PRIVACY POLICY

Effective April 18, 2018.

We are IT Nuggets (CBT), LLC, a leading provider of IT training solutions. We are committed to protecting and respecting your privacy. By accessing or using the Services, you expressly agree to this Privacy Policy. Please read the information below:

This Privacy Policy describes the types of information that we may collect from you or that you may provide to us when you visit the IT Nuggets (CBT)’ website located at https://www.cbtnuggets.com (the “Website”) or the IT Nuggets (CBT) mobile applications (“Apps”) (collectively the “Services”), and our practices for collecting, processing, protecting and disclosing such information.

This Privacy Policy applies to information we collect: (i) through the Services, and (ii) in communications between you and IT Nuggets (CBT). This Privacy Policy does not apply to any information collected by us offline or via third-party sites that may be accessed through hyperlinks on the Services.

IT Nuggets (CBT) complies with the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. IT Nuggets (CBT) has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. IT Nuggets (CBT) shall subject to the Privacy Shield Principles all personal data received from the EU in reliance on the Privacy Shield. IT Nuggets (CBT) remains responsible for any of your personal information that is shared under the Onward Transfer Principle with third parties for external processing on our behalf, as described in the “Information We Share” section.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Except as otherwise expressly provided, this Privacy Policy only addresses the use and disclosure of information IT Nuggets (CBT) collects from you. The Website may contain hyperlinks to other third-party web sites, which may collect and disclose information in a manner not consistent with this Privacy Policy, and such collection and disclosure would be governed by that website’s privacy policy, and any questions or concerns should be directed to that company’s site administrator or provided contact information. We are not responsible for the collection, use, or disclosure of information collected through any third-party web sites, and we expressly disclaim any and all liability related to such collection, use, or disclosure.

By using or interacting with our Services, you are agreeing to:

  • The use of cookies, tracking pixels, and similar technologies;
  • The transfer of your data to the EEA, United States, Mexico, Australia, and countries that have received an adequacy determination by the European Commission under Article 45 of Regulation (EU) 2016/679;
  • The processing of your data as described in this Privacy Policy; and
  • The use of e-mail notifications as a primary source of communication between you and IT Nuggets (CBT).

INFORMATION WE COLLECT:

We will NEVER share your personal data with third party partners for their direct marketing purposes.

IT Nuggets (CBT) and our partners collect data from Learners in the following circumstances:

WEBSITE VISITORS:

When you use or interact with the Services, we and our partners may use a variety of technologies that collect information about those interactions. These technologies include cookies, web beacons, tracking pixels, and similar technologies. We use these technologies internally to customize your learning experience, such as keeping you in a logged-in state or providing you with the most relevant Content. Disabling these technologies on your web browser may negatively impact your user experience. We have partners that use these technologies to provide us with measurement services of our website and deliver advertisements to you as well as optimize your experience. These third party partners may collect your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular advertisement. These technologies attempt to aggregate data to deliver content based on the web browsing activity, social network profile information, including the URLs of the company’s web pages that were visited, where you go and what you do on that company’s websites, apps, or social media pages, the URL of the page that displayed the link that you clicked on, which brought you to that company’s website, the web search you performed that led you to that company’s website, Information you may provide on that company’s website, app, or when interacting with that company’s social media pages, such as information you provide on registration forms, Ad campaign success rates, such as whether you clicked on a company’s ad and whether viewing or clicking on the ad led to your purchase of that company’s product, Items you’ve purchased or placed in your shopping cart on that company’s website or app.

We may use vendors, who use first-party cookies and third-party cookies together to inform, optimise, and serve ads based on your past visits to our websites. There are tools to manage the collection and use of certain information by Google Analytics at tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings, instructions can be found at google.com/settings/ads. Another available tool is the Network Advertising Initiative’s (NAI) Opt-Out Tool at networkadvertising.org/choices. This allows you to opt out from the use of information about your online activities for online behavioral advertising by NAI member companies. On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests. Additional information for mobile users can be found at: http://youradchoices.com/appchoices.

Our website does not respond to Do Not Track signals. You may visit aboutads.info to receive more information about the collection and use of information about your online activities for online behavioral advertising or to learn how to opt out of having your data used for online behavioral advertising by Digital Advertising Alliance (DAA) participating companies. Canadian users can also visit youradchoices.ca. European users can also visit youronlinechoices.com to learn how to opt out of having their data used for online behavioral advertising by European Interactive Digital Advertising Alliance (EDAA) member companies.

By interacting with our site, without disabling cookie functionality and other similar technologies, you hereby consent to the use of cookies and similar technologies as described above.

MAILING LIST:

When you sign up to receive Email Updates from IT Nuggets (CBT), the personal information you provide is collected in order to identify you. Email Updates are sent out no more than a few times per week, and contain information about IT Nuggets (CBT) which you otherwise have requested to receive. We may use Multipurpose Internet Mail Extensions in our marketing emails to help inform us on the effectiveness of our content as well as provide an indication as to your level of interest in continued marketing.

You may unsubscribe from the mailing list at any time by navigating to your Learner Account settings or by using the “Unsubscribe” link in the email. Please note that this does not cover System/Transaction Emails such as subscription notices, payment receipts, or other compulsory commercial or legal correspondence.

LEARNERS:

In order for you to access the CBT Nugget Content (training videos, quizzes, practice exams, virtual labs, and other tools), you must first register for a CBT Nugget Learner Account by providing personal data. We and our third party partners must process your personal data in order to make that Content available to you. The particular data that is processed, and by whom, is relative to the particular Content you access and the particular Service you interact with.

Account Registration:

When you register for a Learner, or administrator, account with IT Nuggets (CBT) we collect only that personal data which is necessary to provide you with Content across our Services. We collect your email to function as your username and provide a means of communication for important notices. We collect your first and last name in order to facilitate our licensing model of one license to one named individual. This allows us to provide a personalized Learning experience and comply with various reporting and recordkeeping obligations. We optionally collect your company/organization/school name in order to enhance your Learner experience.

When you enter your payment information on the registration site you will be asked to either link to your PayPal account or manually enter your personal information along with your payment information. We collect your payment card information, as well as your billing address and phone number for validation, compliance, and recordkeeping purposes. IT Nuggets (CBT) never stores the full credit card number and all payment processing is handled by third parties. All information entered into the secure webform is done so via an encrypted session.

Accessing Exams:

When you access the certification practice exams through the Services, you are accessing proprietary materials which have been provided to Learners through an agreement with Kaplan IT Training, formerly Transcender. Your internal member ID number, email, first name, and last name are stored by Kaplan IT Training and used to create an authentication token which provides you access to the practice exams. Your personal data is only transmitted to Kaplan IT Training when you access the practice exams.

Accessing Labs:

When you access the virtual labs through the Services, you are accessing our proprietary instances on a virtual computer hosted by Learn on Demand Systems. Your email, first name, and last name are used to create an authentication token which provides you access to the virtual labs. Your personal data is only transmitted to Learn on Demand Systems when you access the virtual labs.

Learner Contributions:

When you participate in the Learner Community on Slack, or the Validated Minutes Leaderboard, you are placing your personal data in a public forum. Once you publish in any of the above forums, it becomes publicly available and we are restricted in our ability to delete that data. Before posting in a public forum, you should carefully review the Privacy Policies of the relevant third party partners. Our Learner Community is hosted on Slack and includes your Learner email and/or any information you provide to Slack. The Validated Minutes Leaderboard is a semi-public forum hosted by IT Nuggets (CBT) and available to view by other CBT Learners. If you choose to edit your Leaderboard profile picture through Gravatar, you are creating an account with that separate entity. You can select whether or not you want your Validated Minutes displayed on the Public Leaderboard by indicating your selection in your Learner Account settings.

Promotional Offers:

Certain promotional offers may require the validation of certain personal information. IT Nuggets (CBT) relies on the verification services of third parties when administering promotional offers such as Outside the Wire, which offers free training to those leaving military service for civilian careers.

Surveys:

We may provide Learners or Website visitors with the opportunity to participate in surveys, and we may announce such surveys, beta testing, or similar opportunities, through our Email Updates. Additional details, as appropriate, of the data processing will accompany any survey, beta testing, or similar opportunity for feedback and engagement. Unless otherwise specified, the personal data collected during such surveys will be retained consistent with our data retention schedule. As with any consent, you may revoke this consent at any time.

Communicating With Us:

When you contact us for Learner Support, or otherwise communicate with us, we will attempt to connect that email, phone call, or chat with your Learner account. If we are able to connect the communication to the account, this means your method of communication and the substance of the communication will become associated with your personal data. When you contact an Accountability Coach, we connect those communications to your Learner account as well.

IT Nuggets (CBT) expressly discourages any customers from sending or transmitting any sensitive data via any unsecure networks or channels, including, but not limited to, any customer primary account number (“PAN”) or other cardholder data. You assume any and all risk associated with such transmissions.

Accessing Services Via Apps:

When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best application version to provide you with. During your use of the App, we and our partners may further collect data regarding your device, operating system, and location in order to optimize the services we provide to you. Our mobile Apps require Account Registration for functionality, and the data collected during registration is described in the previous sections. Please note that your subscription may be managed through a mobile application store such as iTunes or Google Play Store, etc.

INFORMATION WE SHARE:

We will NEVER rent, sell, share, or otherwise disclose your personal data with third party partners for their direct marketing purposes. Before sharing your data with third party controllers, we will provide you with notice and an opportunity to opt-out.

We may share your personal information with:

  • Our contractors, service providers and other third parties we use to support our business and to fulfill services requested by you, including, without limitation, content delivery, credit card processing companies, marketing services providers, as well as practice exam and virtual lab features.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by IT Nuggets (CBT) about its Learners and account holders is among the assets transferred. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot ensure that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.
  • To your Account Administrator, if any.
  • To other third parties with your express consent or that of your Account Administrator, if any.

We may also disclose your personal information:

  • To comply with any valid court order, law or legal process.
  • To respond to law enforcement authorities or other government officials.
  • IT Nuggets (CBT) reserves the right to use or disclose personal information provided to IT Nuggets (CBT) in response to a lawful request by public authorities, including to meet national security or law enforcement requirements,
  • To enforce our agreements with you, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

As a Privacy Shield organization, we accept full responsibility for any and all transfers of your personal data to third parties who are obliged to offer the same level of protection for your personal data as we do.

WHERE WE KEEP YOUR DATA:

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and/or the provision of support services. Your data is maintained in servers that are located in the United States, and your data is processed by our team members located in the EEA, United States, Mexico, and Australia. The United States, Mexico, and Australia are not considered by the European Commission to offer adequate protection of your personal data as compared with your country. For these cases, IT Nuggets (CBT) has put into place safeguards to ensure adequate protection of your data, such as Privacy Shield certification, your consent and other technical and organizational safeguards.

Data handled by our service providers is maintained in the United States. Our team members in Mexico and Australia may, on occasion, process personal data through a dedicated and encrypted connection to this data. There is no data at-rest, only occasional data in-use. By submitting your personal data, you agree to this transfer, storing or processing as described in this Privacy Policy. IT Nuggets (CBT) will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

We retain personal data for seven years from a Learner’s last System access or end of subscription period, whichever is later, unless such data must be retained for the establishment, exercise, or defense of legal claims.

YOUR RIGHTS:

Through the Website you can access information regarding your recent orders, your personal information, marketing preferences, and payment settings. With respect to your marketing preferences, you can unsubscribe from IT Nuggets (CBT) email updates by following the unsubscribe instructions included in the email you receive or you can navigate to your Learner account and update your preferences there. Only IT Nuggets (CBT) will send you these emails. You may ‘unsubscribe’ from these messages after which you will no longer receive them. We do not send unsolicited commercial emails or spam. We offer commercial email recipients the opportunity to unsubscribe from further communications in every email, with the exception of non-commercial Service emails regarding any Service order or Support issue you place.

If your password or username is compromised, please notify us as soon as possible by email sales@ITnuggetsonline.com We reserve the right to reset passwords for inactive accounts.

IT Nuggets (CBT) acknowledges that EU and Swiss individuals have the right to access the personal information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to sales@ITnuggetsonline.com. If requested to remove data, we will respond within a reasonable timeframe.

Unfortunately, no online data transmission can be fully guaranteed to be secure. Thus, by accessing the Website and/or utilizing the Services, you acknowledge that: (a) there are online security and privacy limitations that are beyond IT Nuggets (CBT)’ control; (b) the security, integrity and privacy of any and all information and data exchanged between you and IT Nuggets (CBT) through the Website cannot be fully guaranteed and we shall have no liability to you or any third party, with the exception of data covered under the Privacy Shield, for loss, misuse, disclosure or alteration of such information not resulting from the direct fault or negligence of IT Nuggets (CBT); and (c) any such information and data may be viewed or tampered with in transit by a third party.

SPECIAL NOTICES:

Special Notice to California Residents

If you are a California resident and have provided us with any Personally Identifiable Information (PII), California law gives you the right to request and receive from us, once per calendar year, information as to how we have shared your PII with third parties for their direct marketing purposes. However, as stated in this Policy, we do not share information with third parties for their direct marketing purposes.

If you wish to make a request concerning your California “Shine the Light” rights, please send us a request using the contact information below below. Your request must also include your name, email, and current valid California address. We will respond to you within thirty days of receiving such a request.

Special Notice to EU Residents

IT Nuggets (CBT) is subject to the investigatory and enforcement authority of the United States Federal Trade Commission. IT Nuggets (CBT) is obliged to disclose personal data pursuant to lawful requests.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, IT Nuggets (CBT) commits to resolve complaints about our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact the IT Nuggets (CBT) Data Privacy Officer at:

London IT Training

43 Broadway,

London E15 1XH,

UK

IT Nuggets (CBT) has further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information. The services of BBB EU Privacy Shield are provided at no cost to you.

An individual also has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms.

CHANGES TO THIS PRIVACY POLICY:

IT Nuggets (CBT) shall post any revisions to this Privacy Policy on this web page link. The Effective Date of this Privacy Policy version is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Website and this Privacy Policy to check for any changes.

Your continued use of the Services after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to be bound by the modified Privacy Policy.