CEB Inc. ("CEB", "we" or "us") is committed to protecting your personal information.
This Privacy Policy (the "Policy") explains how we collect and use personal information that you provide via the CEB Learning Portal ("the Portal") only. Information you provide via our public website www.cebglobal.com and our member-based websites (which are listed on our public website) (the "Sites"); through our CEB mobile application ("CEB App"); or offline when participating in any Member Program run by CEB, including the CEB International Executive Forums operated by the CEO Forum Group, is governed by the main CEB Privacy Policy. Personal information collected via our Talent Management assessment systems is also not covered by this Privacy Policy and will be governed by the terms of the specific Data Protection Notice ("DPN") shown at the beginning of each assessment.
Please read this Policy before you provide any personal information to us. By using the Portal, you consent to the collection and use of your personal information as outlined in this Policy. If you do not agree with the content of this Policy, you should not provide us with any personal information.
The Portal is owned and operated by CEB Inc, which has its principal place of business at 1919 North Lynn Street, Arlington, Virginia 22209, USA. More information about CEB, its subsidiaries and affiliates, and its network of Programs can be found at www.cebglobal.com. A full list of CEB offices, subsidiaries, and affiliates can be found here.
The Data Controller is CEB Inc of 1919 North Lynn Street, Arlington, Virginia 22209, USA.
Information We Collect From You or Your Employer. Information we collect from you or your employer may include your name, business or personal email address, job title, organization, organization's physical address, direct telephone number, photograph, and biographical details. You may need to provide certain types of information (e.g., email address) to register as a user. We may collect information about your access to and use of materials and other resources available via the Portal.
Information from other sources. We also may periodically obtain information about you from other sources. The collection of such information will be in accordance with applicable privacy laws. Examples of information we may receive include updated contact information and additional demographic information. Please note that we may have previously collected personal information relating to you at the time you or your organization enrolled in a Program or used another service run by CEB or any of its subsidiaries, as well as in the course of allocating and issuing to you a unique ID and password to access the Portal.
Information collected automatically. When you visit the Portal, we automatically collect and analyze certain information. This information includes your IP address, information about your browser type and language, the date and time you are accessing the Portal, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address.
Use of cookies and other technologies. We use various technologies to collect information about your activities on the Portal.
Information Collected by Third Parties. Third parties, such as vendors, advertising entities, and business partners, may use cookies and other technologies described above to collect information about your online activities. The purposes for collecting this information include measuring usage of the Portal and analyzing, modifying, and personalizing content on the Portal. We do not have access to or control over cookies or other features these third parties may use, and the information practices of these third parties are not covered by this Privacy Policy. Some of these third parties may be third-party network advertisers that offer you the option of not having this information collected. For more information about these practices and how to control how these companies use your information, please visit the following links: http://www.networkadvertising.org/managing or http://www.aboutads.info.
We use the information we collect about you for the following purposes, including:
User Profiles. On the Portal, you may be able to create an online profile, which may include information about your job title, employer, and your experience in different areas. This profile enables other users participating in the training to determine whether your background and expertise might make you a useful contact on a particular issue. By creating an online profile, you acknowledge and agree that you are making that information about you available to other users who might use that information to contact you via messages sent through the Portal.
Discussions. In the event that you post personal information in discussion forums or other areas of the Portal allowing users to upload or post content, please note that this information can be viewed by any user with access to those areas.
We believe that it is important to give you choices about the use of your information. We will use your information as described in this Policy. If we want to use your personal information for a purpose not described in this Policy, we will first obtain your consent to do so.
Marketing Communications: We will respect your wishes not to receive, or to stop receiving, marketing communications. You can change your marketing preferences by contacting us as described below. Please note that we will continue to send you service-related communications regardless of any such request. We will not share or sell your information and personal details with third parties for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.
California Online Privacy Protection Act Notice Concerning Do Not Track Signals: Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
Utilization information. We may share information with your employer about how you use the Portal.
We may share your information with third-party companies or individuals in the following instances:
We also may share aggregate or anonymous information with third parties, including advertisers, investors, and partners. Aggregate or anonymous information does not contain any personal information and its use and disclosure is not subject to the terms of this Policy.
We operate the Portal in the United States and, depending on your country of residence, the submission of personal information to the Portal may involve the transfer of personal information to the United States.
In addition, we may transfer personal information to our subsidiaries or affiliated companies and service providers and/or third party agents in various countries, including the United Kingdom, India, Australia, Canada, Germany (and other EU Member States), Singapore, or South Africa for certain processing operations. You should be aware that privacy laws in these countries may not provide protections equivalent to those of your country of residence.
All CEB entities have signed an Intragroup Agreement containing the European Union ("EU") Commission Approved Standard Contractual Clauses for the transfer of data outside the European Economic Area. All CEB entities have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, and the terms of our client and member contracts governing the collection and use of personal information.
CEB Inc. and its wholly-owned subsidiary SHL US, LLC comply with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, and are subject to the investigatory and enforcement powers of the United States Federal Trade Commission. CEB Inc and its wholly-owned subsidiary SHL US, LLC adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
CEB's accountability for personal information that we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process the personal information on our behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
More information about the Privacy Shield program can be found at https://www.privacyshield.gov/.
In some cases, you may directly access your online profiles and other personal details, and amend, update or add information yourself at any time by logging into your account.
You may request access to any personal information that we hold about you, ask us to correct any personal information which may be inaccurate, and/or ask us to block or delete such information and object to the processing of personal data except where the law requires otherwise. Please note that in cases where your employer is the Data Controller of such information, we will need to obtain their permission before making such changes. To access, correct or raise inquiries concerning your personal information in our possession, please email us at privacy@cebglobal.com or contact:
Global Data Protection Officer
CEB
1919 North Lynn Street
Arlington, Virginia 22209, USA
We may require you to prove your identity with approved identification.
We will retain your personal information for as long as needed to provide you with any services which you request. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
California Residents
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@cebglobal.com
We have implemented reasonable technical and organizational security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of information. Unfortunately, no data transmission over the Internet can be guaranteed to be entirely secure, and we cannot and do not guarantee or warrant the security of any information that you transmit on or through the Portal or the CEB App or that we otherwise maintain.
We make reasonable efforts to restrict access to personal information to only those employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Programs, products, and services. We subject our third-party agents to contractual controls to ensure that they appropriately protect and use any personal information they access or receive from us.
Please note that the effective security with respect to the Portal depends, in part, on you ensuring that any IDs and passwords that you have been issued by us are kept confidential and secure and that you adhere to the restrictions on password and ID-sharing set forth in our CEB Learning Portal Terms of Service.
To provide increased value to you, we may provide links to other websites or resources that are not part of the Portal or related to our network of Programs, products, or services run by CEB or its subsidiaries. We do not exercise control over these websites or their privacy practices, and any information you provide to those sites is subject to the Privacy Policies of those sites and not this Policy.
If you have any questions about this Policy or how CEB processes your personal information, please email us at privacy@cebglobal.com or contact us at:
CEB
Attn: Global Data Protection Officer
1919 N. Lynn St.
Arlington, VA 22209
Any complaints about our adherence to the practices described in this Policy should first be addressed to CEB's Global Data Protection Officer at privacy@cebglobal.com.
We agree that any disputes regarding our privacy policies and related actions regarding personal information from data subjects in the EU can be heard by the European Data Protection Authorities ("DPAs") or the Swiss Federal Data Protection and Information Commissioner, and we will be subject to the determinations of those bodies (as further explained in the Privacy Shield Principles). Please contact us to be directed to the relevant DPA. In certain circumstances after they have first tried to resolve the dispute directly with us and with the European Data Protection Authorities, data subjects in the EU may be able to invoke binding arbitration of disputes by the Privacy Shield arbitration panel.
Formal complaints regarding our data protection practices and related actions regarding personal information from countries outside the EU may be addressed directly to the data protection authority in your country.
The Portal contain business-related content and are specifically aimed at and designed for use by adults. We do not knowingly solicit or collect personal information from or about individuals under the age of 18 years.
This Policy may change from time to time. If we make any changes to this Policy, we will post any Policy changes on this page. Where we make any material changes to this Policy, we will provide a more prominent notice. Your continued use of the Portal following such posts or notices will signal your acceptance of such changes.
Last Updated: January 2017
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