PRIVACY POLICY

CONTENT ENABLERS, INC. (“Content Enablers,” “we,” “us,” or “our”) respects individual privacy and values the confidence of its customers, employees, business partners and others. This Privacy Policy (the “Policy”) applies to both this website (the “Site”) and any online training programs created by Content Enablers (the “Programs” and together with the Site, the “Services”). Content Enablers wants you to understand how it collects and uses information from the Services so you can interact with Content Enablers with confidence. By using the Services, you accept and agree to the practices this Policy describes.

The Policy also applies to all Personal Information received by Content Enablers in the United States (US) from the European Economic Area (EEA) (which includes the twenty-eight members states of the European Union (EU), Switzerland, Iceland, Liechtenstein and Norway), in any format including electronic, paper, or verbal.

Certain Definitions

For purposes of the Policy, the following definitions shall apply:

“Agent” means any third party that uses Personal Information provided by Content Enablers to perform tasks on behalf of and under the instructions of Content Enablers.

“Content Enablers, Inc.” means its predecessors, successors, subsidiaries, divisions, and groups in the US.

“Partners” means any third parties that Content Enabler partners with to provide online training programs, online storefronts, or other co-branded services.

Information We Collect

When you use the Services, we may collect and use personally identifiable information about you, as well as other information. “Personal Information” includes your name, address, email address, and other similar information that can be used to identify you. Personal Information does not include information that is encoded or anonymized, or publicly available information that has been combined with non-public Personal Information. More specifically, when you use the Services, we may collect the following information:

• Details of your visits to the Services and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, browser type, the date and time you accessed or left the Site, and which pages you viewed. Some parts of our Services use cookies, pixel tags (also known as “web beacons”), and other technologies to collect this information about your general internet usage. See the section below called “How We Use Cookies and Pixel Tags” to learn more.
• Information that you provide directly to us by filling in forms on our Services, including your name, email address, street address, telephone number, or other information.
• Information provided to us when you communicate with us for any reason, including information you provide in emails you send us, or submissions you may make to our blog.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or that concerns health or sex life. Content Enablers does not collect Sensitive Personal Information.

How We Use Cookies and Pixel Tags

A “cookie” is a small computer file that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Keep in mind, however, that some website features or services may not function properly without cookies.

A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies.

"Do Not Track" Requests

Content Enablers’ Services currently do not respond to “do not track” or similar signals.

Use of Your Information

We use the information we collect from you primarily to enable us to provide the Services to you in the best possible manner. In addition, your information may be used for the following purposes:

• To provide you, including via your email address, with information relating to the Services;
• To administer our Services, including by monitoring and analyzing our Site traffic and usage patterns and by running our Programs; and
• To develop online training programs and analyses for employers.

Sharing Your Information

We may share your Personal Information with our Agents or our affiliates to:

• Assist us in providing our products and services to you, including by acting on our behalf to fulfil orders, deliver packages, send postal mail and email, remove repetitive information from customer lists, analyze data, provide marketing assistance, process credit card payments, and provide customer assistance; and
• Compile statistics and reports regarding our audience and the users of our Services.

Such third parties have access to Personal Information as needed to perform their functions, but they are not allowed to use it for other purposes. Content Enablers does not sell or rent Personal Information collected through the Services to anyone.

When you provide us with Personal Information we also may use and share your Personal Information to contact you, including via email, to thank you for providing your request, to conduct satisfaction surveys, or for other administrative purposes related to your request.

With Partners: We may also share your Personal Information with our Partners for the purposes of providing statistic and reports regarding our audience and the users of our Services. Partners may use your Personal Information to contact you to regarding their services, send marketing communications, or provide other information. Please review the Partner’s privacy policy to learn about their privacy practices

Other Circumstances: We may disclose your Personal Information to third parties if we are involved in a merger, acquisition, or sale of any or all of our business and/or our assets to a third party, or if we have a good faith belief that disclosure is necessary to:

• comply with applicable laws, regulations, legal process (such as a subpoena), or enforceable government request;
• enforce applicable Terms of Service, including investigation of potential violations of such Terms, or to detect, prevent, or otherwise address fraud, security, or technical issues; and
• protect against harm to the rights, property, or safety of Content Enablers, our users, or the public as required or permitted by law.

Communication Opt-Out

We communicate with users who visit our storefronts on a regular basis via email. For example, we may send you email communications to confirm any orders or other requests, send you information about changes to our Services, and to send notices and other disclosures as required by law.

We may also send emails regarding new Services offered by Content Enablers. You have the opportunity to exercise an opt-out choice if you do not want to receive these types of communications. The opt-out choice may be exercised by ticking or un-ticking the appropriate box if such checkbox is available at the points where Personal Information is collected or by contacting us. We will process your request to unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed. You also may opt-out of receiving such emails by clicking on the "unsubscribe" link within the text of the email.

Third Party Websites and Social Media Features

Our Site may contain links to other sites, including those of third parties or business partners. While we seek to link only to sites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices other websites use. By accessing other third party websites or applications through our Site, you are consenting to the terms and privacy policies of those websites. It is possible that other parties may collect Personal Information your online activities over time and across different web sites when you use Content Enablers’ Site.

Content Enablers is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Review and Correction of Your Information

You may review and edit the information Content Enablers collected about you at any time by contacting us at the addresses below. If your information has been shared with a third party, as described elsewhere in this Policy, then that third party has received its own copy of your data. If you have been contacted by one of these third parties and wish to correct or delete your information, please contact them directly.

California Privacy Rights

California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of Personal Information with third parties for direct marketing purposes. Content Enablers does not share any California consumer Personal Information with third parties for marketing purposes without consent.

California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.

Users Only of Legal Age of Majority

Our Services are designed and intended for those who are at least 18 years old. By using our Services, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age. No one under age 13 is authorized to submit any information, including personally identifying information, on our Services. Under no circumstances may anyone under age 13 use our Services. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf.

Human Resource Data Privacy

Content Enablers also handles HR data within the HR relationship as it relates to our employee(s) with the EU.

EU individuals whose HR data we receive can address questions or comments regarding the handling of that information directly to us at privacy@contentenablers.com. We resolve to deal with all questions regarding this data and potential grievances arising from it in a timely manner.

Content Enablers commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by the respective authorities with regard to [human resources] data transferred from the EU and/or Switzerland [in the context of the employment relationship].

General Data Protection Regulation

We abide by the General Data Protection Regulation (GDPR). The GDPR provides a framework for organizations to ensure protection of the Personal Information of European citizens and gives European citizens certain rights.

Legal Basis for Processing

If you are an individual from the EEA or Switzerland, our legal basis for processing your Personal Information will depend on the Personal Information concerned and the specific context in which it is collected. However, we will normally collect or process Personal Information from you only where:

• We have your consent to do so;
• Where we need the Personal Information to perform a contract with you (e.g. to deliver services); or
• Where the party is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

In some cases, we may also have a legal obligation to process Personal Information from you, or may need the Personal Information to protect your vital interest or those of another person.

Where we rely on your consent to process the Personal Information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

Our Services may contain links to other websites and the information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

Retention

We will retain your Personal Information for as long as is needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Rights to Access and Control Your Personal Data

Individuals residing in the EEA and Switzerland have certain rights to access and control their personal data. These rights include:

• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to data portability;
• the right to object; and
• rights in relation to automated decision making and profiling.

For a full list of rights, please visit https://gdpr.eu/tag/gdpr/.

EU-US and Swiss-US Data Privacy Framework

Content Enablers complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework (each, a “Framework” and collectively, the “Frameworks”) 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. Content Enablers has certified to the U.S. Department of Commerce that it adheres to the Data Privacy Framework Principles (the “DPF Framework”. If there is any conflict between the terms in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework, and to view our certification, please visit https://www.dataprivacyframework.gov/

Privacy Principles

The privacy principles in this Policy are based on the DPF Principles.

Notice: Where Content Enablers collects Personal Information directly from individuals in the EEA, the UK, and Switzerland it will inform them about the purposes for which it collects and uses Personal Information about them. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Content Enablers or as soon as practicable thereafter, and in any event before Content Enablers uses the information for a purpose other than that for which it was originally collected.

Choice: Content Enablers does not currently transfer Personal Information to third parties. In the event that Content Enablers engages any future third party, Content Enablers will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Content Enablers will provide individuals with reasonable mechanisms to exercise their choices.

Accountability for Onward Transfer: Content Enablers will obtain assurances in the form of a written contract from its Agents including marketing automation software partner, that they will safeguard Personal Information consistently with this Policy. Examples of appropriate assurances that may be provided by Agents include: a contract obligating the agent to provide at least the same level of protection as is required by the DPF Principles. Where Content Enablers has knowledge that an agent is using or disclosing Personal Information in a manner contrary to this Policy or the DPF Principles, Content Enablers will take reasonable steps to prevent or stop the use or disclosure. In cases of onward transfer to third parties of data of EU, UK, and Swiss individuals received pursuant to the relevant Data Privacy Framework, Content Enablers may remain liable for any misuse.

Security: Content Enablers uses commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect on our Site. These procedures include, but are not limited to, firewalls, encryption, intrusion detection, and Site monitoring. We also limit access to any Personal Information we receive to employees who need access to that information in order to do their jobs. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your Personal Information, we cannot guarantee that it will be 100% secure. Your transmission of your data to our Site thus is done entirely at your own risk.

Data Integrity and Purpose Limitation: Content Enablers will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Content Enablers will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.

We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Access: Content Enablers acknowledges the individual’s right to access their Personal Information. Upon request, Content Enablers will grant individuals reasonable access via email transmission of Personal Information that it holds about them. In addition, Content Enablers will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Recourse, Enforcement and Liability: Content Enablers will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Content Enablers determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution: In compliance with the DPF Principles, Content Enablers commits to resolve complaints about your privacy and our collection or use of your Personal Information. EU, UK or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Content Enablers at: privacy@contentenablers.com.

Content Enablers has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

Complaints and Questions: If you have any questions or believe that we have infringed on your rights, please contact us so we can try to address your concerns or dispute informally. You can reach us by email at privacy@contentenablers.com.

You also have a right to lodge a GDPR-related complaint with a competent supervisory authority situated in the country of your habitual residence, place of work, or place of alleged infringement. You can find the relevant supervisory authority name and contact details for the EEA here, the UK here, and Switzerland here.

Privacy Policy Updates

This Privacy Policy was last updated on November 10, 2021.

We update the Privacy Policy from time to time, so please review it regularly. If we materially change our Privacy Policy, we will notify you by contacting you through your user account e-mail address or by posting a notice on our Services. Your continued use of the Services will be deemed your agreement that your information may be used in accordance with the new policy. If you do not agree with the changes, then you should stop using the Services and notify us that you do not want your information used in accordance with the changes.

Contacting Us

We welcome any questions, comments, or complaints you may have regarding this Privacy Policy. Please do not hesitate to contact us by email at privacy@contentenablers.com or by writing to:

CONTENT ENABLERS, INC
462 Broadway, Suite 200
Saratoga Springs, NY 12866
privacy@contentenablers.com