Training

Privacy Policy

Effective as of May 28th, 2016.

Purpose

The purpose of this Privacy Policy is to describe how PVR Technology Inc (“PVR,” “us,” “we,” or “our”) collects, uses and shares information about you through our U.S. online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.training.pvrtech.com (collectively referred to herein as the “Site”). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at training@pvrtech.com. Your use of our Site is also governed by our Terms of Use.

What Information this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any personal information, though for features or services related to the Online Courses, personal information is required. If you do not use these specific features or services on the Site, then the only information we collect will be “Non-Personal Information” (i.e., information that cannot be used to identify you). Non-Personal Information includes information such as the web pages that you have viewed. In order to access certain features and benefits on our Site, you may need to submit “Personally Identifiable Information” (i.e., information that can be used to identify you). Personally Identifiable Information can include information such as your name and email address, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to PVR. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

What You Consent to by Using Our Site

Please understand that by submitting any Personally Identifiable Information to us, you consent and agree that we may collect, use and disclose such Personally Identifiable Information in accordance with this Privacy Policy and our Terms of Use, and as permitted or required by law. If you do not agree with these terms, then please do not provide any Personally Identifiable Information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personally Identifiable Information, we may not be able to provide you with the services that can be offered on our Site.

What Information We Collect

We gather two types of information about users through the Site:

Non-Personal Information. When users come to our Site, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. Although such information is not Personally Identifiable Information, we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.

We also use or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Site links, the length of time each user spends at any particular area of our Site, and the specific functionalities that users choose to use. Essentially, cookies are a user’s identification card for the PVR servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Site and related functionalities. Cookies and web beacons allow PVR to serve you better and more efficiently, and to personalize your experience at our Site. Cookies and web beacons are not used to retain Personally Identifiable Information. From time to time we may also use additional typical methods of collecting data.

You should be able to control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar. If you reject our cookies, many functions and conveniences of this Site may not work properly.

Personally Identifiable Information – We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates or Online Courses, participate in our public forums, send us email messages, and/or participate in Online Courses or other services on our Site. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific course and/or services you select, send you updates about Online Courses offered by PVR or other PVR events, and send you email messages about Site maintenance or updates.

Account Registration – If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name and email address.

Updates – PVR may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name and email address.

Forums – PVR may offer public forums from time to time (the “Forums”) where you can share comments and thoughts. In order to participate in the Forums, you may be required to register with us and/or provide us with Personally Identifiable Information such as your name and email address. Personally Identifiable Information shall not include any information posted or sent by or to you via any public Forum. Please keep in mind that information you post or make available in Forums will be publicly available. Accordingly, you should be careful when posting any personal or sensitive information. Please also reference our Terms of Use for our Rules for Online Conduct and additional information about proper use of our Forums.

Participation in Online Courses – PVR offers users the opportunity to participate in an Online Course on or through the Site. If you desire to participate in a course, you will be asked to provide us with certain information necessary to conduct such a course. This information may include, among other things, your name and email address.

If you participate in an online course, we may collect from you certain student-generated content, such as assignments you submit to instructors, peer-graded assignments and peer grading student feedback. We also collect course data, such as student responses to in-video quizzes, standalone quizzes, exams and surveys.

Identity Verification. PVR may offer you the ability to verify your identity (e.g., through the Signature Track or ACE-CREDIT courses) for selected classes. In order to enroll for these services, you are required to provide us with Personally Identifiable Information such as your name, address, date of birth, a headshot taken using a webcam, a photo identification document, and a sample of your typing patterns. Additionally, if you apply for financial aid in connection with these services, you are required to provide information regarding your income.

Communications with PVR – We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.

Third Party Sites – We may receive Personally Identifiable Information when you access or log-in to a third party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.

Surveys – We may receive Personally Identifiable Information when you provide information in response to a survey operated by us.

Partner sites providing Online Course related tools and services to PVR users may collect nonfinancial individual level user data regarding the individual’s use of that partner site while engaged with such Online Course related activities, and the partner sites may share that data with PVR for the purpose of improving PVR’s services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.

Third Party Credit Card Processing. PVR provides you with the ability to pay for Online Courses and other services using a credit card through a third party payment processing service provider. Please note that our service provider – not PVR – collects and processes your credit card information.

How We Use the Information

Non-Personal Information – We use Non-Personal Information to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use it for other business purposes.

Personally Identifiable Information – Except as set forth in this Privacy Policy or as specifically agreed to by you, PVR will not disclose any Personally Identifiable Information we gather from you on the Site. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personally Identifiable Information as described below. We may also use it for research and business purposes, including improving and customizing the Site and the products and services we offer.

Updates – We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Site or an Online Course. We may also archive this information and/or use it for future communications with you.

Forums – To facilitate your use of the Forums, we use Personally Identifiable Information collected during your use of the Forums. In addition, we may publish this information via extensions of our Platform that use third-party services, like mobile applications. We also reserve the right to reuse Forum posts containing Personally Identifiable Information in future versions of the courses we offer, and to enhance future course offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the University or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using Personally Identification Information.

Participation in Online Courses – We use the Personally Identifiable Information that we collect from you when you participate in an Online Course through the Site for processing purposes, including but not limited to tracking attendance, progress and completion of an Online Course. We may also share your Personally Identifiable Information and your performance in a given Online Course with the instructor or instructors who taught the course, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification or operation of the course, and with the institution or institutions with which they are affiliated. Also, we may archive this information and/or use it for future communications with you.

Identity Verification – For services that require identity verification (e.g., the Signature Track or ACE-CREDIT courses), we use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. Your photo identification document will be deleted after successful verification of your profile information.

Communications with PVR – When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you.

Communications with PVR Business Partners – We may share your Personally Identifiable Information with University partners and other business partners of PVR so that PVR business partners may share information about their products and services that may be of interest to you.

Research – We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our University partners and other business partners so that our University partners and other business partners may use the data for research related to online education.

Disclosure to PVR Operations and Maintenance Contractors – We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Online Course. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.

Government Authorities, Legal Rights and Actions – PVR may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of PVR, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.

Disclosure to Acquirers – PVR may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of PVR to which your Personally Identifiable Information relates.

e-Readers – If we receive any Personally Identifiable Information related to the extent to which you use designated e-Readers to access PVR materials, we may archive it, and use it for research, business, or other purposes.

External Links

For your convenience we may provide links to sites operated by organizations other than PVR (“Third Party Sites”) that we believe may be of interest to you. We do not disclose your Personally Identifiable Information to these Third Party Sites without obtaining your consent. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personally Identifiable Information.

Confidentiality & Security of Personally Identifiable Information

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical and administrative security measures to keep your Personally Identifiable Information confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless we have good faith belief that such disclosure is necessary in special cases, such as a physical threat to you or others. Because the Internet is not a 100% secure environment we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Site are not encrypted.

Updating or Deleting Your Personally Identifiable Information

You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site and visiting your user account page. You may also contact us via training@pvrtech.com. We try to answer every email promptly, but may not always be able to do so. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personally Identifiable Information.

If you have any privacy-related questions, unresolved problems, or complaints you may contact us via training@pvrtech.com.

California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2012 will receive information regarding 2011 sharing activities).

To obtain this information, please send an email message to training@pvrtech.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

International Privacy Practices

PVR’s Sites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our products and services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Changing Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Policy by posting a notice on our Site’s homepage for a reasonable period of time following such update, and by changing the effective date (located at the bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

No Information from Children Under 13

PVR strongly believes in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personally Identifiable Information.


Safe Harbor Policy

Introduction:

PVR Technology Inc. (referred to as “we,” “us,” or “our”), believes in protecting your privacy.

When we collect Personal Information (as defined below) from you, we adhere to the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information from European Union member countries and Switzerland. Accordingly, we follow the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement (collectively, the “Principles”). To learn more about the Safe Harbor program, please visit www.export.gov/safeharbor/. We are currently in the process of obtaining formal self-certification of our adherence to both the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework.

When we use the term “Personal Information” in this Safe Harbor Policy (the “Policy”), we are referring to any information that (i) is recorded in any form; (ii) is about or is related to a specific individual; (iii) can be linked to that individual; and (iv) is transferred by us from the EU and Switzerland to the U.S.

When we use the term “Sensitive Personal Information” in this Policy, we are referring to a particular subset of an individual’s Personal Information that provides details of his or her race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns his or her health.

The purpose of this Policy is to outline our general practices for implementing the Principles with respect to the Personal Information we collect. If you would like to obtain additional information regarding our privacy practices in connection with information collected on this website in general, please refer to our online Privacy Policy.

Principles
Notice – We will provide you with timely and appropriate notice in our Terms of Use, describing what Personal Information we are collecting, how we will use that information, and the types of third parties with whom we may share such information.

Choice – We will offer you the opportunity to opt-out of your Personal Information (or explicitly consent for Sensitive Personal Information) being: (i) disclosed to a third party (other than a service provider as set forth below); or (ii) used for a purpose other than the purpose for which it was originally collected (or subsequently authorized by you) when the circumstances arise.

Notwithstanding the foregoing, we may disclose Personal Information under the following circumstances without offering you an opportunity to opt out of such disclosure: (i) to our service providers that we have retained to perform requested services on our behalf; (ii) if we are required to do so by law or legal process; (iii) pursuant to valid requests by law enforcement or other government authorities; and (iv) when we believe disclosure is necessary to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. In addition, we reserve the right to transfer Personal Information in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the Personal Information in a manner consistent with this Policy.

Onward Transfers – (Transfer to Third Parties). We will only transfer Personal Information to third parties where the third party: (i) has provided satisfactory assurances to us that it will protect the Personal Information in accordance with this Policy and the substance of the Principles; (ii) is located in the EU, Switzerland or a country considered “adequate” for privacy by the EU Commission and/or the Federal Data Protection and Information Commissioner of Switzerland, and therefore is required to comply with the EU or Swiss data protection laws or substantially equivalent privacy laws; or (iii) has certified to the Safe Harbor, and is accordingly independently responsible for complying with the Safe Harbor requirements.

Where we have knowledge that a third party to whom we have provided Personal Information is processing that Personal Information in a manner contrary to this Policy or the Principles, we will take reasonable steps to prevent or terminate processing by the third party until such time the third party can process Personal Information in compliance with this Policy and the Principles.

Where we have knowledge that a third party to whom we have provided Personal Information is processing that Personal Information in a manner contrary to this Policy or the Principles, we will take reasonable steps to prevent or terminate processing by the third party until such time the third party can process Personal Information in compliance with this Policy and the Principles.

Data Security – We will take reasonable steps to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction.

Data Integrity – We will process Personal Information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by you. To the extent necessary for those purposes, we will take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access – Upon request, we will provide you with reasonable access to the Personal Information about you that we hold. We will also take reasonable steps to correct, update, amend or delete any information that is demonstrated to be inaccurate, except where the burden or expense of doing so would be disproportionate to the risks to your privacy in the case in question or where the rights of third parties would be violated.

Enforcement – We will regularly review our compliance with the statements set forth in this Policy, and we will provide an independent way to resolve complaints about our privacy practices. We encourage interested persons to Contact Us (contact information provided below) and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

We also participate in the International Centre for Dispute Resolution (“ICDR”), a division of the American Arbitration Association’s, Dispute Resolution Process. If your inquiry is not satisfactorily addressed by us, you may contact the ICDR.

Modifications

We may amend this Policy from time-to-time in accordance with the requirements of the U.S.–EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework. The most recent version of the Policy will always be posted to this website. Anytime that we do make such changes, we will also update the Effective Date listed at the beginning of the Policy. Please be sure to review the most recent version of the Policy each time that you visit this website so that you are aware of how we collect, use and retain personal information.

Contact Us

To understand more about the transfer of your Personal Information from the EU or Switzerland to the US, access your information, ask questions about our privacy practices or issue a complaint, please contact us at: training@pvrtech.com.

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