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GDPR Readiness Assessment Powered by PositiveGrid, Inc. Privacy Note

We take the private nature of your personal information very seriously, and are committed to protecting it. To do that, we've set up procedures to ensure that your information is handled responsibly and in accordance with applicable data protection and privacy laws. We're grateful for your trust, and we'll act that way.

The privacy policy explains how we use any personal information we collect about you when you use this website, our products, our wider services, and what choices we offer you to access, update, and control it.

Glossary of Terms

Personal information:

Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

  • Names and contact information (i.e. emails and telephone numbers)
  • National Insurance Numbers
  • Employment history
  • Employee numbers
  • Credit History
  • Personal tax
  • Payroll and accounting data
Sensitive personal information:

Sensitive personal data refers to the above but includes genetic data and biometric data. For example:

  • Medical conditions
  • Religious or philosophical beliefs and political opinions
  • Racial or ethnic origin
  • Convictions
  • Biometric data (e.g. photo in an electronic passport)
What is a Data Controller?

For general data protection regulation purposes, the “data controller” means the person or organization who decides the purposes for which and the way in which any personal data is processed.

The data controller is PositiveGrid. Positive Grid
3773 Howard Hughes Pkwy
South Tower, Suite 500
Las Vegas, NV 89169
USA

What is a Data Processor?

A “data processor” is a person or organization which processes personal data for the controller.

Whose data we collect?

We collect and process from a range of our customers:

  • Visitors to our website at www.positivegrid.com and other related websites.
  • Customers who use our software (including software demos) or our services.
  • Customers who bought our hardware directly or from our agencies.

You will fall into one or more of these categories of customers.

What data is being collected?

COLLECTION OF PERSONAL DATA OFF LINE

If Positive Grid processes personal data off-line (e.g. printed forms), the party concerned must be given an information notice regarding the processing in order to obtain their consent, whenever necessary; this also applies to situations in which the data are collected from forms downloaded from the web site (the privacy statement is set out on the forms together with, whenever necessary, the request for express consent to the specific handling operation in question).

COLLECTION OF PERSONAL DATA ON LINE

As regards to the collection of data directly on the web site (e.g. registration forms, data sent in order to benefit from services online), the basic information relating to the processing is provided on each individual form found on the site (e.g. at the end of each registration form); this page can however be accessed at any time in order to view the PRIVACY POLICY applied more generally by Positive Grid.

Every request for information regarding the processing of personal data, whether optional, explicit or voluntary, made by electronic mail, necessarily requires the address of the sender/applicant to be given, as well as any further personal data included in the message, in order that a reply can be submitted.



We collect data from you directly or receive them from 3rd party services (e.g. Google Analytics, BigCommerce, etc.)

Personal data
Profiling:
  • Name
  • Age
  • Gender
  • Email
  • Country
  • Language
  • Phone
  • Address
  • Avatar
Technology:
  • Encrypted device UUID (Universally Unique Identifier)
  • OS version
  • Browser
  • Device
Behavior
Interaction with functions and contents presented on given platform (if applicable):
  • Viewing/Browsing
  • Searching
  • Clicking
  • Playing
  • Adding to cart
  • Purchasing
  • Downloading
  • Login
  • Leaving/Abandoning
Transaction:
  • Product purchased
  • Amount
  • Payment method
Cookies

Positive Grid uses “cookies” to personalize surfing on the Internet. A cookie is a text file that is stored in the non-volatile memory in the user’s device by the server of Web pages. Cookies cannot be used to execute programmes or transmit viruses to your computer. Cookies are designated to users individually and can only be read by Web servers belonging to the domain that created them.

One of the main purposes behind cookies is to provide a simple, practical method to help you save time. For example, if you personalize Positive Grid pages or register with Positive Grid sites or services, a cookie will facilitate access to consult the Web pages in question. Every time you visit the Positive Grid page, you can call up the information supplied beforehand, thereby utilizing the Positive Grid personalized functions in a straightforward, practical way.

Most browsers accept cookies automatically, but the browser may be programmed to refuse them. If you choose to refuse cookies, however, you may be unable to benefit from some of the interactive functions provided by Positive Grid services and by the Web sites you have visited.

Google Analytics

Positive Grid uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States . Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Positive Grid uses Google’s program for “interest-based advertising” for some marketing operations. In the process of this program a special browser cookie is stored on the user’s computer. It is used for serving the user special ads by Positive Grid, Google or third-party services when visiting other websites. Users can opt out of Google’s use of these cookies by visiting the Opt out site of Google ads.

If you want to opt-out, download and install the add-on for your web browser. (https://tools.google.com/dlpage/gaoptout?hl=en)

How do we share your data?

We may engage and contract with third party companies (e.g. service providers) to provide services that help us with our business activities such as cloud hosting services. These third party service providers are limited to only using information as instructed to provide contracted services to us.

We may also disclose your personal information:

  • As required by law such as to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process. Positive Grid also may be required to disclose personal information in response to lawful requests by public authorities, including requests from national security or law enforcement authorities.
  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a written government request.
  • We will share your personal information with third parties only in the ways that are described in this Privacy Notice. We do not otherwise sell your personal information to third parties.

How will the data be used?

GENERAL PURPOSE FOR WHICH DATA ARE USED

All personal data acquired and/or requested, either prior to or during the course of contractual relationship, will be used to fulfill your requirements, ensuring that the contractual obligations are met and administrative and legal obligations are provided correctly by the company Positive Grid, thereby allowing the business activities associated to its objectives to be conducted as efficiently as possible. The supply of data is not mandatory but is necessary in order to set up and execute this agreement; refusal to provide such data may therefore prevent the company from establishing a working relationship with you. Furthermore, your non-sensitive personal data provided with your express consent, revocable at any time, has been obtained, for the following additional uses:

  1. Inclusion in Positive Grid’s databases for the purpose of sending business notices/information relating to commercial activities conducted by Positive Grid.
  2. Use for statistical purposes in connection with promotional campaigns.
  3. Circulating of personal data, including in the form of images and/or videos within the company’s official website.
PROCESSING METHODS

Data will be processed using appropriate methods and tools that guarantee their confidentiality and may be processed using electronic or automated means (network data processing systems not accessible to the public) and using non-automated means (paper-based archives and records), both protected by appropriate security measures such as personalised passwords offering exclusive access, personal identity codes and limited access to records.

Certain types of data that are considered sensitive by the law (such as data capable of revealing racial and ethnic origin, religious, philosophical or other convictions, political opinion, membership of political parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, as well as personal data capable of revealing state of health or sexual activities), which we could be made aware, after being informed by yourself or after having processed documents furnished by you, at the start up or during the course of a working relationship with our Company, may only be used with your prior written consent.

TRANSFER OF DATA

Personal data supplied may not be transferred by our Company, except

  1. Only in the circumstances outlined by law, for the purpose of supplying the service requested and/or executing the agreement, in order to fulfill administrative, accounting and/or fiscal obligations referred to under point 1). In such circumstances, your express consent is not required, but failure to provide it will prevent the Company from setting up a working relationship or responding to your request;
  2. Solely to outside associates of the company Positive Grid, acting as tax and/or accountancy consultants, for the performance of the tasks described under point 1). Again, in these circumstances, your express consent is not required, but failure to provide it will prevent the Company from setting up a working relationship or responding to your request;
  3. To subsidiary companies and/or companies in which shares are held, sales networks (agents, dealers, collaborators and/or distributors), customer service and support agents, sub-suppliers and sub-contractors involved in conducting agreement / contractual or business relations.

How do we protect our customer’s data?

We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect from you.

How long will the data be stored for?

We will retain your information for as long as you maintain a GDPR Readiness Assessment account (if you are an EU user) with us and have not otherwise requested us to delete your information.

Access to your information, correction, portability and deletion

You are in complete control. You can object or withdraw your consent to the use of your personal data at any time.

Subject to some legal exemptions, you have the right to:

  • Request a copy of the personal information Positive Grid holds about you;
  • To have any inaccuracies corrected;
  • To have your personal data erased;
  • To place a restriction on our processing of your data;
  • To object to processing; and
  • To request your data to be ported (data portability).

Please address any such requests to the Positive Grid Data Protection Officer by contacting privacy@positivegrid.com

If you are dissatisfied with the way LearnTech processes your personal data you should formally raise such complaints with the Data Protection Officer (DPO).

Privacy Policy
Positive Grid
©2018 Positive Grid All rights reserved.


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