LEGAL & PRIVACY POLICY

Last Updated: 05/08/2019
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This Privacy Policy (“Privacy Policy”) explains how K2Share, LLC and its subsidiaries and affiliates, including CareerSafe, LLC (“CareerSafe”) collects, uses, and discloses information about you (“Personal Data”) through its website and other online products and services, including the CareerSafe course platform ( the “Platform,” and collectively, the “Services”) or when you otherwise interact with us.  K2Share LLC and its subsidiaries and affiliates, including CareerSafe serves residents of the United States and is not intended to serve users from other countries or territories. This Privacy Policy is intended to be read in connection with our Terms of Use and that by accessing or using our Services, you agree to be bound by both the Terms of Use and this Privacy Policy.

 

We may occasionally update this Privacy Policy – you can see when the last update was by looking at the “Last Updated” date at the top of this page. We won’t reduce your rights under this Privacy Policy without your explicit consent. If we make any significant changes to this Privacy Policy or material changes to data security processes or protocols, we’ll provide prominent notice by posting a notice on the Service and/or notifying you by email (using the email address you provided), so you can review and make sure you know about them prior to the change taking effect. We will notify schools in advance of material changes to this policy.

 

We encourage you to review the Privacy Policy whenever you access our Services or otherwise interact with us to stay informed about our information practices and the choices available to you. By continuing to use the Service after the revised Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.

 

Educational institutions (e.g., teachers, schools, or districts) should evaluate this Privacy Policy and our Terms of Service to ensure CareerSafe complies with their privacy policies and other requirements. Educational institutions shall be responsible, where applicable, for obtaining pertinent consent from parents, legal guardians or eligible students prior to utilizing the service. K2Share LLC and its subsidiaries and affiliates, including CareerSafe shall not be responsible for any miscare of the educational institution in the review of this privacy policy.

 

1. WHAT PERSONAL DATA DO WE COLLECT?

1.1 PERSONAL DATA YOU PROVIDE TO US

We collect Personal Data you provide directly to us. For example, we collect Personal Data from you in the following situations:

  • If you register for and participate in one or more of our online courses or surveys, we collect your first and last name, email address, race, gender, age, assessment and test results, progress results, completions, transcripts of courses, course survey information and other data necessary to support online training.
  • If you express an interest in obtaining additional information about our Services, request customer support, use our “Contact Us” or similar features, sign up for an event, webinar or contest, or download certain content, we may require that you provide to us your contact information, such as your name, job title, school or company name, mailing address, phone number, and email address;
  • If you make purchases via our Services or register for an event, webinar, or course, we may require that you provide your financial and billing information, such as billing name and address, credit card number or bank account information;
  • If you attend an event, we may upon your consent scan your attendee badge, which will provide to us your name, title, company name, address, country, phone number and email address;
  • In support of media coverage of events or contests, we may upon your consent record quotes, take photographs or film which would be posted on our website or social media; and

If you provide to us any Personal Data relating to other individuals, you represent that you have the authority to do so and permit us to use the Personal Data in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information in Section 12 below.


1.2 INFORMATION ABOUT YOUR USE OF THE SERVICES

When you access or use our Services, we automatically collect information about you, which may qualify as Personal Data, including:

  • Log Information: We collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
  • Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. In particular, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites. Information on Google Analytics and how it collects and processes data can be found at "How Google uses data when you use our partners' sites or apps", ( google.com/policies/privacy/partners/, or any other URL Google may provide from time to time)”. Additional information on Google Analytics can be found at https://www.google.com/analytics/terms/us.html. CareerSafe may also utilize HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it. For more information about cookies and how to disable them, please see “Your Choices” below.

 

1.3 PERSONAL DATA WE COLLECT FROM OTHER SOURCES

We may obtain information about individuals who purchase our services directly from our website (e.g., not affiliated with an educational institution) as well as information about teachers and administrators at a school, district or other public education entity from other sources and combine this information with Personal Data we collect through our Services, including Personal Data provided by you. This helps us to, among other things, update, expand and analyze our records, identify new customers and create more tailored advertising to provide services that may be of interest to teachers, administrators at a school, district or other public education entity, and individual purchasers of our services. In particular, we collect Personal Data belonging to teachers and administrators at a school, district or other public education entity from third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion and profiling.

 

2. HOW DO WE USE PERSONAL DATA?

We use the Personal Data we collect and process to provide, maintain, and improve our services and may also use the Personal Data we collect to:

  • Send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;
  • Promote the security of our Services by tracking use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies to protect the rights and property of CareerSafe and others;
  • Manage user registrations;
  • Manage event registrations and attendance;
  • Manage contests or promotions and deliver entries and rewards;
  • Manage payments;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Personalize and improve the Services; and
  • Communicate with teachers and administrators at a school, district or other public education entity as well as individuals which purchase our services directly from our website and are not affiliated with an educational institution about products, services, offers, and events offered by CareerSafe, and provide news and information we think will be of interest to teachers, administrators at a school, district or other public education entity, and individuals who purchase our services directly without affiliation with an educational institution.

 

3. WHO DO WE SHARE PERSONAL DATA WITH?

We may share your Personal Data as follows or as otherwise described in this Privacy Statement:

  • With third party operators such as our vendors, consultants and other contracted service providers who provide services such as credit card processing, research and analytics, marketing, customer support and data enrichment and need access to such information to carry out work on our behalf. Here is a list of the essential third-party service providers we work with, if they are used only on our website or within our Services, why we use them and links to their respective privacy policies;
Vendor
Service or Website Only
Purpose
Amazon Web Services (AWS)
Services
Cloud Infrastructure as a Service
Google Analytics
Website Only
Website Traffic Analytics
PayPal
Services
Credit Card Processing
Salesforce
Website and Services
Marketing to teachers and administrator at a school, district, or other public education entity; we do not market to students.

If you attend an event or webinar organized by us, or download or access an asset on our website, with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with the instructions set forth in “Your Choices” below; 

  • With sponsors of contests or promotions for which you register;
  • With third-party social media networks, advertising networks and websites, which usually act as separate controllers, so that CareerSafe can market and advertise on third party platforms and websites;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with our user agreements, terms or policies, or to protect the rights, property and safety of CareerSafe or others;
  • Between and among CareerSafe and our current and future parents, affiliates subsidiaries and other companies under common control and ownership;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. In the event that all or a portion of the CareerSafe or its assets are acquired by or merged with a third-party, personal information that we have collected from users would be one of the assets transferred to or acquired by that third-party. This Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this policy (unless you give consent to a new policy). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage, or by email to your email address that you provided to us. If you do not consent to the use of your personal information by such a successor company, you may request its deletion from the Company. In the unlikely event that we go out of business, or file for bankruptcy, we will protect your personal information, and will not sell it to any third-party;
  • With the United States Department of Labor Occupational Safety and Health Administration (“OSHA”) in order to process OSHA card requests; and
  • With your consent or at your direction.

For further information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section, below.

 

4. USERS UNDER 13

Except as described in this section, we do not knowingly collect Personal Data of users under the age of 13. In accordance with the Children’s Online Privacy Protection Act (“COPPA”) policies for online educational services, we require the educational institution (teacher, school, or district), on behalf of the parents or legal guardians of a student under the age of 13, to provide consent for the online collection of student Personal Data through CareerSafe services as a “Child User”.  After the educational institution has obtained parental consent, teachers may register the Child User or provide a CareerSafe voucher to the student, parents, or legal guardians to allow the Child User to register.

If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in Section 12, and we will take steps to delete such Personal Data from our system.

 

4.1 PERSONAL DATA WE COLLECT FROM CHILD USERS AND HOW WE USE IT

  • Child User Personal Data: We will collect the following Personal Data from Child Users in order to provide the Services requested by the Child User’s educational institution in connection with the Platform: (1) first name, (2) last name, (3) email address, (4) age, (5) gender, (6), race, (7) assessment and test results, progress results, completions, transcripts of courses, course survey information and other data necessary to support online training. This information is either provided directly by the Child User or provided to us through the school that is offering our Services via the Platform.
  • Use of Child User Data: A Child User’s Personal Data will only be used by CareerSafe in order to provide the Services requested by the Child User’s school, which includes online courses via the Platform. In addition, CareerSafe may provide a Child User’s school or teacher with access to his or her test scores and will submit a Child User’s Personal Data to the Department of Labor in order for the Child User to receive an OSHA card after successful completion of any such online course.
  • Information Collected by Cookies and Other Tracking Technologies: Please refer to Section 1.2 for more information on how we use various technologies to collect information, including cookies and web beacons.

 

4.2 PARENTAL RIGHTS

Because CareerSafe relies on the parental consent for a Child User provided via the Child User’s school, parents should always contact the school first with any questions, concerns or requests regarding their child’s Personal Data. Notwithstanding the foregoing, (1) we will not require a Child User to disclose more information than is reasonably necessary to participate in the Services specifically requested by the Child User’s educational institution, (2) a Child User’s parent or guardian can review their child’s Personal Data, direct us to delete it, and refuse to allow any further collection or use of the Child User’s Personal Data, and (3) a Child User’s parent or guardian can agree to the collection and use of their child’s Personal Data, but not allow disclosure to third parties unless part of the Services (e.g., disclosure to the Department of Labor in order to receive an OSHA card). To exercise any of these rights, a Child User’s parent or guardian should first contact the Child User’s educational institution but may also contact us as set forth in Section 12.

 

5. SOCIAL SHARING FEATURES

Our Services may offer social sharing features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Sharing Features”). You may be given the option by such Social Sharing Features to post information about your activities on our Services to a profile page of yours that is provided by a third-party social media network in order to share with others within your network, depending on the settings you establish with the entity that provides the Social Sharing Feature. For more information about the purpose and scope of data collection and processing in connection with Social Sharing Features, please visit the privacy policies of the entities that provide these features.

 

6. ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by CareerSafe and others to, among other things, analyze and track data, and determine the popularity of certain content. This information may also be used to deliver teachers and educational institution administrators (school or district) advertising and content targeted to their interests on our Services and other websites and better understand their online activity. For more information about interest-based ads, or to opt out of having web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

 

7. SECURITY

CareerSafe takes reasonable measures to help protect your Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. In particular: 

  • Security Protocols: We periodically review our information collection, storage and processing practices to guard against unauthorized access to systems.
  • Security Technology: We implement features to keep your personal information safe - for example, when you enter any information anywhere on the Service, we encrypt the transmission of that information using secure socket layer technology (SSL) by default.
  • We ensure passwords are stored and transferred securely using encryption and salted hashing.
  • Employee Access: We make best effort practices to secure usernames, passwords and any other means of gaining access to user data. All employees sign confidentiality agreements and pass criminal background checks.
  • Employee Training: We provide periodic security and privacy training to those employees responsible in whole or in part for design, production, development, operations, or marketing of our services. This includes employees that are directly or peripherally involved in collection, use, storage, disclosure or any other handling of Personal Data.

Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems as per best industry standards, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. If we learn of a security breach or other unauthorized disclosure of your Personal Data, we will attempt to notify you so that you can take appropriate protective steps by posting a notice on our homepage (www.careersafeonline.com) or elsewhere in our Service and we will send email to you at the email address you have provided to us. Additionally, we will notify the primary administrative contact at your school or district by email and telephone and assist with their efforts to ensure your notification. Any such notice will include:

  • The date of the breach.
  • The type of information that was subject to breach.
  • General description of what occurred.
  • Steps we are taking to address the breach.
  • The contact person with CareerSafe who you can contact regarding the breach.

If you are a parent, legal guardian or eligible student and an unauthorized disclosure of your student’s Personal Data records occurs, we will notify you by email at the email address we have on record for you or through notice to your school or district’s primary administrative contact in the event that we do not have an email address on record for you.

 

8. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We store the Personal Data we collect about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal or other regulatory obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable regulator obligations (e.g., OSHA) and legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

For further information on applicable data retention periods, please contact us by using the information in the “Contacting us” section, below.

 

9. TRANSFER OF PERSONAL DATA TO THE U.S. AND OTHER COUNTRIES

CareerSafe is based in the United States and we use Amazon Web Services (AWS) to host the application and for cloud computing and storage.  All Personal Data is securely stored on AWS resources in the United States.

 

10. YOUR CHOICES

10.1 ACCOUNT INFORMATION

You may update, correct or delete information about you at any time by logging into your online account or emailing us at support@careersafeonline.com. If you wish to delete or deactivate your account, please email us at support@careersafeonline.com, but not that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

 

10.2 COOKIES

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

 

10.3 YOUR RIGHTS RELATING TO PERSONAL DATA

CareerSafe is committed to protecting student Personal Data and will cooperate with school partners with regard to applicable access, correction, retention, deletion, use, sharing and other requirements (including the Student Online Personal Information Protection Act (SOPIPA), the federal Family Educational Rights and Privacy Act (FERPA), the federal Children’s Online Privacy Protection Act (COPPA), the Children’s Internet Protection Act (CIPA), and California Assembly Bill (AB) 1584.

An educational institution retains full ownership rights to the personal information and education records it provides to us in connection with our services. We will not use any student information from an educational institution for any purpose other than for the delivery and functioning of the Service.

Parents, legal guardians, or eligible students may review student Personal Data and correct erroneous information by contacting their educational institution. Our Platform provides educational institutions with functionality required to assist educational institutions in responding to requests from parents, legal guardians or students to inspect and review Personal Data and categories of data being held in education records. Additionally, users may access, correct, update, or delete personal information in their profile by signing into console, accessing their user account, and making the appropriate changes.

We will delete or de-identify personal information when it is no longer needed, upon expiration or termination of our agreement with an educational institution with any deletion or de-identification to be completed according to the terms of our agreement with the educational institution, or at the direction or request of the educational institution.


10.4 PROMOTIONAL COMMUNICATIONS

You may opt out of receiving promotional communications from CareerSafe by following the instructions in those communications or by emailing us at support@careersafeonline.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

 

11. LINKS TO OTHER SITES

The K2Share and CareerSafe web sites contains links to other sites that are not owned or controlled by CareerSafe or its parent organization. Please be aware that we are not responsible for the privacy or security practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every web site that may collect personal data.

 

12. CONTACTING US

To exercise your rights regarding your Personal Data, or if you have any questions regarding this Privacy Statement or our privacy practices, please email us at support@careersafeonline.com or call (888) 614-7233. You may also write us at CareerSafe, 1005 University Dr., E., College Station TX 77840.

 

In our commitment to protect the privacy of children, we participate in the iKeepSafe Safe Harbor program. If you have any questions or need to file a complaint related to our Privacy Policy and practices, please contact the iKeepSafe Safe Harbor program’s dedicated consumer complaint department at COPPAPrivacy@ikeepsafe.org. Any such complaints received by us will be submitted to the iKeepSafe Safe Harbor program upon receipt.

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