Privacy

Privacy Policy

Master Privacy Policy and Express Consent

1. Preamble

This Master Privacy Policy (“Privacy Policy”) explains the collection, use, processing, transferring and disclosure of “personal information” by Groman Consulting Group Inc (“GCG”), an Illinois corporation, and also contains an Express Consent that applies to those who use our Websites and Services (as defined below).

Unless otherwise noted on a particular website or service hosted by GCG, this Privacy Policy applies to your use of all websites that GCG operates. These include http://gromancg.com and https://learning.gromancg.com, together with all other subdomains thereof, (collectively, the “Websites”). This Privacy Policy also applies to all products, information, and services provided through the Websites, including without limitation the learning platform and membership (together with the Websites, the “Services”).

This Privacy Policy also explains our commitment to you with respect to our use, processing, transfer and disclosure of non personal browsing and site usage data that GCG collects as the provider of the Services. “Non personal browsing and site usage data” refers to information that GCG collects indirectly and automatically about your activities while visiting the Websites and using the Services through tools such as Google Analytics. The type of information that we collect focuses on general information such as general location such as country or city where you are located (not intentionally fine-grained location information), pages visited, heat-map of visitors’ activity on the site, information about the browser you are using, etc. In addition, whenever you use the Services, our servers (which, again, may be hosted by a third party service provider) keep a plain text log of the websites you visit and when you visit them. GCG does not deliberately track people over the Internet. See section 11, below for more information about this.

As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number, or email address or information from which a person could deduce your identity.

By accessing or using any of the Services, you are accepting and agreeing to the practices described in this Privacy Policy.

2. Our Principles

GCG is committed to handling responsibly the personal information and data we collect and process about you through our Services, whether personal information or non personal browsing and site usage data. We have designed our Privacy Policy consistent with the following principles (the “Principles”):

  • Privacy policies including provisions regarding data collection, processing and use, should be human readable, comprehensive, and easy to locate;
  • Only the minimum amount of personal information reasonably necessary to provide you with services should be processed, collected and maintained, and only for so long as reasonably needed or required, consistent with the principles of proportionality; and
  • Personal information you provide through our Services, or that we gather as a result of your use of our Services, should not be used for marketing or advertising purposes, nor should it be provided voluntarily (without your permission) to anyone else unless required.

3. Personal Information GCG Collects

We may collect and process personal information through our Services, including without limitation:

  • in connection with your selection of one of our Services;
  • when you provide us with your personal information such as by sending an email to us or signing up to receive updates from GCG;
  • when you subscribe to one of our email discussion lists;
  • when you create a membership account;
  • when you purchase a course through the GCG Learning platform;
  • when you provide personal information in connection with your participation in any of the forums we make available through our Services.

Specifically, the following personal information at a minimum will be collected, processed and transferred as set forth below when you apply for membership on the GCG Learning Platform:

  • Name;
  • Email address;
  • Brief bio (including links and references);
  • Country in which you are located and/or with which you have voluntarily chosen to be associated;
  • URLs and links to social media;
  • A personal photo for your profile (if that feature is enabled and you voluntarily supply a photo);
  • Any other information that you elect to provide or that GCG may request.

Some of this personal information (along with your new user ID) will be used to create your GCG member profile. Some of that information will be public (user ID, name and photo (if the feature is enabled and you have voluntarily supplied it), and some of that information will only be accessible by other GCG members (email address, country in which you are located and/or with which you have voluntarily chosen to be associated, URLs and social media, and similar)).

4. What GCG Does with Personal Information

Emails and Newsletters . We use the personal information you provide to us when you send us emails or sign up to receive our newsletter in order to respond to your request – for example, to reply to your email or to send you communications about GCG news and campaigns.

When you subscribe to updates from us, your email address is sent to and stored in a Customer Relationship Management (CRM) database (such as MailChimp) hosted on servers that can only be accessed by GCG staff and contractors. GCG may change CRM system(s) from time to time. When you subscribe to one of our email discussion lists, your name and email address is sent to and stored by (1) GCG, and/or (2) another service with which GCG has engaged to provide email support (such as a CRM system as mentioned above). Personal information submitted as part of our email discussion lists is used for the purpose of managing the discussion lists. Your name and email address typically will be visible to other list participants when you correspond on the list and to the general public in the discussion archives. All emails sent to the discussions lists are publicly archived.

7. Participating in the GCG Services

Registered Users . When you register to obtain a user account on any of the Services (any such person, a “Registered User”), including but not limited to a GCG Service, you may be asked to provide personal information to create your account and establish a password and profile. We generally encourage you to use an alias or nickname if you are not comfortable providing your legal name. The name or nickname you provide in connection with your account may be used to attribute you in connection with any content you submit to any Service. We also use that personal information to establish and maintain your account, to provide you with the features we provide Registered Users, and to email you regarding changes to this policy or other applicable policies. If you sign up to receive updates from GCG when you create your account, we will use your personal information to send you communications about GCG news and campaigns.

Any other personal information that we may collect which is not described specifically in this Privacy Policy will only be collected, processed, transferred and used in accordance with the Principles and as stated herein.

8. Disclosures of Personal Information

In general, it is not GCG’s practice to disclose personal information to third parties other than as made available on the Services. Except as otherwise set forth herein or for providing you with attribution using your GCG Service name or nickname (as you have elected), we may share your personal information in the following instances:

  1. First, GCG may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Services, to organize and run an event you signed up to attend, or to otherwise run any GCG program or activity in which you have chosen to participate.
  2. Second, we may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Privacy Policy; (c) enforce Code of Conduct and policies contained and incorporated therein, (d) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (e) address legitimate interests pursued by GCG or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child) and ensure our compliance with applicable laws.

For the purposes listed in section 3 above, GCG may transfer your personal information to GCG affiliates and third parties that provide products or services to GCG. The majority of consultants that GCG is using as of the effective date of this Privacy Policy were located in the United States and in Canada, but this may change from time to time.

When personal information is directly transferred to a third party provider located in a country including those listed above, that may not provide a level of protection equivalent to the laws in your jurisdiction, GCG will exercise appropriate due diligence in the selection of such recipients, and require that these recipients maintain adequate technical and organizational security measures to safeguard the personal information and process the personal information only as instructed by GCG and for no other purposes. See also section 20 below.

9. Security of Personal Information Collected via the Services

GCG has implemented reasonable physical, technical, and organizational security measures for personal information that GCG processes, transfers, stores and controls against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, in compliance with applicable law. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. If any data breach occurs, we will post a reasonably prominent notice to the Websites and comply with all other applicable data privacy requirements including, when required, personal notice to you if you have provided and we have maintained an email address for you.

10. Information from Cookies and Similar Technologies

We and our service providers (for example, Google Analytics as described in section 1 above) may collect information using cookies or similar technologies for the purposes described above and below. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device.  Cookies may enable us to personalize your experience on the Services, maintain a persistent session, passively collect demographic information about your computer, and monitor advertisements and other activities.  The Websites may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).

11. Non Personal Browsing and Site Usage Information We Process and Collect

When you use the Services, our servers (which may be hosted by a third party service provider) may process and collect information indirectly and automatically (through, for example, the use of your “IP address”) about your activities while visiting the Websites and using our Services, and information about the country you are located in and the browser you are using. In addition, we use website and application analytics services provided by third parties that use cookies and other similar technologies to collect information about the use of the Websites and Services, and to report trends, without identifying individual visitors (this is all “non personal browsing and site usage information” for purposes of this Privacy Policy and as described in section 1, above). The third parties that provide us with these services may also collect information about your use of third-party websites. You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. Whenever you use your GCG website account, our servers (which, again, may be hosted by a third party service provider) keep a log of the websites you visit and when you visit them. We may share the non personal browsing information we collect with our third party service providers in connection with the services they provide.

12. No Linking

We do not intentionally link browsing information or information from our GCG Services server logs to the personal information you submit to us. We use this information for internal purposes only, such as to help understand how the Services are being used, to improve our Services, and for systems administration purposes. GCG may use a third party analytics provider (for example, Google Analytics as discussed in section 1 above) to help us collect and analyze non personal browsing and site usage information through operation of our Services for those same purposes.

In connection with your use of the Services, you may tag content, create lists of favorite content, and do other things to personalize your experience. You should not, however, tag other persons or post photographs or other images or likenesses without that other person’s express consent. This information will be retained by GCG in connection with the relevant GCG Service.

13. No Selling or Sharing

Except in the unique situations identified in this Privacy Policy, GCG does not sell or otherwise voluntarily provide the non personal browsing information we collect and process about you or your website usage to third parties.

14. No Access; More about GCG Login Services

As a provider of GCG Services, GCG could access your web-based account tied to such services, and could log in on behalf of any of Registered Users to any of the accounts they have accessed using the GCG Services. GCG will never use this technical login ability for any purpose except as required by law.

15. Data Retention

GCG generally discards non personal browsing information from our GCG Services once we have used the information for the limited purposes noted above under “No Linking” and described elsewhere in this Privacy Policy. Nevertheless, we may, but are not obligated to, retain certain data in connection with routine information technology backups and for archival purposes.

16. Notice

Any other non-personal information that we collect which is not described specifically in this Privacy Policy will only be collected, processed, transferred and used in accordance with the Principles.

17. Reorganization or Spin-Offs

GCG may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin-off, or similar transaction. Upon such transfer, the acquirer’s privacy policy will apply. In such event, GCG will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer’s privacy policy complies with the Principles and with all applicable laws.

18. Children

The Services are not directed at children under the age of 13. Consistent with the U.S. federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personal information from anyone under the age of 13 without requiring parental consent.

19. Third-Party Sites

The Services may include links to other websites. You should consult the respective privacy policies of these third-party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.

20. Special Note to International Users

If you are accessing or using the Services in regions with laws governing data collection, processing, transfer and use, please note that we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. The Services are hosted in the United States and the United Kingdom. Please note that your personal information may be located on servers in the United States and/or the United Kingdom. By providing your personal information and by checking all required boxes when you apply for membership in the GCG or otherwise access and use our Services or Websites, you expressly consent to the use of your personal information for the uses identified above in accordance with the Privacy Policy.

21. Accuracy of Personal Information Collected

GCG intends to keep personal information accurate and up-to-date. We also retain personal information no longer than is necessary to carry out the purposes described in section 3 above, or as required by law. If changes need to be made to your personal information, please notify us (as identified below, see the “Questions” section) right away. If you inform us of changes or we otherwise become aware of any factual inaccuracies in personal information, we will promptly make changes as appropriate. You also have the option to update some of your personal information yourself via your GCG account or profile if you have one.

22. Access to Personal Information

Along with all other rights granted to you under applicable laws, you may at any time request to be informed of personal information that GCG holds. If you wish to access such personal information, you should apply in writing to GCG (as identified below, see the “Questions” section). You are generally entitled to access personal information that GCG holds and to have inaccurate data corrected or removed to the extent GCG still maintains it. In certain circumstances, you also may have the right to object for legitimate reasons to the processing or transfer of personal information.

23. Changes and Updates to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will provide you with notice of such update through (at a minimum) a reasonably prominent notice on the Websites and Services, and will revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting, using, processing and transferring the personal information we collect.

25. Questions?

If you have questions about this Privacy Policy, please contact us by email at info[at]gromancg.com.