Effective starting: May 25, 2018
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us We collect information about you when you input it into the Services registration process, or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases for/through the Services. For example, you provide your contact information and, in some cases, billing information when you register for the Services. You also have the option of adding a display name, profile photo, job title, background, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.
Content you provide through our products: The Services include the TRL products you use, where we collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include. Examples of content we collect and store include (but are not limited to): the summary and description of your background and bio should you choose to become a Practitioner; content you post inside our products; the messages with comments and questions you submit via webform or webchat or email; testimonials you submit; and, any feedback you provide to us. Content also includes the files and links you upload to the Services. We also may collect clickstream data about how you interact with and use features in the Services.
Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, interact with one of our representatives through webchat, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment Information: We collect certain payment and billing information when you register for certain paid Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration, if different from the beneficiary of the Service. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.
Information we collect automatically when you use the Services We may collect information about you when you use our Services, including browsing our websites, and attending our events, and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; the type, size and filenames of attachments you upload to the Services; frequently used search terms; the origin of your visit; and, how you interact with others on the Services. We also may collect information about the teams and people you work with and how you work with them, like who you collaborate with and communicate with most frequently.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Information we receive from other sources We receive information about you from other Service users, from third-party services, from our related companies, from our business and channel partners, and from our Practitioner partners.
Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned in a customer service request submitted by someone else. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator/executor/employer may provide your contact information when they designate you as the billing or technical contact on your purchase (this is especially the case if the purchase is made by a company).
TRL Partners: We work with a global network of partners who provide consulting, implementation, training and other services around our products. Some of these partners also help us to market and promote our products, generate leads for us, and resell our products. We receive information from these partners, such as billing information, billing and technical contact information, company name, what TRL products you have purchased or may be interested in, evaluation information you have provided, what events you have attended, what language(s) you speak/prefer, and what city and country you are in.
Other Partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services and online advertisements.
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. Our Services also include tailored features that personalize your experience, enhance your productivity, and improve your ability to collaborate effectively with others by automatically analyzing activities to provide search results, activity feeds, notifications, connections and recommendations that are most relevant for you and/or your organization. For example, we may use your stated job title and activity to return search results we think are relevant to your job function. As another example, should you choose to become a Practitioner, we may use information about you to connect you with potential customers for your practice, or with other practitioners in your region, or who share similar interests. We may use your email domain to infer your affiliation with a particular organization or industry to personalize the content and experience you receive on our websites. Where you use multiple Services, we combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one Service while searching from another or to present relevant product information as you travel across our websites.
For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. We automatically analyze and aggregate frequently used search terms to improve the accuracy and relevance of suggested topics that auto-populate when you use the search feature. In some cases, we apply these learnings across our Services to improve and develop similar features or to better integrate the services you use. We also test and analyze certain new features with some users before rolling the feature out to all users.
To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We send you email notifications when you or others interact with you on the Services, for example, when you are @mentioned on a page or ticket or when a comment is directed to you. We also provide tailored communications based on your activity and interactions with us. For example, certain actions you take in the Services may automatically trigger a feature or third-party app suggestion (for example, the suggestion that you can add an event to your google/email calendar) within the Services that would make that task easier. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.
To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying TRL ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under “Opt-out of communications.”
Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
We build communities everywhere we go, create educational content and educational experiences, and hope to build more tools and avenues for collaboration in the future. We want all of these interactions to be productive for you, and to add value to your personal and professional life. This means sharing information through the Services we offer, and at times with certain third parties where they benefit our goals to offer you value. We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not, and have never been, in the business of selling information about you to advertisers or other third parties.
Sharing with other Service users When you use the Services, it is possible to share certain information about you with other Service users.
For collaboration: You can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content based on settings you select. Some of the collaboration features of the Services display some or all of your profile information to other Service users when you share or interact with specific content. For example, when you comment on a post in a closed group for Practitioners, or in a closed course for enrolled students, we may display your profile picture and name next to your comments so that other users with access to the page or issue understand who made the comment. When you send a direct message to another user, the recipient can view any information in your profile card that you have chosen to reveal. Similarly, when you publish a blog post or testimonial submission, your name may be displayed as the author of that page, and Service users with permission to view the page can view your profile information as well. Please be aware that some aspects of the Services can be made publicly available, meaning any content posted, including information about you, can be publicly viewed and indexed by and returned in search results of search engines. You can confirm whether certain Service properties are publicly visible from within the Services, and choose to submit or not submit based on your desire to have the content visible.
Managed accounts and administrators/executors/employers: If you register or access the Services using an email address with a domain that is owned by your employer or organization, and such organization wishes to establish an account or site, certain information about you including your name, profile picture, contact info, content and past use of your account may become accessible to that organization’s administrator and other Service users sharing the same domain. If you are an administrator for a particular site or group of users within the Services, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests. Certifications and Practitioner status may not be transferred to any other individual, regardless of the email address or domain used to engage in our Services, or pay for our Services; individuals always retain the right the history of their participation milestones with TRL (example: that certain courses were finished, or events attended, or certifications completed/held), retain the right to proof of their participation, and retain the right to Practitioner status and Certification status.
Community Forums: Our websites may offer publicly or privately accessible blogs, forums, issue trackers, and wikis. You should be aware that any information you provide on these websites – including profile information associated with the account you use to post the information – may be read, collected, and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
Sharing with third parties We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
TRL Partners: We work with third parties who provide consulting, sales, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.
Social Media Widgets: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect TRL, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
TRL companies: We share information we have about you with other TRL corporate affiliates in order to operate and improve products and services and to offer other TRL affiliated services to you. This includes companies that own or operate the services listed here.
Information storage and security We use hosting service providers is in the United States and Canada to host the information we collect, but our hosting providers’ Global CDNs (content delivery networks) serve content from 40+ POPs (points of presence) distributed around the world. All of our providers use use technical measures to secure your data. For more information on where we store your information, please see our Cloud hosting infrastructure page. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. If you use our Services, responsibility for securing storage and access to the information you put into the Services rests with you and not TRL. We strongly recommend that every user access our services through browsers and systems equipped with SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage points used.
How long we keep information How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: For paid Services, we retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services, or until such time as you tell us to disable your account. For nonpaid, or complementary, Services, we retain your account information for as long as we deem that there is a legitimate interest in your account remaining active, or until such time as you tell us to disable your account. Even when an account is disabled or deleted, we also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display content you provided.
Managed accounts: If the Services are made available to you through an organization (examples: your employer, an association), we retain your information as long as required by the administrator/executor/employer of your account, email address, or affiliated domain.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your TRL account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
Your Choices: You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an employer, you may need to contact your employer to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance. Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your employer are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Access and update your information: Our Services and related documentation give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account and search for content containing information about you using key word searches in the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Deactivate your account: If you no longer wish to use our Services, you or your administrator/executor/employer may be able to deactivate your Services account. If you can deactivate your own account, that setting is available to you in your account settings. Otherwise, please contact your administrator/executor/employer. If you are an administrator/executor/employer and are unable to deactivate an account through your administrator settings, please contact TRL support. Please be aware that deactivating your account does not necessary delete all of your information; your information remains visible to other Service users based on your past participation within the Services. For more information on how to delete your information, see below.
Delete your information: Our Services and related documentation give you the ability to delete certain information about you from within the Service. For example, you can remove content that contains information about you using the key word search and editing tools associated with that content, and you can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator/executor/employer does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator/executor/employer to do so.
Opt out of communications: You may opt out of receiving promotional or marketing communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional or marketing email list(s) or registration database. Even after you opt out from receiving promotional or marketing messages from us, you will continue to receive transactional messages from us regarding our Services, especially if you have chosen to remain subscribed to or have chosen to attend those Services. You can opt out of some notification messages in your account settings. You may be able to opt out of receiving personalized advertisements from other companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info, http://optout.networkadvertising.org and http://www.youronlinechoices.eu.
Turn off Cookie Controls: Relevant browser-based cookie controls are described in our Cookies & Tracking Notice.
Send “Do Not Track” Signals: Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces within our systems that are under your sole control.
International transfers of information we collect We collect information globally and primarily store that information in the United States and Canada. We transfer, process and store your information outside of your country of residence, to wherever we, or our third-party service providers operate, for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
International transfers within the TRL Companies: To facilitate our global operations, we transfer information to either the United States or Canada, and allow access to that information from countries in which the TRL owned or operated companies have operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our customers and users are based. When we share information about you within and among TRL corporate affiliates, we make use of standard contractual data protection clauses. For more information contact us as provided below.
Notice to End Users Some of our products are intended for use by organizations. Where the Services are made available to you through an organization (examples: your employer, or your association), that organization is the Administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy. If you registered with us through an Administrator/Employer, please be advised that these parties are able to:
In some cases, Administrators can also:
Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens. If you do not want an administrator to be able to assert control over your account or use of the Services, use your personal email address to register for or access the Services. If an administrator has not already asserted control over your account or access to the Services, you can update the email address associated with your account through your account settings in your profile. Once an administrator asserts control over your account or use of the Services, you will no longer be able to change the email address associated with your account without administrator approval. Please contact your organization or refer to your administrator’s organizational policies for more information.
Your information is controlled by The Reconnection, LLC. If you have questions or concerns about how your information is handled, please direct your inquiry to The Reconnection, LLC:
The Reconnection, LLC
P.O. Box 3600
Los Angeles, CA, 90078-3600
United States of America
Telephone: +1 323-960-0012