MINDFORGE PRIVACY POLICY

 

EFFECTIVE DATE: AUG 23, 2019

 

At MindForge LLC,(“MindForge,” “we,” “us,” or “our”) privacy is a priority. This Privacy Policy explains how MindForge collects and uses information from customers and other individuals who access or use our website, our mobile applications, including, without limitation, Site-Smart, and other MindForge-related content, products, and services (collectively the “Services”) that link to this Privacy Policy. By using our Services, you understand that we will collect and use your information as described in this Privacy Policy.

 

Please note that this Privacy Policy only applies to the MindForge Services.  Our owner, International Risk Management Institute, Inc. (“IRMI”) has a separate Privacy Policy that explains how IRMI collects and uses information from customers and other individuals who access or use IRMI’s website, products, and services.

 

We recommend that you read this Privacy Policy in full to understand how we collect and use gathered information. However, if you want to access a particular section of this Privacy Policy, please refer to the Table of Contents below.

 

1.         Information We Collect

2.         How We Use Your Information

3.         Information Sharing

4.         Your Choices

5.         Children’s Privacy

6.         Additional Information for California Residents

7.         Users from Outside the United States

8.         How We Protect Your Information

9.         Links to Third-Party Websites and Apps

10.       Changes to this Privacy Policy

11.       How To Contact Us

 

1.         INFORMATION WE COLLECT

 

To provide and improve our Services, we collect information about visitors to our sites, users of our Services, and the devices they use.

 

We collect certain information directly from you, such as when you fill out forms with a name or email address or when you register for an account. We collect other information about devices, browsers, or locations, automatically (without you typing it into a form).

 

You have choices about whether you visit our website, install our app, or provide information to us. However, if you do not provide us with certain information, you may not be able to use some of our Services. For example, if you do not register or create an account, you may not be able to create a profile or access portions of our website. For choices you may have, please see the “Your Choices” section of this Privacy Policy.

 

1.1       Information We Collect from You

 

You provide us with information about yourself when you:

 

a.         Register for an Account

 

To create an account, you need to provide us with information including your name, email address and/or mobile number, and a password. If you purchase certain Services, you will need to provide payment (e.g., credit card) and billing information.

 

b.         Create or Update a Profile

 

You have choices about the information on your profile, such as your education, work experience, skills, photo, or location. You may edit your profile information at any time or may Contact Us if you need help editing your profile. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping you to connect with your colleagues, people at your jobsite, and others in your industry. Please note that you are not required to include certain sensitive information, such as race, ethnicity, political opinions, philosophical beliefs, or trade union memberships, on your profile or to make that type of sensitive information public. Please do not post or add any sensitive information or other personal information to your profile that you would not want to be publicly available.

 

c.         Additional Ways You Provide Personal Information to Us

 

You also provide us with information about yourself when you:

 

●          Purchase or register for one of our courses;

●          Sign up to receive emails from us;

●          Participate in any interactive tools or features offered by the Services, such as messaging or posting content on discussion boards;

●          Download and use one of our mobile applications;

●          Contact us for customer support; or

●          Contact us to provide us with comments and suggestions about the Services.

 

1.2       Information We Collect from Others

 

a.         Employer Provided Information

 

Others purchasing our Services for your use, such as your employer, provide us with personal information about you and your eligibility to use the Services that they purchase for use by their employees. For example, we may receive authorization from your employer to provide you access to specific Services (such as training or certification courses).

 

b.         Content and News

 

You and others may post content that includes information about you (as part of messages, discussion board posts, or announcements) on our Services. Unless you Contact Us to opt out, we collect public information about you, such as professional-related news and accomplishments (e.g., certifications earned, training modules completed, professional recognition, etc.) and make it available as part of our Services as part of your Profile.

 

1.3       Information We Collect Automatically

 

We automatically collect information from you and your devices when you use our Services, even when you visit our website or our app without logging in. For choices you may have on what information we automatically collect, please see the “Your Choices” section of this Privacy Policy.

 

The information we automatically collect includes:

 

a.         Device and Usage Information

 

We collect information about how you use our Services and the computers or other devices, such as mobile phones or tablets, you use to access our Services. Examples include:

 

●          IP address

 

●          Geolocation information

 

●          Unique device identifiers and device attributes, like operating system and browser type

 

●          Usage data, such as: web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information

 

b.         Cookies and Related Technologies

 

We may use cookies, which are text files containing small amounts of information that are downloaded on your device (“Cookies”), or related technologies, such as web beacons, local shared objects, and tracking pixels to store or collect information. Cookies can store your preferences, your user name, and help tailor content and advertisements. The “Your Choices” section below explains how you can manage cookies.

 

c.         Messages

 

If you communicate through our Services, we learn about that. We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a message from a colleague or a member of your network, we track whether you have opened the message. We do not read your messages, except in incidental situations as may be necessary to provide, fix, or improve our Services. We do not use automatic scanning technology on messages.

 

2.         HOW WE USE YOUR INFORMATION

 

2.1       In General.

 

In general, we collect, use, and store or process your information to provide our Services, to fix and improve them, to develop new services, and to market our Services. Here are some examples of how we use the information we collect:

 

●          To provide you with the Services you request and collect payments

●          To process and respond to your requests and inquiries, or to otherwise provide you with customer support when you request such support

●          To perform research and analysis about your use of our Services as well as your interest in new products, services, or features

●          To create statistics and reports for various business purposes

●          To develop and display content and advertising tailored to your interests

●          To verify your log-in credentials to maintain the security of our Services

●          To manage the MindForge website and app, including support systems and security

●          To perform functions essential to our business operations

●          To perform functions as otherwise described to you at the time of collection

●          To prevent, investigate, and respond to fraud, unauthorized access to, or use of, our Services, breaches of terms and policies, or other wrongful behavior

●          To comply with applicable legal requirements, industry standards, and our policies, including this Privacy Policy.

 

2.2       We May Send You Promotional Communications

 

We may send you promotional communications via email in order to provide you with targeted, relevant content or information about Services that may be of interest to you. All promotional communications sent via email will include a link to unsubscribe from future promotional email messages. You may also Contact Us at any time to opt out of receiving our email promotional communications.

 

You may not opt out of receiving the following communications from us via email or U.S. mail or by any other electronic method specified herein or in our Terms of Use: (a) legal notices; (b) notices regarding changes to the Terms of Use, Privacy Policy, or changes to the Services; (c) notices regarding violations of our Terms of Use; (d) notices concerning fees you may owe for the Services; or (e) invoices for fees for the Services.

 

2.3       Lawful Basis for Using Your Information

 

The Services are not designed to be used outside of the United States. If you are visiting the Services from outside of the United States, or are otherwise contacting us from outside the United States, please be aware that your information, including personal information or financial information, may be transferred to, or processed in, the United States where our servers and database(s) are located and operated, or in those countries where our authorized service providers are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in force in your country. That said, we collect or use information from you or others only where we have your consent to do so, where we need the information to perform a contract with you, or where the use is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or use personal information or may need the personal information to protect your vital interests or those of another person. For example, when we:

 

●          Use information to create and manage an account, we need it in order to provide relevant Services.

 

●          Gather usage data and analyze it to improve our Services, we do so based on our legitimate interest in safeguarding and improving our Services. Usage data is not anonymized.

 

If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us using the contact details provided in the “How to Contact Us” section of this Privacy Policy.

 

3.         INFORMATION SHARING

 

We do not share your information with third parties except as described in this Privacy Policy.

We share information as follows:

 

3.1       Authorized Service Providers

 

We may share your information with our authorized service providers that perform certain services on our behalf. These services may include customer service, processing credit card or other payments, or supporting the functionality of our Services. These authorized service providers may have access to personal information needed to perform their services for us, but they are not permitted to share or use such information for any other purposes and are required to maintain the confidentiality, security, and integrity of such information.

 

3.2       Our Services

 

a.         Your Profile.

 

Your profile is fully visible to Users who are logged in to the Services and who are either: (i) within your organization; or (ii) working at the same jobsite; or (iii) with whom you have connected. Subject to your settings, it can also be visible to others on or off of our Services (such as nonmembers or visitors to our Services or users of third-party search engines).

 

b.         Messages and Posts

 

Our Services allow viewing and sharing information including through messages, discussion, or message board posts and comments.

 

●          Any information you share through company or organization pages, including your employer’s page, on our Service will be viewable by others who visit those pages.

 

●          In groups or discussion boards, posts are visible to others in your organization or others working at the same jobsite. Your membership in groups is not public nor is it a part of your profile.

 

3.3       Safety, Security, and Compliance with Laws

 

In addition to the purposes described above, we may share your personal information in response to subpoenas, court orders, or legal process, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.

 

Furthermore, we may disclose your personal information when we believe disclosure is necessary in order to investigate, prevent, report, or take action regarding illegal activities, suspected fraud or other wrongdoing; to protect the security or integrity of the Services; to protect and defend the rights, property, or safety of our companies, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website Terms of Use or other agreements or policies.

 

3.4       Business Transactions

 

We may also disclose your personal information to a third party in connection with a substantial corporate transaction, such as sale of any or all of our businesses, a partial or total sale of the assets of any of our businesses, or if we or our subsidiaries and affiliated companies are involved in a divestiture, merger, acquisition, reorganization, or other corporate change, or in the unlikely event of bankruptcy. Any third party to whom we transfer or sell our assets will have the right to continue to use the personal information that you provide to us but only in the manner set forth in this Privacy Policy.

 

3.5       Consent

 

We may share your information in other ways if you have asked us to do so or have given consent. For example, with your consent, we post user testimonials that may identify you.

 

4.         YOUR CHOICES

 

This section describes many of the actions you can take to change or limit the collection or use of your information.

 

4.1       Data Retention

 

We keep your personal information for no longer than necessary to fulfill the purposes outlined in this Privacy Policy. The length of time for which we retain information depends on the purposes for which we collected and use it, and/or as required to comply with applicable laws. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal data and limit active use of it.

 

4.2       Rights To Access and Control Your Personal Information

 

We provide choices about the collection, use, and sharing of your personal information, from deleting or correcting information you include in your profile to messaging controls. We offer you settings to control and manage the personal information we have about you.

 

For personal information that we have about you, you can:

 

●          Delete Information: You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide Services to you).

 

●          Change or Correct Information: You can edit some of your personal information through your account. You can also ask us to change, update, or fix your information in certain cases, particularly if it’s inaccurate.

 

●          Object to, or Limit or Restrict, Use of Information You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal information is inaccurate or unlawfully held).

 

●          Right To Access and/or Take Your Information: You can ask us for a copy of your personal information and can ask for a copy of personal information you provided in machine readable form.

 

Please Contact Us to learn more about how to make these requests. You may also contact us using the contact information in Section 11 below, and we will consider your request in accordance with applicable laws.

 

4.3       Managing Cookies

 

You can manage cookies by using features and functions available on most Internet browsers. For example, most browsers will allow you to choose what cookies can be placed on your computer and to delete or disable cookies. To learn more about how to control cookie settings through your browser:

 

Click here to learn more about managing cookie settings in Firefox;

Click here to learn more about managing cookie settings in Chrome;

Click here to learn more about managing cookie settings in Internet Explorer; and

Click here to learn more about managing cookie settings in Safari.

 

In addition, Firefox and Chrome have third-party add-ons that can help enhance your control over your privacy.

 

Please note that if you decline or disable cookies entirely, certain features of the Services may not function properly.

 

4.4       Do Not Track Signals

 

Some Web browsers allow you to set a "Do Not Track" privacy preference that transmits a “Do Not Track” signal to the websites you visit with information indicating that you do not want your activity to be tracked. More information about this privacy preference can be found on the following websites: Firefox, Google, and Internet Explorer. Please note that this “Do Not Track” signal is different from disabling certain forms of tracking cookies in your browser settings, as browsers with the “Do Not Track” preference enabled still have the ability to accept cookies. We do not respond to “Do Not Track” signals at this time. If we do so in the future, we will describe how we do so in this Privacy Policy. For more information about “Do Not Track,” please visit www.allaboutdnt.com.

 

4.5       Device and Usage Information

 

If you do not want us to see your device location, you can turn off location sharing on your device, change your device privacy settings, or decline to share location on your browser.

 

4.6       Account Closure

 

You may choose to close your account at any time by contacting MindForge.

 

5.         CHILDREN’S PRIVACY

 

Our Services are not designed for and are not marketed to people under the age of 18 (“minors”). We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use our Services. In fact, we require users who register for an account to be at least 18 years old. If we learn that a user is a minor, we will promptly delete any personal information that the individual has provided to us. If you are a minor, please do not use our Services or send us your information. Please Contact Us if you believe we might have information from or about a minor.

 

6.         ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

 

Pursuant to California Civil Code Section 1798.83, also known as the “Shine The Light” law, California residents are entitled to request and obtain from website operators or owners, once per calendar year, information regarding the “personal information” (as that term is defined by California Civil Code Section 1798.83) about themselves, if any, that the website operator or owner shared with third parties, including affiliates, for direct marketing purposes during the preceding calendar year. If such information is shared with third parties for their direct marketing purposes, the website operator or owner is required, upon request, to provide the list of the categories of personal information described in California Civil Code Section 1798.83(e)(6) that were disclosed in during the preceding calendar year, if at all, and the names and addresses of all third parties with which it has shared such information for direct marketing purposes. MindForge does not share any personal information with third parties, including affiliates, for their direct marketing purposes.

 

7.         USERS FROM OUTSIDE THE UNITED STATES

 

As previously noted, the Services are not designed to be used outside of the United States. If you are a user from a country outside of the United States, by using our Services, you:

 

(a)        Acknowledge that your information will be used as described in this Privacy Policy; and

 

(b)        Consent to having your information transferred to us and our facilities, in the United States or elsewhere, and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

 

8.         HOW WE PROTECT YOUR INFORMATION

 

We use a variety of security measures to protect your personal information. We employ reasonable organizational, electronic, physical, administrative, and technical measures, including encryption, firewalls, access controls, and other security protocols to help safeguard personal information from unauthorized access or disclosure. However, due to the inherent open nature of the Internet and related technology, we cannot warrant or guarantee that the security measures we have in place to safeguard personal information will always be sufficient or effective, nor can we warrant or guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy. MindForge expressly disclaims any such obligation.

 

9.         LINKS TO THIRD-PARTY WEBSITES AND APPS

 

This Privacy Policy applies solely to our Services. The Services may contain links to third-party websites and apps that are not owned or operated by us. We provide these links solely as a convenience to you. We do not control and are not responsible for the privacy practices, policies, or the content of such third-party websites or apps, even if you link to such websites or apps from our Services. You should review the terms and policies for third-party websites and apps before clicking on any links.

 

10.       CHANGES TO THIS PRIVACY POLICY

 

We reserve the right to modify this Privacy Policy to reflect changes in the law, our company, our Services, our data collection and use practices, or advances in technology. When we post changes to this Privacy Policy, we will revise the “Effective Date” date at the top of this Privacy Policy, and any changes will be effective upon posting of the revised version of this Privacy Policy.

 

If, in MindForge’s sole discretion, we make what we deem to be material changes to this Privacy Policy, we will provide notice through our Services, or by other means, such as email, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may Contact Us to close your account.

 

You acknowledge that your continued use of the Services after we publish or send a notice about our changes to this Privacy Policy means the collection, use, and sharing of your personal information is subject to the updated Privacy Policy.

 

11.       HOW TO CONTACT US

 

If you have any questions or comments about this Privacy Policy or our privacy practices, please Contact Us. You may also contact us at the following address or phone number:

 

MindForge LLC

C/O Customer Service

22 E Gay Street, Suite 600

Columbus, OH 43215

Toll-Free: (844) 846–0456