Center for Innovative OT Solutions Privacy Policy

This privacy policy sets out how the Center for Innovative OT Solutions (CIOTS) uses and protects any information that you give CIOTS when you use this website. The privacy policy is meant to help you understand what information we collect, why we collect it, and how you can update or delete your information.

CIOTS is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this privacy statement. CIOTS may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy was last updated 29 August 2018.

OUR COMMITMENT TO INDIVIDUAL PRIVACY

CIOTS is committed to protecting the privacy and accuracy of your information. We do not share your personal information and we collect the least amount of personally identifiable information required to provide you with requested products or services. CIOTS does not request and we ask that you not send us any sensitive information (e.g., government-issued identification numbers, racial or ethnic information, political opinions, religious affiliations, health, biometrics or genetic characteristics, criminal background). If you choose not to provide requested personal information, you can still visit most CIOTS’ web pages, but you might be unable to access certain products or services that require our interaction with you.

WHAT WE COLLECT

We collect a variety of information that you provide directly to us. In general, we collect information from you through:

  • Using any of our services, including registering for a user account through our website(s)
  • Making a purchase from us, including registering for a course
  • Signing up for e-mail updates
  • Uploading or posting to public forums associated with CIOTS
  • Submitting requests or questions to us via forms or e-mail
  • Requesting customer support and technical assistance

We may collect the following information:

  • Name, address, telephone number, and e-mail address
  • Log-in credentials, if you register as a user account through our website(s)
  • Information about purchases or other transactions with us, such as your shipping address. Please note, however, that we do not collect, store, or transmit financial account information. Instead, we use a third-party payment processor, Stripe, to process our payments and QuickBooks to reconcile payments.
  • Information about your customer service or maintenance interactions with us
  • Information, such as your age, job, professional affiliation, and other personal information
  • Information you provide to us in connection with any course registration process, including, for example, educational and work experience, prerequisite knowledge, any pre-assessment you complete, your goals, and other information
  • User-generated content you upload or post to public forums through our services
  • Information from third parties about you in connection with any affiliate programs we may offer
  • Any other information you choose to directly provide to us in connection with your use of our services

Please note, we will never ask for your social security number or other government-issued identification number.

INFORMATION WE COLLECT THROUGH AUTOMATED MEANS

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Analytics Information

When you use our services, we and our service providers (which are third-party companies that work on our behalf) may use cookies and similar technologies to track, collect and aggregate certain information including, among other things, which pages of our website(s) were visited, the order in which they were visited, when they were visited, the website from which you linked to our website(s), and which hyperlinks were “clicked.” Collecting such information may involve logging the Internet Protocol (IP) address, operating system and browser software used by each user of the website. Through such information, we may be able to determine from an IP address a user’s Internet Service Provider and the general geographic location (city/state) of his or her point of connectivity.

We also may use these technologies to help us determine and identify repeat visitors, the type of content and sites to which a user of our website(s) links, the length of time each user spends at any particular area of our website(s), and the specific functionalities that users choose to use.

We use third-party web analytics services (such as those of Google Analytics) on our website(s) to collect and analyze usage information through cookies and similar tools; engage in auditing, researching, or reporting; assist with fraud prevention; and provide certain features to you. We also provide a limited amount of your information (such as your e-mail address and order history) to our marketing agency partners so that they can analyze website usage and send marketing communication on our behalf, which allows us to improve our products (e.g., courses or books) and services.

We may also use third-party eCommerce platforms (like WooCommerce) as a medium to deliver a digital shopping experience; customer relationship management software (like Infusionsoft), as a medium for communications, either through e-mail, or through messages about our products and service(s); credit card processors/gateways (like Stripe); software usage providers (like Google Analytics); financial services (like independent accountants, tax preparers, bookkeepers, and QuickBooks); independent contractors (like team members in marketing, management, software development), and CRM Add-Ons (like BitBucket).

The use of these and any such medium may be subject to the terms and conditions and privacy policy for those service providers and you should carefully review those terms and conditions. If you have questions about other third-party service provider’s collection of your information for this purpose, please contact us. For more information about our use of cookies and similar technologies, including how you can install the Google Analytics Opt-out Browser Add-on to prevent Google from using your information for analytics, or otherwise control or disable cookies, please see https://tools.google.com/dlpage/gaoptout. Your choice to opt out of Google Analytics will in no way affect your ability to receive CIOTS products or services.

Online Advertising

We may allow third party companies, including advertising companies (such as Google, Facebook, Instagram, etc.), to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. These cookies store information about the content you are browsing together with an identifier linked to your device or IP address.

These cookies also allow us and third parties to know whether you’ve seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads. For more information about online advertising and how you can control or disable these cookies, please see:

  • Cookie settings in Internet Explorer (https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies)
  • Cookie settings in Firefox (http://support.mozilla.org/en-US/kb/cookies)
  • Cookie settings in Chrome (https://support.google.com/chrome/answer/95647)
  • Cookie settings in Safari Mac (https://support.apple.com/kb/PH21411) and iOS (https://support.apple.com/en-us/HT201265)

If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links:

  • Your Online Choices (http://www.youronlinechoices.com/uk/)
  • Network Advertising Initiative (http://www.networkadvertising.org/)
  • Digital Advertising Alliance (http://www.aboutads.info/consumers)

Do Not Track Signals

Currently, we do not monitor or take any action with respect to web browser signals or other mechanisms for the expression of choice regarding collection of information about an individual over time and across third-party web sites or online services (e.g., Web browser “do not track” signals).

WHAT WE DO WITH THE INFORMATION WE GATHER

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Send you information in connection with the products or services purchased
  • Respond to your communications and requests
  • Manage and process in-person and online courses, including but not limited to tracking attendance, progress and completion; administering exams, projects, and other assessments; and monitoring performance during an assessment to confirm that you are abiding by the applicable rules or requirements
  • Provide services to you, such as data analysis services that you request in conjunction with the in-person and online courses
  • Contact you by e-mail, postal mail, or phone (including via SMS messages) regarding CIOTS products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you
  • Customize the content we provide through our products and services
  • Help us better understand your interests and needs, and improve our products and services
  • Engage in analysis, research, and reports regarding use of our products and services
  • Secure our products and services
  • Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
  • Internal record keeping

AGGREGATE / ANONYMOUS DATA

We may aggregate and/or anonymize any information collected through the website(s) so that such information can no longer be linked to you or your device (“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, statistical analyses of website(s) usage, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

PARTICIPATION IN IN-PERSON AND ONLINE COURSES

If you participate in an in-person and/or online course, you will be asked to provide us with certain information necessary to conduct the course and provide you with software and platform access. This information may include, among other things, your name and e-mail address. CIOTS, or its third-party service providers, like Talent LMS, may also collect certain information from you in conjunction with assignments, exams and other assessments related to the in-person and online courses. The use of these may be subject to the privacy policy for those service providers and you should carefully review those terms and conditions. For example, Talent LMS services are governed by the privacy policy which can be found at http://talentlms.com/privacy. For example, as part of rater calibration for a course or to process your credential of completion, CIOTS (or its third party service providers) may collect certain information from you in order to (a) verify or authenticate your identity or submissions made by you, such as a signature for a test or assignment log, a photograph or recording of you (e.g., using a webcam) or information included on a government issued or other photo identification card or document, or (b) monitor your performance during an assessment to confirm that you are abiding by the applicable rules or requirements (e.g., confirming that you are not using prohibited OTAP resources). CIOTS may also collect information from you or about your performance or accomplishments related to the course, such as scoring, grades, course evaluations, instructor evaluations and other evaluations of your performance or accomplishments.

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

CIOTS will share your information in the following ways:

  • Service Providers. We provide access to or share your information with operations and maintenance contractors, like Talent LMS, and other third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.
  • Educational Institutions and Scholarship Partners. If you are taking a course sponsored or associated with a particular Educational Partner (e.g., such as a university or scholarship/sponsored partner), we may share information about you and your performance with the university or scholarship partner, including to report on your progress in rater calibration. Information shared with our educational partners will be subject to the privacy policies and procedures of such partners.
  • Business Partners. With your consent, CIOTS may share information that can be used to directly connect you with third party business partners, such as companies that may be offering products or services or other opportunities that may be of interest to you.
  • Protection of CIOTS and Others. By using the website, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or law; (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of CIOTS, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, compliance with applicable law, and spam/malware prevention, and similar purposes.
  • Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of CIOTS’s assets are sold or transferred to a third-party, customer information (including your e-mail address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, CIOTS will comply with such restrictions.
  • Aggregate/Anonymous Information. From time to time, CIOTS may share Aggregate/Anonymous Information about use of our services, such as, but not limited to, publishing a report on usage trends or survey results, as well completion rates, success rates, and other demographic information provided to us by our clients. The sharing of such data is unrestricted.

DATA SUBJECT RIGHTS AND YOUR CHOICES

You may have certain rights with respect to your information as further described in this section.

Your Legal Rights

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “CIOTS Contact Information” section below at any time. Your local laws, such as in the European Union, may permit you to request that we:

  • Provide access to and/or a copy of certain information we hold about you
  • Prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
  • Update information which is out of date or incorrect
  • Delete certain information which we are holding about you
  • Restrict the way that we process and disclose certain of your information
  • Transfer your information to a third-party provider of services
  • Revoke your consent for the processing of your information

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation.

To the extent that you make such a request, we require certain information to help verify your request and prevent fraudulent information and removal requests. Specifically, we ask that you provide the following pieces of information:

  • Username and e-mail address associated with your user account(s)
  • Courses currently or previously enrolled in
  • Approximate date of user account registration
  • Information you want to view and/or request removed
  • Country of residence
  • A statement under penalty of perjury that all information in your request is truthful and that this is your user account or that you have the authorization to make the request on behalf of the owner of the user account

Depending on the circumstances and the information you request, we may require additional methods of verification in our discretion.

MARKETING COMMUNICATIONS

You may instruct us not to use your contact information to contact you by e-mail, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial e-mail messages, you can also opt out by following the instructions located at the bottom of such e-mails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational e-mails, such as those reflecting our relationship or transactions with you.

SOCIAL MEDIA

CIOTS does not require that users disclose user names or passwords for a user’s personal social media account, nor does CIOTS require users to access personal social media in our presence or divulge any personal social media information to us.

THIRD PARTY LINKS AND FEATURES

Our website(s) may contain links to third-party websites such as social media sites, and also contain third-party integrations (such as the Facebook “Like” button) and functionalities. If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. CIOTS is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third-parties.

JURISDICTION AND CROSS-BORDER TRANSFER

Your personally identifiable information may be stored and processed in any country, including the United States, where we have facilities in which we engage third-party service providers, and by requesting CIOTS products or services you consent to the transfer of information to countries outside of your country of residence which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personally identifiable information.

CHILDREN’S PRIVACY

CIOTS is intended for general audiences and not for children under the age of 18. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

INTERNATIONAL USERS

CIOTS stores information about visitors to our website and users on servers located in the United States. By using our services, you consent to the storage of your information inside the United States. If you are using our products and services from outside the United States and the European Union, please know the information you submit will be transferred to and stored in servers in the United States or other countries. The data protection and other laws of the United States and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our services, you acknowledge the transfer, storing, and processing of your information in and to the United States.

As described above, CIOTS also may subcontract the processing of your data to, or otherwise share your data with, service providers and others in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If we provide any information about you to any such non-European Union entities, we will take appropriate measures to ensure such companies protect your information adequately in accordance with applicable law.

HOW WE PROTECT YOUR INFORMATION

We consider the confidentiality and security of your information to be of the utmost importance. CIOTS takes a variety of technical, administrative, and physical measures to protect your information from disclosure to or access by third parties. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Please note that we do not guarantee the security of information, as no method of internet transmission or storage is completely secure. Also note that we may retain and store your information in our databases and systems even after your CIOTS account is deactivated as long as we have a legitimate purpose to do so and in accordance with applicable law.

We intend to take reasonable and appropriate steps to protect the information that you share with us and/or third-party service providers from unauthorized access or disclosure. We will contact you within 72 hours after first becoming aware of any data breach that is likely to result in a risk to your rights or freedoms. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by e-mail at info@innovativeotsolutions.com or by phone +1 970.416.8612.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

  • Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
  • If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or e-mailing us at info@innovativeotsolutions.com

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting. You will have the choice to opt out from receiving this promotional information.

CHANGING, UPDATING, OR DELETING PERSONAL INFORMATION

If you believe that any information we are holding on you is incorrect or incomplete, please write to us at the address below or notify us by e-mail at info@innovativeotsolutions.com as soon as possible. We will promptly correct any information found to be incorrect.

If you would like to request to review, correct, update, suppress, restrict, or delete personally identifiable information that you have previously provided to us, or if you would like to request to receive an electronic copy of your personally identifiable information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by e-mail at info@innovativeotsolutions.com or by phone (+1 970.416.8612; reverse charges accepted). We will respond to your request consistent with applicable law.

In your request, please make clear what personally identifiable information you would like to have changed, whether you would like to have your personally identifiable information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personally identifiable information. For your protection, we will only implement requests with respect to the personally identifiable information associated with the particular e-mail address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

Residents of the United Kingdom may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to 4223 S. Mason St., Suite A, Fort Collins, CO 80525, USA.

CHANGES TO OUR PRIVACY POLICY

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Website(s). You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use our services, you are confirming that you have read and understood the latest version of this Privacy Policy. Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

CIOTS CONTACT INFORMATION

If you have any questions, comments or complaints about this Privacy Policy, please contact us:

E-mail: info@innovativeotsolutions.com

Center for Innovative OT Solutions
Attn: Information Security Officer 4223 S Mason St Suite A
Fort Collins, CO 80525

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