Privacy Policy

This Privacy Policy (“Policy”) describes the practices Pragmatic Marketing, L.L.C. (the “Company,” “we,” or “us”) observes when collecting, using, and sharing data and other information (“Information”) from individuals who:

  • Visit the websites operated by the Company, including our primary website located at http://www.pragmaticmarketing.com (our “Sites”); and
  • Apply for or participate in our training courses (“Courses”) or certification programs (“Certifications”), whether offered publicly, onsite at your place of employment, online, or in any other format or venue.

This Policy will also apply to other Information we may collect from individuals if we clearly indicate at the time of collection that this Policy is applicable to that Information.

By using our Site or by registering for or participating in any Course or Certification, you consent to the collection and use of your Information by the Company as described in this Policy.

If you have any questions or concerns regarding this Policy or our Information collection or usage practices, please email privacy@pragmaticmarketing.com.

If we need, or are required, to contact you concerning any event that involves this Policy or your Information we may do so using the email address, telephone number, or physical mail address we have on file for you.

Summary

Although we encourage you to read the entire Policy, the following provides a summary of some of the important aspects of this Policy:

  • This Policy is applicable to Information we collect from you through our Site or our Courses or Certifications.
  • We may collect both Non-Personal Information and Personal Information from you.
  • We may also collect Sensitive Personal Information from you.
  • Your Personal Information (including Sensitive Information) will not be used or shared with third parties except as permitted by this Policy.
  • You are permitted to “opt out” of certain uses of your Personal Information.
  • We will take reasonable and appropriate measures to secure your Personal Information, but we make no promise that your Personal Information will remain secure in all circumstances.

Scope of this Policy

This Policy covers Information we collect through our Site, Courses, and Certifications. EXCEPT AS SPECIFIED IN THIS POLICY, THE POLICY DOES NOT COVER THE COLLECTION OR USE OF ANY INFORMATION BY THIRD PARTIES WITH WHICH YOU MAY INTERACT IN CONNECTION WITH YOUR USE OF THE SITE OR ANY COURSES OR CERTIFICATIONS. For information about what policies may apply to the Information you may share with any third party not specified in this Policy, please contact the third party before sharing Your Information.

Information We Collect

The Information we collect about you through the Site and our Courses and Certifications may include both “non-personal” and “personal” Information. We may also obtain “sensitive” personal information about you through the Site, Courses, and Certifications. For purposes of this Policy:

Non-Personal Information” refers to information that may not by itself be reasonably associated with, linked to, or used to identify you. For example, general, non user-specific Information regarding your use of the Site or participation in the Courses or Certifications.

Personal Information” refers to information that may be reasonably associated with, linked to, or used to identify you or allow you to be personally identified or contacted. For example, Personal Information may include information such as your name, email address, telephone number, address, or credit card number either alone or in combination with other information.

Sensitive Personal Information” refers to Personal Information regarding more sensitive areas such as financial information, such as bank account, medical or health conditions, or other sensitive topics.

Sources of Information

We may collect Information about you through the Site, Courses, and Certifications from a variety of sources, for example:

Directly from You. We may collect Information directly from you when you provide Information to us. For example, by registering for any Courses or Certifications, visiting and using the Site, responding to the Company’s annual survey, subscribing to a Company magazine or newsletter, or otherwise communicating with the Company. We may use any Information you provide to us through the Site, Courses, or Certifications in accordance with this Policy.

From Your Employer. We may obtain Information about you from Your employer. For example, when your employer registers You for a Course or Certification or responds to a survey. We may use any Information your Employer provides to us in accordance with this Policy.

From Third Party Service Providers. We may obtain Information about you from third parties who provide services to us in connection with our Sites or Courses and Certifications. We may use third parties to: (a) host, maintain, or manage the Site; (b) host or provide Courses or Certifications; (c) collect or analyze Information we collect from you through the Site, Courses or Certifications; (d) manage or assist us in managing our databases; or (e) provide other services relating to the Site, Courses, and Certifications. For example, if you register for the Site or for any Course or Certification through a third-party provider, we may receive Information about you from that third-party. Also, if you provide Information to one of our third party service providers in connection with taking a Course or testing for a Certification, we may receive that Information. We may use any Information obtained from our third party service providers in accordance with this Policy.

From Other Third Parties. We may also obtain Information about you from third parties who provide us with that Information. For example, we may contract to obtain Information about you from third parties that collect or obtain Information about you and have the right to provide that Information to businesses such as ours. We may use any Information about you we receive from a third party in accordance with the terms we establish with that third party. Only if we combine that Information with Information we collect under this Policy will we be required to use that Information in accordance with this Policy.

Through the Operation of the Site. We may collect Information about you automatically when you interact with the Site. For example, Company and our third party service providers may use “cookies” to monitor and collect Information regarding how you access, use, and interact with the Site. “Cookies” are commonly used small files that are stored on your computer or mobile device to help identify you as a unique user of the Site.

We may use cookies that expire once you close your browser or log out of the Site or that persist and stay on your computer until you delete them. Most browsers will allow you to erase cookies from your computer, block acceptance of cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more information.

The computers we use to provide the Site may also automatically record Information about you. For example, our web servers may record the Information you enter when using the Site (including registration information), the areas of the Site you visit, the services you use through the Site, your IP address, or cookies that are set on your browser. We may use any Information we collect from you automatically through the Site in accordance with this Policy.

Please note that our third party providers may also use cookies, web beacons, or other online tracking technologies in messages displayed on or communicated through the Site (“web beacons” (also known as “single–pixel” or “clear” GIFs) include electronic images imbedded in the Site that allow you to be recognized when you visit that area of the Site). We do not have access to information that would confirm all uses of cookies, web beacons, or other online tracking technology by our third party providers.

 

How We Use Information.

Non-Personal Information. We may use and share the Non-Personal Information we collect and obtain for any lawful business purpose without any duty or obligation of accounting or otherwise to you, provided that the Information remains Non-Personal Information. This will include, by way of example, developing products, services, and other offerings based on the Non-Personal Information and providing those offerings to other users and third parties.

Personal Information. We may use the Personal Information we collect about you for a variety of purposes, for example:

  • Providing our Courses and Certifications to you
  • Operating the Site and providing services to you through the Site;
  • Customizing and improving the Site, Courses and Certifications for you;
  • Providing maintenance, support, and customer service for the Site, Courses and Certifications;
  • Providing notices and announcements to you relating to the Company, our Course and Certification offerings, the Site, or your Information;
  • Providing offers for products, services, or other offerings that we feel may be of interest to you;
  • Contacting you for direct marketing purposes;
  • Processing payments made through the Site or for a Course or Certification;
  • Developing additional products, services and offerings; and
  • Research and analysis.

We may combine and enhance the Personal Information we collect and obtain about you with Information we receive from third parties, provided that we use the combined Information in accordance with this Policy.

You should not provide any personal information TO US, WHETHER IN CONNECTION WITH ANY COURSES OR CERTIFICATIONS OR through the SITE, unless you agree to the use of that information in accordance with this Policy.

Sensitive Personal Information. The Information we collect and obtain regarding you may include Sensitive Personal Information. For example, when you share Sensitive Personal Information in communications with us through the Site or when registering for or participating in a Course or Certification. Company will use any Sensitive Personal Information about you that we receive solely in accordance with this Policy to enable the operation of the Site and our Courses and Certifications. Note though that Company is not responsible for monitoring the Sensitive Personal Information you exchange through the Site or with any other participants in our Courses or Certifications, or for the use of that Information by other third party with whom you share that Information.

How We Share Information

We may share Information about you in a variety of ways, for example:

Affiliates and Subsidiaries. We may share Information with our affiliates and subsidiaries, including companies that we own or control, that own or control us, or that are under common ownership or control with us. We will require that our affiliates and subsidiaries agree to use the Information we share with them in compliance with this Policy.

Service Providers. We may share Information we collect about you with our third party service providers that help us provide the Site and our Courses and Certifications. We require that our third party service providers agree to use the Information we share with them only to perform their obligations to us and to treat all Personal Information they receive from us in compliance with this Policy.

Law Enforcement. We may share Information with law enforcement agencies if we reasonably believe unlawful activities have occurred or the Information may aid in an investigation into unlawful activity. We may also share Information with law enforcement if we determine, in our sole judgment, that you have violated our agreements or policies or that the release of your Information may protect the rights, property, interests, or safety of Company or any third party.

Legal Processes. We may share Information as required by, or permitted by, law, whether in response to subpoenas, court orders, other legal processes, or as we believe is necessary to exercise our legal rights, including to defend against legal claims that have been or might be brought against us.

Business Transactions. If we transfer ownership or control of any portion of Company or the Site, Courses or Certifications to a third party, whether or not in the context of an acquisition, merger, or reorganization, we may transfer Information to that third party, provided that the use of any of your Personal Information by that third party remains subject to the terms of this Policy.

Choice and Opt-out

We provide you with a choice whether to receive certain messages from us, whether through the Site or through other means. We also may give you the opportunity to “opt-out” of having your Personal Information shared for certain purposes permitted by this Policy.

If you no longer wish to receive certain messages from us or to have your Personal Information shared in the manner permitted by this Policy, you may seek to opt-out of receiving those messages or having your Personal Information shared in that manner. In some cases, opting out of receiving messages or having your Personal Information shared will not affect your ability to use the Site or to participate in our Courses and Certifications. However, some messages are necessary to the operation of the Site. Likewise, some sharing of Personal Information is necessary to provide you our Courses and Certifications. If you wish to opt-out of receiving these messages or of sharing your Personal Information in this manner, we may be required to limit or cancel your access to the Site or to our Courses and Certifications.

All opt-out requests can be made as indicated through the Site or contacting the Company as described above. Note that it may take up to [10] business days to remove contact information from our lists, so messages from us may continue for a time after a removal request is made.

Security

We are committed to protecting and securing your Personal Information. Despite our commitment, no security system can be 100% effective and we cannot guarantee that your Information will be secure in all situations. We will nonetheless take all reasonable and appropriate steps to ensure the safety and security of your Personal Information. This includes using industry standard security measures to protect the loss, misuse, and unintended alteration of the Personal Information under our control. For example, our policy is that only those individuals who need your Personal Information to perform a specific job for us are granted access to that Personal Information. Likewise, all employees and contractors are kept up-to-date on our security and privacy practices. Finally, the servers that we store personally identifiable information on are kept in a secure environment.

Additional Terms

Children. The Site and our Courses and Certifications are not directed to children under 13 years of age. The Company does not knowingly solicit or collect personal information from children under 13 years of age.

Do Not Track. Certain web browsers and other devices you may use to access the Site may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, we do not modify your experience on the Site or the Information we collect from you through the Site based on whether such a preference is indicated.

Review and Update of Information. While the Company takes reasonable steps to ensure that the Personal Information we collect from you is reliable for its intended use, accurate, complete, and current, we rely on you to update and correct your Personal information. Please contact us as described above to review, update, or change any of the Personal information we have on file for you.

Your California Privacy Rights. California law provides that California residents have a right to request that businesses tell them how their personal Information has been shared with third parties for use in direct marketing purposes. There is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s Personal Information to third parties for use in direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their Personal Information to third parties for such purposes. We have adopted a policy of allowing you to opt-out of the disclosure of your Personal Information to third parties for direct marketing purposes and thus fall within this exception. Instructions for opting out can be found in the section of this Policy entitled “Choice and Opt-Out”

Notification of Changes. We may notify you of any changes to this Policy by way of an email, by posting on the Site, or when you register for a Course or Certification. Changes to this Policy will be effective [30] days following such notice. Your continued use of the Site or continued participation in our Courses or Certifications after any change has become effective will constitute your acceptance of that change. Unless we seek and receive consent from you, we will use the Personal Information we collect and obtain about you in accordance with the version of this Policy effective when the Personal Information was last collected.

Revision Date: March 6, 2014