Last Updated: May 25, 2018
The Online Channels may provide links to other third-party websites and features. Some of these third-party websites may be co-branded with a Braillo logo even though they are not owned, controlled, operated or maintained by Braillo. Braillo does not share your personal information with those websites and is not responsible for their privacy practices. These websites are subject to their respective privacy policies. In some cases, we may provide the Offerings jointly with other businesses. For these co-branded offerings in which a third party is involved in your transactions, we will sometimes share or jointly collect customer data related to those transactions with that third party.
Click on one of the links below to jump to the listed section:
- Personal Information We Obtain
- How We Use Personal Information
- Cookies and Other Technologies
- Interest-Based Advertising
- How We Share Your Personal Information
- International Data Transfers
- Your Rights and Choices
- How We Protect Personal Information
- Retention of Personal Information
- Notice to California Residents
- Children’s Personal Information
- How to Contact Us
Personal Information We Obtain
The data we obtain varies based on the Offerings you use. We obtain personal information through your interaction with the Offerings, such as when you:
- Create an account in an Online Channel;
- Register or apply to a Braillo partner program;
- Sign up for an online program, event, seminar, promotion or sweepstakes;
- Request products (including product evaluations, trials, tech preview and beta downloads), services or information;
- participate in Braillo events, surveys, questionnaires, research or evaluations; or correspond with us or request information from us.
The types of personal information we obtain include:
- Contact information (such as name email address, telephone number, postal or other physical address) for you or for others (e.g., principals in your business or billing contacts);
- Information used to create your online account (such as username and password);
- Biographical and demographic information (such as gender, job title/position and occupation);
- Business profile and practices information used to evaluate you as a partner;
- Billing and financial information (such as name, billing address, payment card details and bank account information and purchase history);
- Information you submit in connection with a career opportunity at Braillo, such as contact details, information in your résumé (including work history, education and language skills) and details about your current employment;
- Location data (such as data derived from your IP address, country and zip code);
- The precise geolocation of your mobile device;
- Personal information contained in forums, blogs, and testimonials you provide or that we obtain from publicly available sources (such as social media channels);
- Information related to participation in classroom or online training, including programs completed and certifications achieved;
- Information necessary to provide support or other paid consulting services (such as contact details, chat services, support details, and event history);
- Personal information contained in content you submit to us (such as through our “Contact” feature or other in-product or in-service messaging); and
- Other personal information we obtain through our Offerings.
Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.
How We Use Personal Information
We use the information we obtain to:
- Provide and administer our products and services (including websites and apps for which you have registered);
- Process and fulfill orders in connection with our products and services and keep you informed about the status of your order;
- Help you complete a transaction or order and provide customer support;
- Bill you for products and services you purchased;
- Provide training, support and consulting services;
- Manage career opportunities, including for recruitment purposes, employee onboarding and other Human Resources purposes;
- Create and manage your account with Braillo;
- Operate, evaluate and improve our business (such as by administering, developing, enhancing and improving our products and services; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
- Perform data analytics (such as research, trend analysis, financial analysis and customer segmentation);
- Communicate with you about your account and orders (including sending emails relating to your registration, account status, order confirmations, renewal or expiration notices and other important information);
- Conduct marketing and sales activities (including sending you promotional materials, generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
- Communicate with you about, and administer your participation in, events, programs, promotions and surveys;
- Connect employees with their enterprise account administrator;
- Verify your identity and protect your account against unauthorized use or abuse of our services;
- Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
- Comply with and enforce relevant industry standards, contractual obligations and our policies;
- Maintain and enhance the security of our Online Channels, products, services, network services, information resources and employees; and
- Respond to your inquiries.
Depending on the purposes for which personal information is used, and the context in which the data is obtained, we may rely on one or more of the following legal bases:
- Performance of a contract with you or a relevant party;
- Our legitimate business interests;
- Compliance with a legal obligation, a court order, or to exercise or defend legal claims; or
- Your consent to the processing, which you can revoke at any time.
We may combine data collected from you with other sources to help us improve the accuracy of our marketing and communications as well as to help expand or tailor our interactions with you. This includes combining personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information (such as referral programs), for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.
Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.
Cookies and Other Technologies
We use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner includes IP address and other identifiers associated with your devices, types of devices connected to our Offerings, device characteristics (such as operating system), language preferences, referring/exit pages, navigation paths, access times, browser preferences and characteristics, installed plugins, local time zones, local storage preferences, clickstream data and other information about your online activities. We use on our Online Channels both first-party cookies (served directly by our website domain when you visit our Online Channels) and third-party cookies (served by a third-party website when you visit our Online Channels and certain third-party websites with whom we have partnered). Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).
The cookies we use on our Online Channels include
(1) essential and functional cookies
(2) analytics cookies; and
(3) targeting/advertising cookies
each as described below.
Essential and Functional Cookies
We use analytics cookies to collect information on how users navigate and use our Online Channels, such as how the users traverse our Online Channels, the pages they view, how long they stay on a page and whether the page is displayed correctly or whether errors occur. Such cookies help us to improve the performance of our Online Channels and make the Online Channels more user-friendly. These cookies are provided by third-party analytics providers, including Google Analytics and HotJar. To learn more about Google Analytics and how to opt out, please visit Google Analytics.
Advertising cookies are used to control and manage advertisements. These Cookies may collect information on whether a user has reacted to an advertisement and visited another website. Such cookies help us to offer you content and provide targeted information that is more relevant to your interests. They also help us to measure the effectiveness of our advertisements and communications. In the EU, we deploy analytics and advertising cookies on our websites only when users have opted-in as required by applicable law.
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Online Channels. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
Additional information about our cookie practices and how to manage your cookie preferences is available here. To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.
The providers of third-party apps, tools, widgets and plug-ins on our Online Channels (such as Twitter, LinkedIn and Facebook) also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, Braillo is not responsible for these providers’ information practices.
When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) collect information about your online activities, over time and across third-party websites (such as on websites that serve our ads). We may use such information to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. You may see certain ads on other websites because we engage third-party ad buying networks. Through such buying networks, we can target our messaging to users through demographic, interest-based and contextual means. The information our ad networks may collect on our behalf includes data about your visits to websites that serve Braillo advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in these ad networks. This process helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, click here. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
How We Share Your Personal Information
We do not sell or otherwise disclose personal information about you except as described here or at the time of collection. Braillo may share personal data in the following ways:
- If sharing your data is necessary to provide a product, service or information you have requested;
- As part of a joint sales promotion or to pass sales leads to our business partners;
- To keep you up to date on the latest product announcements, software updates, special offers or other information we think you would like to hear from our business partners;
- For the purposes of validating employment, training completed or product certifications achieved;
- To connect employees with their company administrator(s);
- With our customers to report and help manage issues requiring support or as part of consulting services;
- With our customers and partners to inform them about their users’ use of our services (such as when a user has obtained credentials or completed a course);
- With service providers we have engaged to perform services on our behalf (such as payment processing, order fulfillment, customer support, customer relations management and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements;
- With approved Braillo partners, to offer and provide our products and services to you; and
We also may disclose personal information about you (1) if we are required or permitted to do so by applicable law, regulation or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss to Braillo, its users or the public as required or permitted by law, (4) to establish, exercise or defend our legal rights, and (5) in connection with an investigation of suspected or actual fraud, illegal activity, security or technical issues.
In addition, we reserve the right to transfer to relevant third parties information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business transaction.
We also may share the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.
International Data Transfers
EU-U.S. and Swiss-U.S. Privacy Shield
Braillo is responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Braillo complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to a Privacy Shield Framework, Braillo is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Braillo may be required to disclose personal information in response to lawful requests by public authorities, including to satisfy national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Braillo here. If you have an unresolved compliant that has not been addressed to your satisfaction, please contact or visit https://feedback-form.truste.com/watchdog/request (a U.S.-based alternative dispute resolution provider) for more information or to file a complaint. The services are provided at no cost to you.
Braillo has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
Your Rights and Choices
To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, update, amend or delete your information, or that we restrict the processing of such information by contacting us as indicated below or by accessing MyAccount. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.
We support the Self-Regulatory Principles for Online Behavioral Advertising (“Principles”) of the Digital Advertising Alliance in the U.S., the Digital Advertising Alliance of Canada, and the European Digital Advertising Alliance in the EU. If you live in the United States, Canada, or the European Union, you can visit Ad Choices, Ad Choices Canada or Your Online Choices to find a convenient place to indicate your preferences, including the option to make one “universal” opt-out of interest-based advertising with participating entities. These websites also provide detailed information about interest-based advertising and tips for managing your privacy online and in applications. Opting out of interest-based advertising does not mean you will no longer see advertisements from us or on the Online Channels; rather, opting out means that the online ads that you do see will not be based on your interests. When you opt-out of receiving interest-based advertisements through the links above, cookies and other technologies on the Online Channels may still collect information about your use of the Online Channels, including for analytics, fraud prevention and any other purpose permitted under the Self- Regulatory Principles.
When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) may collect personal information about your online activities, over time and across third-party websites. Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. While our Online Channels are not designed to respond to “do not track” signals received from web browsers, you can manage your cookie preferences and the choices you can make in connection with the personal information we collect about you through automated means by visiting our Cookie Consent Tool.
Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.
Retention of Personal Information
Notice to California Residents
Subject to certain limits under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To obtain this information, please send an email to firstname.lastname@example.org with “California Shine the Light Privacy Request” in the subject line and in the body of your message.
Children’s Personal Information
How to Contact Us
Attn: Data Protection Officer