meet national security or enforcement requirements.

Template and Asset Library Overview

The following discloses the information gathering and dissemination practices for our website: ‘ELB Learning’ (the "website").

‘ELB Learning’ gathers visitor information in the following two ways:


Information provided voluntarily in order to request our electronic newsletters and class schedules, register for courses, etc.; and


Information gathered through aggregated tracking information derived mainly by tallying page views and similar visitor activity thereby allowing us to better tailor our content to visitors’ needs.

Optional Voluntary Information

Electronic Newsletters (Dispatches)

‘ELB Learning’ distributes electronic newsletters and class announcements. In so doing we gather the e-mail addresses of the visitors who want to be included on our distribution. Subscribers to these emails may remove themselves from this mailing list by unsubscribing on each email’s subscription management page.

Registration and Information Request Forms

‘ELB Learning’ offers online registration for events and courses which ask the website visitor to voluntarily provide personal information. The website's registration forms may ask website visitors for contact information (like their name and email address), and/or financial information. We may also ask the website visitor to voluntarily provide personal information such as names and addresses.

Sharing of Voluntary Information

‘ELB Learning’ does not voluntarily sell or disclose personal information gathered through the website without permission.

Opting Out

To opt out from any future mailings or to opt out of having personal information shared with Affiliates, Resellers, and Licensee Partners of ELB Learning please call or email the contact information posted on our contacts page.

Public Forums

The website may make forums, message boards, and/or news groups available to its visitors. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.


The website contains links to other sites. ‘ELB Learning’ is not responsible for the privacy practices or the contents of such other websites. Use these linking features at your own discretion.


Consistent with the Children’s Online Privacy Protection Action of 1998, the ‘ELB Learning’ will not knowingly request personally identifiable information from anyone under the age of thirteen without first requesting parental consent.


‘ELB Learning’ operates secure data networks protected by industry standard firewall and password protection systems [specifically Secure Socket Layer (SSL), other server authentication or data encryption products]. Although our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized individuals are given access to the information provided by our visitors, perfect security does not exist on the Internet. We cannot guarantee that any visitor information will remain secure and therefore you should use extreme caution when revealing information on the website.

Your Consent

By using this site, each website visitor hereby consents to the collection and use of information as disclosed herein by the ‘ELB Learning’.

Privacy Policy Updates

This privacy statement will be continuously assessed with respect to new technologies, business practices and our visitors’ changing needs. ‘ELB Learning’ may change its privacy practices from time to time. If we make any changes, we will update this privacy statement accordingly (the date of the most recent change is displayed at the bottom of this statement).

Contacting the Website

If you have any questions about this privacy statement, the practices of the website, or your dealings with the website, you can use the contact information posted on our contact page to contact us.

Safe Harbor

This website has certified its adherence to the US-EU and US-Swiss Safe Harbor Privacy Principles. For further information on Safe Harbor please visit

Independent Recourse Mechanism

The recourse mechanism for ELB Learning is the American Arbitration Association.

This Privacy Policy governs the manner in which ELB Learning collects, uses, maintains and discloses information collected from users (each, a “User”) of the website (“Site”). This policy is in line with the EU General Data Protection Regulation (GDPR). This privacy policy applies to the Site and all products and services offered by ELB Learning and covers the following:


What information is collected


How we use collected information


Sharing your information


Legal basis for processing information


User’s rights


Security, storage, and transfer of information


Third party websites


Compliance with the Children’s Online Privacy Protection Act


Changes to the Policy and Contact Information


Your acceptance of these terms


Contacting us

What Information is Collected

Personal Identification Information

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, place an order, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email and address, phone number. ELB Learning does not store financial, health, government, or other kinds of more sensitive user information. Users may visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site-related activities.

Non-Personal Identification Information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about User’s means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

Web Browser Cookies

Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How We Use Collected Information

ELB Learning may collect and use User’s personal information for the following purposes:


To improve customer service


Information you provide helps us respond to your customer service requests and support needs more efficiently.To personalize user experience


We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.To improve our Site


We may use feedback you provide to improve our products and services.To process payments


We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.To run a promotion, contest, survey or other Site feature


To send Users information they agreed to receive about topics we think will be of interest to them.To send periodic emails


We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

Sharing Your Personal Information

We do not sell, trade, or rent User’s personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

Legal Basis for Processing Information

ELB Learning only collects information with User’s consent. Any User may withdraw their consent and have their personal information removed from ELB Learning databases. User information is used for legitimate Interests in the course of marketing, sales or other legitimate purpose as outlined in the section of How we use your collected information.

User’s Rights


Users have the right to withhold their personal information


Users have the right to request ELB Learning via email at the following:


What User information ELB Learning has


With whom ELB Learning has shared User’s information


Users have the right to withdraw their consent for personal information and to have ELB Learning remove their information from ELB Learning database

Security, Storage, and Transfer of Information

ELB Learning uses Amazon Web Services (AWS) as its cloud services provider. AWS provides the physical security of the cloud and uses the most advanced security protocols to do so. In addition, to the extent the seven principles relate to AWS services, AWS complies with those principles. It has fully registered under the Privacy Shield framework, so any processing accomplished by AWS is fully authorized under EU law. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

Third Party Websites

Users may find advertising or other content on our Site that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Compliance with Children’s Online Privacy Protection Act

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Site from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

Changes to this Privacy Policy

ELB Learning has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your Acceptance of these Terms

By using this Site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting Us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us at:

732 E Utah Valley Dr Suite 100
American Fork, UT 84003

Cookies and Usage Data

1. How We Use Cookies and Usage Data.


Cookies. “Cookies” are small bits of electronic information or files that a website sends to your browser for storage on your hard drive, which makes your interaction with the Site more efficient by remembering you, so for example you may not have to reenter a User ID on a subsequent Site visit. Like most websites, we employ the use of "cookies" on our Site so that you can navigate easily on the Site, as well as to collect Site analytics (usage data), which generally are used on an aggregate and de-identified basis to improve the Site experience.  Cookies may also be used to allow us to provide information that is targeted to your interests and optimizes your online experience, such as information of potential interest to you based on your use of the Site and certain channels on it. Most cookies are "session cookies," meaning that they are automatically deleted at the end of your session.  You always have the right to decline our cookies by setting your web browser to reject cookies, generally found in the browser’s Tools or Options menu, although this may adversely affect the usability of the Site or make certain features unavailable to you. If you are a resident of the European Union, you will be given the opportunity to consent to store the described cookies on your device (other than those that are essential to provide a service) in order to continue to use the Site and its offerings. To review ELB Learning's complete Cookie Policy, please click here.


Additional Information about Site Usage Data. Tracked information: our servers automatically track certain information about you as you use our Site, some of which may contain personal data. This information may include the URL that you just came from, which URL you go to next, what browser you are using, which webpages and services you use on the Site, how long you spend on particular webpages, and your IP address. Our Site logs track and collect aggregate and sometimes anonymized or de-identified Site usage data, such as the number of hits and visits to our Site (“Usage Data”). This information is used for internal purposes by technical support staff to provide better services to you, the public and Site visitors and may also be provided to third parties, but the statistics are aggregate and contain no individual personal data. We do not ask for, collect or knowingly receive sensitive personal data. To the extent that the aggregate and anonymized Usage Data is obtained from European residents and is not fully de-identified, either we will rely on the legitimate interests of ELB Learning in collecting such data to provide a better Site experience, or we will ask for your express consent.

2. How Marketing Uses Personal Data.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.


Promotional Offers from Us. We may use your Identity, Contact, Technical, Usage and Profile Data to determine what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased Products from us and, in each case, you have not opted out of receiving that marketing.


Third-party Marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.


Opting Out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of Products or similar transactions.


Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3. How You May Control, Rectify and Erase Your Information; Data Portability.


Residents of European Union and Switzerland: Personal Data Control Rights. You have the rights to (i) request access to your personal data, and receive a copy of it and to check it we are lawfully processing it; (ii) request correction or rectification of your personal data, which means to have incomplete or inaccurate data we hold about you corrected, subject to our right to verify the accuracy of the new data you provide; (iii) request erasure of your personal data, where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we must erase your personal data to comply with applicable law.


Additional Commentary and Right to Restrict Processing. To provide a bit more detail, you can request rectification verbally or in writing, and we will respond within 30 days if your request is appropriate. While we are checking out your request, you have the right to ask that we restrict the processing of your personal data. After review, we may respond that we believe the personal data is accurate, and we will not be amending it. If we believe that your rectification request is manifestly unfounded or excessive, or repetitive, was may condition our response on your payment of a reasonable fee to deal with your request, or refuse to deal with it, explaining our decision. In either case, you can then make a complaint to the pertinent data protection authority as indicated below.


GDPR Rectification Requests. We suggest that you send any request to, and call it “GDPR Rectification Request” in the header. This is not a legal requirement, but it increases the likelihood of a timely response if we can catalog your request. If your request is complex or part of multiple requests from you, we have the right to extend our response time by an additional two months provided we keep you informed. If we are uncertain or suspicious about the identity of the person making the rectification request, we can ask you for additional ID.


Right to Erasure: Some Limits. The right to “erasure” of your personal data is sometimes called the right to be forgotten. However, you only have the right to erasure if our basis for holding your personal data is consent, because your giving consent implies your right to reverse your consent. However, much of the personal data we hold is NOT based on your consent, but rather has another basis such as a contractual or legitimate interests basis. For example, if we hold personal data about you as a party to which we have fulfilled a license of software, and we are continuing to provide support services, we are under no obligation in such circumstance to remove your personal data (or existence) from the case record. In relation to a request for erasure, we will not charge any fee.

We mentioned above that you have the right to request us to restrict the processing of your data, and we will not charge a fee for this provided that the request is not excessive or unreasonable. You have this right in the following circumstances: (i) you contest the accuracy of the personal data; (ii) the personal data has been unlawfully processed, but instead of erasure, you want processing restricted; (iii) we no longer need the personal data, but you would like us to keep it in order to establish, exercise or defend a legal claim; or (iv) you object to our processing of personal data, but we have not yet responded to your request. At that point we will store but not process the data, and we will not lift the restriction until we have rendered a decision on the accuracy of the data or whether our grounds for resuming processing override your legitimate grounds for restriction. We will inform you of our decision before lifting the restriction.


Data Portability: if we process your personal data by automated means based on your consent, or performance of a contract, and not another legal basis, then you have the right to request that we provide you a copy of your personal data in a structured, commonly used, machine-readable form, such as a CSV file. We will do this free of charge. If it is technically feasible, you can request that we transmit the personal data directly to another organization, rather than to you. We will respond to your request within 30 days, unless the request is complex or you send us multiple requests, in which case we have the right upon notice to you to extend our response by another two months. We also have the right to obtain sufficient information about your identity to ensure that the request is not fraudulent. If we determine that access should be restricted, we will provide you with an explanation as to why we made that determination, and give you a contact point for any further inquiries. For example, if we are unable to separate confidential commercial information from your personal data, we have the right to deny or limit access to avoid revealing such confidential commercial information or redact the confidential commercial information. Moreover, we have the right to set reasonable limits on the number of times within a given period you have the right to make access requests, so as to limit repetitious or vexatious requests.


Data Protection Authority for EU Residents. Given that our only data center in the European Union is at Amazon Web Services in Ireland, we suggest that the Irish Data Protection Commissioner would be the appropriate Data Protection Authority (DPA) for recourse under the GDPR for any cross-border processing activity, or that involves citizens of more than one EU country, if you are dissatisfied with our handling of your request.


All Other Users (Outside EU). You have the right to access your personal data. You may choose to opt out of certain disclosure if you do not want your information to be disclosed to a third party or to be used for a purpose materially different than the purpose for which it was originally collected or subsequently authorized by you (unless the disclosure is merely to an agent performing tasks for us under our instructions or control). You may request that we update, correct, amend or delete any of the personal data or other information we have collected from you, or you may opt out of receiving ELB Learning emails and other communications, by sending an email to us at We may choose not to fulfill any request that we determine is illegal or incorrect, where we need to maintain the personal data because of our contractual or legal obligations (e.g., personal data in case files), where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated, but our intention is to comply with opt-out requests, and other requests that seek to correct, update or delete your personal data, as fully as possible in accordance with applicable law.


Sensitive Personal Data. We do not ask for, collect or knowingly receive sensitive personal data, i.e., personal data specifying medical or health conditions, racial or ethnic origin, political opinions, religious beliefs, or information relating to sex life (unless this is part of case information that we administer). Organizations that seek or disclose such sensitive personal data must receive your affirmative express consent (opt in) before disclosing it to a third party or using it for a purpose other than that for which it was originally collected or subsequently authorized.

4. Third-Party Websites.

While using the Site and its various channels and services, you may have access to or link to third-party websites, or your use of the services may involve transfer to a third-party website, e.g., you may be referred to a payment processor website to provide credit card information. Linked third-party websites are independent of ELB Learning, and have their own terms of use/service and privacy policies, which govern your use of such websites. Any link does not imply ELB Learning endorsement of the third-party website.

5. Security.

Any personal data that you provide to us is stored on servers located in secure third-party data centers with restricted access, and which are protected by protocols, procedures and best practices designed to ensure the security of such information. In addition, we restrict access to personal data to ELB Learning employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Site and Products, and are subject to confidentiality obligations. For further information, please see ELB Learning Information Security Policy here. However, no server, computer or communications network or system, or data transmission over the Internet, can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee the security of any information you transmit to us or through the use of the Site or any of the services. In the event that we believe that there has been a security breach involving your personal data, we would endeavor to notify you promptly in accordance with applicable law. In the event such notification is appropriate under the circumstances, we would first try to notify you at the latest email address we have for you on record, subject to legal requirements.

6. Children’s Privacy.

The Site is a general audience website not intended for any person under 18 years old. We do not knowingly collect personal data from any person under the age of 13.

The Training Arcade® Privacy Policy


The Game Agency, LLC (“TGA,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy describes how we collect, use, and disclose information we may collect about you in your capacity as a Customer, Customer Administrator, Customer Learner, or Visitor when you use or any of its Customer-specific subdomains, or you otherwise access games hosted by TGA (the “Service”). The Service allows Customer to designate Customer Administrators to customize a library of game types with the Customer’s content and/or to create a gamified destination to house the games in an arcade (“Arcade™”) for social learning by Customer Learners.

This policy applies only to information we collect from Customers, Customer Administrators, Customer Learners, and Visitors on this Service when creating the games, playing the games, email, online forms, text, and other electronic messages between you and us regarding the Service. It does not apply to information collected: (a) from any other service operated by TGA (including, which have their own privacy policies, or (b) by any third-party including through any application or content (including advertising) that may link to, or be accessible from or on the Service, such as an LMS or eLearning authoring tools.

Information We Collect About You and How We Collect It

We may collect information that qualifies as “personal information” or “personal data” under the law applicable to you. We prohibit Customers from sending us any of the following data: (1) special categories of data enumerated in European Union Regulation 2016/679, Article 9(1), any successor legislation, and any applicable United Kingdom laws including the U.K. GDPR; (2) patient, medical, or other protected health information regulated by the Health Insurance Portability and Accountability Act (as amended and supplemented) (HIPAA); (3) credit, debit, or other payment card data or financial account information, including bank account numbers; (4) credentials granting access to an online account (e.g. username plus password); (5) social security numbers, driver’s license numbers, or other government identification numbers; (6) other information subject to regulation or protection under specific laws such as the Children’s Online Privacy Protection Act or Gramm-Leach-Bliley Act (or related rules or regulations); or (7) any data similar to the above protected under foreign or domestic laws; and shall not use the Product or Services in connection with any activities where its use or failure could lead to death, personal injury, or environmental damage, such as in life support systems, emergency services, nuclear facilities, autonomous vehicles, or air traffic control.

Our purposes and means of collecting information depend on your status as a Customer, Customer Administrator, Customer Learner, or Visitor.

Authorized User:Authorized User” is a Customer Administrator and/or Customer Learner.

Customer: “Customer” is the customer that subscribes to The Training Arcade.

Customer Administrator: “Customer Administrator” is designated by Customer to customize game and other content, access results data, invite and authorize Customer Learners to play the games, or add or remove certain features available to Customer Learners.

Customer Learner: “Customer Learner” is invited and authorized by a Customer Administrator to play the games for educational or marketing purposes. For example, a Customer may use the Service (i) to create customized corporate training for its employees (who are the Customer Learners), (ii) at tradeshows for its own marketing purposes to engage with and collect contact information of booth visitors/attendees (also, Customer Learners), or (iii) on Customer’s website to educate its website visitors (also, Customer Learners) about its products, services, or mission. A Customer Learner accesses the Service via the Customer’s website, learning management system (“LMS”), Single-Sign On (“SSO”), a link provided to a Customer Learner by Customer Administrator, or another method selected by the Customer. TGA processes Customer Learners’ data according to its agreement with the Customer. Customer Learners are also subject to their respective Customer’s privacy policies, which we do not control.

Reseller: “Reseller” is a company that we authorize to sell the Service to Customers.

Visitor: “Visitor” is anyone who visits our Service and is not an Authorized User. Visitors may, for example, play our publicly available games or sign up for information about our Service. TGA processes Visitors’ data as a controller and consistent with this Privacy Policy.

Information You Provide Us
The information we collect on or through our Service may include the following, depending on whether you are a Customer, Customer Administrator, Customer Learner, or Visitor:

If You Are a Customer or Customer Administrator:

  • Information that you provide by filling in forms associated with our Service. This includes information provided at the time of registering to use our Service, engaging with a customer service “chat bot” to assist you in using the Service or requesting further services.
  • Records and copies of your correspondence (including email addresses), if you contact us, for example, regarding customer support.
  • Customer Data. Each Customer may provide us with contact information about its authorized agents (e.g., an employee, agent, or independent contractor of Customer who is designated by Customer as a Customer Administrator) and its authorized Customer Learners.
  • Customer Content. Customer Administrators may provide information to be published or displayed (hereinafter, “posted”, or “post”), such as content uploaded to customize games in The Training Arcade® by Customer Administrators (e.g., questions, answers, images) (“Customer Content”). Although we limit access to certain pages, please be aware that no security measures are perfect. Therefore, we cannot and do not guarantee that your Customer Content will not be viewed by unauthorized persons.
  • Customer Administrators’ search queries on the Service.

If You Are a Customer Learner:

  • Registration information you provide to play a game, such as first name, last name, and email address.
  • Details of activities you carry out through our Service, including the answers you provide to questions in the games and time spent playing each game. If you participate in an Arcade, we collect information such as experience points and prizes collected.
  • Records and copies of your correspondence (including email addresses), if you contact us, for example, regarding customer support; we will generally direct Customer Learners to the Customer Administrator for support questions.
  • Learner Content. Customer Learners may post information, such as leaderboard names, scores, and comments (collectively, “Learner Content”) to game leaderboards, through social media sites such as Twitter™, or through internal communication business applications such as Slack. Customers determine whether to directly post or allow their Customer Learners to post Learner Content. Your Learner Content is posted on our Service or third-party social media sites and transmitted to others at your own risk.

If You Are a Visitor:

  • Information that you provide by filling in forms on our Service. This includes information provided at the time of registering to use our Service, signing up to receive marketing emails from us, engaging with a customer service “chat bot” to assist you in using the Service or requesting further services, and scheduling an appointment to receive a demonstration or discuss our Service.
  • Records and copies of your correspondence (including email addresses), if you contact us, for example, regarding customer support.
  • Search queries on the Service.

Information Provided to Us from Others

Information Provided to Us by Customers About Their Customer Learners:

Customers may provide us with Customer Data that includes information about Authorized Users. For example, an employer may provide us with the company email addresses, names, and company IDs for those of its employees it invites to use the Service as Customer Learners. Similarly, a company using the Service to run a game tournament on its website may provide us with email addresses or some other unique identification, as determined by the Customer, for its Customer Learners who want to participate so that we can enable access to the Service on behalf of the Customer to its authorized Customer Learners. If the Customer has implemented the “challenge a colleague” feature, allowing Customer Learners to invite other Customer Learners (of the same Customer) to play a challenge game, the Customer will provide us with the list of Customer Learners authorized to use this feature, including the name of the Customer Learners as well as their email address.

Information Provided to Us from Resellers About Customers:

Resellers may provide us with the same information that Customers provide.

Information Provided Through Use of Social Networks by Customers and Authorized Users:

Customers may permit Customer Learners to share information about themselves, such as their position on a leaderboard, on social media networks (like Slack, Facebook, Twitter, and Google). For example, certain games in our Service may allow you to share your score through your Twitter™ account. If you share Learner Content with a social media network, please be aware that such content may become public. TGA does not have the ability to control Learner Content, including by deleting it. Once you share Learner Content with a social media network, it may collect, use, and disclose that content and any information associated with it according to its privacy policy, not ours.

Information We Collect Through Data Collection Technologies About Customers, Authorized Users, and Visitors

As you navigate through and interact with our Service, we may automatically collect certain information about your equipment, browsing actions, engagement on the Service with content and activities, as well as your browsing patterns, including:

  • Details of activities Customer Administrators carry out through our Service, including to create games using uploaded Learner Content, determine the method of game access and distribution, invite users to play the games, and analyze the results of the gameplay.
  • Details of your visits to our Service, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Service.
  • Information about your computer and internet connection, including your IP address, platform, operating system and browser type.

The information we collect automatically is both statistical data and individual. This data helps us to provide and improve our Service and to deliver a better, more secure, and more personalized service by enabling us to, for example:

  • Estimate our audience size and usage patterns for our Customers and for ourselves (with respect to Customer Learners, using aggregated and/or de-identified data).
  • Store information about your preferences, allowing us to customize our Service according to your individual interests; with respect to Customer Learners, as authorized or instructed by the applicable Customer.
  • Recognize you when you return to our Service and where you left off.
  • Provide data to Customers about their Customer Learners (e.g., providing an employer information about an employee’s engagement with our Service).
  • Speed up your searches.
  • Support our company growth, publicity, and marketing efforts; with respect to Customer Learners, using aggregated and/or de-identified data.

The Technologies We Use for This Automatic Data Collection May Include:

  • Cookies (or browser cookies). A “cookie” is a small data file that a website sends to and stores on your device that allows the site to recognize your browser or store information or settings. The cookie itself does not contain directly identifiable data but can be read by the entity that placed the cookie and may allow it to associate your device to other data about you.
  • Web Beacons. Pages of the Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit TGA, for example, to count users who have visited those pages or opened an email and for other related Service statistics (for example, recording the popularity of certain Service content and verifying system and server integrity). For further information visit

Please click here to find out more about the cookies that are used on our Service and your options to enable and disable those cookies.

How We Use Information About You

We may use any of the information we collect about you for the following purposes. We may use and disclose aggregated or anonymous information about our Customers, Authorized Users, and Visitors, and information that does not identify any individual, without restriction (unless prohibited by applicable law).

  • Service functionality: To provide you with the Service. For more information about what the Service is and how it works, please visit Part of Service functionality is compiling data about Customer Learners’ scores on a leaderboard. Customers have full control over how to use and disclose leaderboard information, and Customer Learners may share leaderboard information with social media services as permitted by their Customer Administrators. Service functionality also includes taking steps to enter a contract for sale or for services, processing payments, fulfilling orders, sending service communications (including renewal reminders), and conducting general business operations, such as accounting, recordkeeping, and audits.
  • Service improvement: To improve and grow our Service, including to develop new products and services and understand how our Services are being used, our customer base and purchasing trends, and the effectiveness of our marketing.
  • Personalization: To offer you recommendations and tailor the Service to your preferences.
  • Advertising and marketing: To send you marketing communications, personalize the advertisements you see about our Service on third-party online properties, and measure the effectiveness of our advertising. We may share your information with business partners, online advertising partners, and social media platforms for this purpose.
  • Security: To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
  • Legal compliance: To comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal requirements.

How We Share Information About You

Customer, Authorized User, and Visitor Information. We may disclose information we collect from Customers, Authorized Users or Visitors:

  • To contractors and service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. For example, our service providers may use information about you to support the following:
  • Supporting Service functionality, such as vendors that support customer service and customer relationship management, application development, and communications (email, fax, chat-bot).
  • Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
  • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
  • Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential customers.
  • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
  • Information technology vendors, such as entities that assist with website design, hosting and maintenance, data and software storage, and network operation.
  • Marketing vendors, such as entities that support distribution of marketing emails.
  • To social network services, as described above, if you elect to connect our Service with your social network accounts. If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Service (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.
  • To our subsidiaries and affiliates in connection with providing the Service and subject to this Privacy Policy, including Plato eLearning, LLC dba ELB Learning, the parent entity that owns The Game Agency, LLC.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, other sale, or transfer of some or all of TGA’s assets, whether as a going concern, as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TGA about our Service users is among the assets transferred.
  • To fulfill any other legitimate purpose for which you provide it (or where we have obtained your consent if required by applicable law). For example, if you give us an email address to use the “email a colleague” feature of our Service, we will transmit the contents of that email and your email address to the recipients.
  • To enforce or apply our terms of use and other agreements, as permitted by law, including our agreement with a Customer.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TGA, our customers, or others, as permitted by law. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Customer Information (including Customer Administrators). In addition to the disclosures listed above, we may disclose Customer information:

  • To our payment services provider, Stripe, if a Customer purchases Services directly from us using our online shopping cart. You can review Stripe’s privacy policy at We share information with Stripe only to the extent necessary for the purposes of processing payments you make to us via our Service and dealing with queries relating to such payments and refunds. We do not store your credit card payment data on our servers. Your use of Stripe is subject to Stripe’s terms of service and privacy policy.
  • To our Resellers, if you are a Customer who purchased access to our Service from one of our Resellers. We share this information with your Reseller to the extent reasonably necessary for the purposes of processing payments you make for our Service and dealing with queries relating to such payments and refunds, administering or enforcing agreements relating to our Service, or providing Service maintenance and support. If you are a Customer, you should contact your Reseller for its privacy policy as we are not responsible for and do not control the Reseller’s privacy practices.

Customer Learner Information. In addition to the disclosures listed above, we may disclose Customer Learner information:

  • To the Customer who provided us with information about its Customer Learners to enable their use of the Service on behalf of the Customer and in compliance with our contractual obligations. For example, a Customer will have access to information regarding its Customer Learners’ engagement with our Service, including personal information, such as answer grading, gameplay frequency and duration, and leaderboard status in relation to other Customer Learners of the same Customer (which may be viewable to all Customer Learners of that Customer and/or the Customer Administrator(s) of that Customer) and activities within an Arcade (such as all the experiences points a Customer Learner garners when playing, watching videos, challenging other Customer Learners).
  • To other Customer Learners at the direction of the Customer Learner. For example, if the Customer has implemented the “challenge a colleague” feature, the challenge invitation from one Customer Learner will be received by the other Customer Learner through one or more of the following Customer approved methods: (i) web browser notification or (ii) email.  The Customer Learners will have their game scores shown on leaderboards in the Service.
  • To an LMS or SSO as authorized by a Customer, through which our Service is made available to their respective Customer Learners. We may make available to the Customer’s LMS and/or SSO information about Customer Learners in order to facilitate that integration, including all information originally passed to us from the Customer and/or its LMS or SSO as well as the Customer Learner engagement data.

What We Will Not Do With Customer Learner Personal Information

TGA does not sell, rent, copy, or allow third-party access to Customer Data that is personal information except as described in this Privacy Policy.

Your Options And Rights Regarding Your Information

Your Account: If you are a Customer Learner using Arcades™ or a Customer Administrator using the Service, please log in to update your information.

Email Unsubscribe: If you do not wish to receive marketing information from us or wish to opt out of future email promotions from us, please contact us. Please note that all promotional email messages you receive from us will include an option to opt out of future email communications.

Ad Choices: You have options to limit the information that we and our partners collect for online advertising purposes. Please see our Cookie Policy. If you exercise these options, please be aware that you may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to you. If you delete your cookies, you may also delete your opt-out preferences.

“Do Not Track” Signals: Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a Customer or Authorized User.  To find out more about “Do Not Track,” you may wish to visit

Jurisdiction-specific rights: You may have certain rights with respect to your information depending on your location or residency. Please see “privacy disclosures for specific jurisdictions” below. Please contact us to exercise your rights.

Making a request to exercise your rights

Submitting requests: You may request to exercise your rights by making a request using the contact information below.

If you are a California resident, you may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Verification: We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity.

We will not use information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

Data Security

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Service. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Data Retention

Following termination or deactivation of a Customer account, subject to our agreement with the applicable Customer: (a) we may retain personal information of Customers for a commercially reasonable time for backup, archival, contract performance and enforcement, compliance with law, fraud prevention, dispute resolution, troubleshooting problems, or audit purposes, and (b) we will promptly delete, return, or anonymize Customer Data, unless further storage of the information is required or authorized by applicable law and/or our agreement with the Customer. We retain Visitor information as long as it is necessary and relevant for our operations. The information we retain about you will be handled in accordance with this Privacy Policy.


TGA is based in the United States, and, regardless of where you use our Service or otherwise provide information to us, the information will be transferred to and maintained in servers located outside the EEA, including in the United States, which may not provide the same level of data protection as your country of residence. This is necessary in order to provide our Service. Regardless of where your personal information is located, we undertake measures to protect the security of your personal information as set out above.


Our Service is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Service. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Service or on or through any of its features/register on the Service, make any purchases through the Service, use any of the interactive or public comment features of this Service or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at


It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Service home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.


To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: or write to use at The Game Agency, LLC, Attention Privacy Policy, 470 West Avenue, Suite 2002, Stamford, CT 06902 USA.  If you are an EU resident, please email us at: If you are a UK resident, please email us at: In the header of the email, please include the words <The Training Arcade Marketing Opt Out>.


European Economic Area, United Kingdom, and Switzerland

We process “personal data,” as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”).

Your rights under the GDPR: Users who are located in the European Economic Area (“EEA”), U.K., or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here:

If you are located in the EEA, U.K., or Switzerland, you have the following rights.

  • Access and Portability: Request access to personal data we hold about you or request transmission of your data to a third party.
  • Correction: Request that we rectify inaccurate or incomplete personal data we store about you.
  • Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected, when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
  • Restriction of processing: Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise or defense of legal claims; or if your request to object to processing is pending evaluation.
  • Objection to processing: Object to processing of your personal data based on our legitimate interests or for direct marketing (including profiling). We will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.
  • Transfers: Obtain information about and a copy of the safeguards we use to transfer personal data across borders.

Please contact us to exercise these rights.


Your California Privacy Rights; “Shine the Light” Law

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year. We do not share your personal information with third parties for those third parties’ direct marketing purposes.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, delete, and limit disclosure of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of the categories of personal information we collect and the purposes for which we use personal information. The following table summarizes the categories of personal information we collect, the categories of sources of that information, and whether we disclose or sell that information to service providers or third parties, respectively. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described in “how we use information.”

CategoryInformation TypeSourceWe disclose to:We sell to:
  • Contact information or personal characteristics (name; email address; postal address; telephone number; signature)
  • Social media handles
You; our social media pagesService ProvidersNot sold
Financial Information (Customers only)
  • Payment card data
  • Bank account information
  • Credit information
YouService ProvidersNot sold
Commercial Information (Customers only)
  • Transaction information
  • Billing and payment records
  • Order history
YouService ProvidersNot sold
Geolocation Information
  • IP address
You; our analytics and advertising partnersService ProvidersParties listed in our Cookie Policy for advertising purposes
Internet or Electronic Network Activity Information
  • IP address
  • Device identifier (e.g., MAC)
  • Advertising identifier (e.g., IDFA, AAID)
  • Information provided in URL string (e.g., search keywords)
  • Cookie or tracking pixel information
  • Information about your interaction with our website, app, email correspondence, or products
  • Browsing history
  • Search history
  • Diagnostic information (e.g., crash logs, performance data)
You; our analytics and advertising partnersService ProvidersParties listed in our Cookie Policy for advertising purposes
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
  • Call recordings
  • Photographs
  • Video
YouService ProvidersNot sold
Professional or Employment-Related Information
  • Current employer
  • Job title
YouService ProvidersNot sold
Education Information
  • Education history
  • Level of education
YouService ProvidersNot sold
Inferences Drawn About You
  • User profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
You; our analytics and advertising partnersService ProvidersParties listed in our Cookie Policy for advertising purposes
Content of Communications
  • Contents of phone calls, emails, or text messages
YouService ProvidersNot sold
  • List of contacts that you supply to us
  • List of contacts we collect from your device with your permission
YouService ProvidersNot sold

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement. The types of service providers we use are listed in “How We Share Information About You.”

Entities to whom we “sell” information are third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us.

Your rights under the CCPA

  • Opt out of sale of personal information: You have the right to opt out of our sale of your personal information to third parties. The only circumstance in which we sell personal information is when we permit third party tracking technologies to collect data about your browser when you visit our website. To exercise this right, please visit our Cookie Policy and follow the instructions in “How to Control and Delete Cookies” or contact us. Please be aware that your right to opt out does not apply to our disclosure of personal information to service providers.
  • Know and request access to and deletion of personal information: You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with to whom we sell or disclose it. You also have the right to request in certain circumstances that we delete personal information that we have collected directly from you. Please contact us to exercise these rights.

Colorado, Connecticut, Utah, and Virginia

Residents of the States of Colorado, Connecticut, Utah, and Virginia have the following rights:

  • Opt out of “sales” of personal information and use of their personal information for “targeted advertising,” as those terms are defined under applicable law.
  • Opt out of “profiling” under certain circumstances, as defined under applicable law. (Residents of Colorado, Connecticut, and Virginia only.)
  • Confirm processing of and access to personal information under certain circumstances.
  • Correct personal information under certain circumstances. (Residents of Colorado, Connecticut, and Virginia only.)
  • Delete personal information under certain circumstances.

Residents of these states can exercise their rights by contacting us at using one of the methods listed above.


Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us.