Privacy Policy

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Last updated: April 2018 
 
Cybrary is committed to respecting your privacy and complying with applicable laws and regulations to ensure that the personal information you give us is kept appropriately secure and processed fairly and lawfully.
 
Cybrary, Inc. is a company incorporated in Maryland with DUNS number 079758241.
 
Your personal information will be held and managed by Cybrary, Inc. By visiting and using Cybrary’s website or mobile site (www.Cybrary.it) (the “SITE“) or any Cybrary application (“APPLICATION“) that we make available from time to time or for the purchase or sampling of products or for interacting with our content and/or services or by contacting our Customer Services Team, you acknowledge that you have read this Privacy Policy. You must be at least 13 years old to use the Site and Applications. If you are under 13 or a minor in your country or state of residence, please ask your parent or legal guardian to provide their information for you.
 
This Privacy Policy covers all personal information about you that we collect, use and otherwise process in connection with your relationship with Cybrary as a customer or potential customer. Cybrary will collect and use your personal information as described in this Privacy Policy and as permitted by applicable laws, including in circumstances where: (i) it is necessary to provide or fulfil a service requested by or for you; (ii) you have given us your express consent; or (iii) it is necessary for one or more of the following legitimate interests pursued by Cybrary:
·         To analyze, profile and monitor customer patterns and better understand the interests and preferences of our key customer audiences so we can consistently improve our products and services.
·         To offer an enhanced customer experience and service, including by ensuring we personalize the Site and Application and (if applicable) Cybrary updates relating to products, services and events to make them more relevant to our customers’ specific preferences.
·         To ensure the proper functioning and security of our services, Site and Application, for example by preventing fraudulent transactions.
·         To analyze Cybrary promotions or events for internal reporting purposes and to ensure adequate and appropriate product and resources.
·         To ensure we continue to comply with applicable laws, for example in maintaining the accuracy of our records.
 
 
Personal Information Collection
 
When you register for an account with us, place an order, interact with our digital content on your computer or mobile device, request service or send us an inquiry, we will collect certain information from you. We will indicate whether this collection involves personal information and, if it does, whether providing your personal information is voluntary or mandatory for the service. Please be aware that where collection is mandatory, we may not be able to provide the relevant products or services to you if you do not provide that information to us.  Please select from the different sections of this Privacy Policy to learn more about what personal information we collect and how we use it.


ACCOUNT MANAGEMENT AND CUSTOMER PROFILE INFORMATION 
 
We may collect the following information:  your name, postal address, phone numbers, e-mail address(es), company, and other information. You acknowledge that we may also obtain information about you as a result of authentication or identity checks (for example in connection with our standard fraud checks when you make a purchase on our Site or Application). We use this information to identify you as a customer, to process your order, to deliver services, to process payments, to update our records and to generally manage your account with us under our terms with you.  Providing us with personal information is voluntary but we may not be able to process your order and send you the required order acknowledgement and confirmation e-mails if you do not provide us with certain requested information.
 
Where permitted under applicable laws or with your consent (if so required by applicable laws), we may use information about how you use our Site, Application and any in-store services to personalize our communications to you, tailor the content appearing on our Site and Application and how these appear to you so as to make the Site, our Application and our services and communications more relevant to you and to enable your use of any interactive features of our services.
 
If you have a customer account, you acknowledge that we may also collect information about the products you browse online or purchase, where you purchased the products from and other information related to your purchases or which is otherwise relevant to your customer relationship with Cybrary. We may also ask for your birthday and gender or you may provide us with information about yourself, lifestyle interests on our Site or Application or when using interactive content in Cybrary surveys or events.  We use your customer account and profile information to offer you an enhanced service according to your preferences.
 
We may also use your personal information to contact you in relation to service-related matters, including, on occasion, to request and respond to feedback on your experience on our Site and/or Application, and to assist you in relation to prospective purchases on our Site and/or Application, where permitted to do so in accordance with applicable laws or if we have your consent to do so if required by applicable laws.
 
We may also use your personal information for our internal marketing analysis and demographic studies, together with non-personal information, to analyze, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers. This means that we can offer more personalized and integrated shopping and interactive experiences to our customers across our Site and Applications.
 
We may supplement information we collect about you with marketing and demographic information which we receive from affiliated third-party companies, in addition to other information which is available in the public domain or which we are otherwise lawfully permitted to be provided with, in order to ensure the accuracy of our records, better understand the interests and preferences of our key customer audiences and improve our service to our customers. If you don’t want us to use your personal information in this way, then you can contact us at any time to ask us to stop (see “Contacting Cybrary” below).
 

DEVICE AND LOCATION INFORMATION
We collect information about the device you are using to connect to the services on our Site, Application or any interactive content we may provide. This includes the type of device you use, your internet browser, your location based on the unique identifier for your device such as an Internet Protocol address or a code for an Application running on your device.
 
We use this information to ensure the proper functioning and security of our Site and Application, to optimize our services to you and to better understand how our content and services are used and their effectiveness.
 
COOKIES
Cookies are small pieces of information which are issued to your device when you visit a website or some applications and which store and sometimes track information about your use of the website or application. When you enter our Site or Application our web server sends a cookie to your device which allows us to recognize your device. By associating the identification numbers in the cookies with other customer information that you provide when for example you log-in to the Site or Application, then we know that the cookie information relates to you. 
 
We use cookies, local storage and other similar technologies which may place codes on or access information from and/or about your device to elevate your user experience and the quality of our Site, Application and service. This includes keeping track of what you have in your shopping bag, remembering you when you return to our Site, identifying how you navigate around the internet, including where you click, and which website you arrived from. We may also use cookies and other technologies to understand how parts of our Site are used. 
 
Most web browsers are initially set up to accept cookies.  You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of our Site or Application may not work if you delete or disable cookies. 
 
We use Google Analytics on our Site to collect usage data, to analyze how users use the Site, and to provide advertisements to you on other websites.  For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/
 
We inform you where relevant of our use of cookies and other device identifiers on arriving at our Site, Application or, if required by applicable laws. You acknowledge and agree that by continuing to use our Site or Application or services without managing your cookie and device choices and preferences, that you consent to our cookie and device identifier settings and agree that you understand our Cookies Policy (see below). Please be aware that restricting certain cookies or other device identifiers will impact on your user experience and may prevent you from using part of our Site or Application.
 
Please see the Cookies Policy (see below) for more information about cookies and other technologies which are used on our Site and Application, including information on how you can manage your cookie choices and preferences. 


COMMUNICATIONS WITH CUSTOMER SUCCESS TEAM
If you contact our Customer Service Team by live chat from our Site or Application, by email or phone, our Customer Service consultants may collect your personal information and use this information to identify you as a customer, help with your query, process your order, deliver products and services, process payments, update our records and to generally manage your account with us under our terms with you.

INFORMATION ABOUT YOUR FRIENDS
We sometimes run promotions (for example on social media platforms) where you can tell us about a friend or someone else who you have a personal relationship with and two-way communications based on your shared interests, experiences, opinions and any other relevant factors (a “FRIEND”) who may be interested in our products, services, Site or Application. You may only provide us with information about your Friend with their permission. If your Friend gives you their permission to provide us with their details, then we will only use their information for that reason and not to send them any other unrelated offers. We may also mention that it was you who shared their details with us in the message we send to them.

CHILDREN’S PRIVACY
You must be at least 13 years old to use our Site and Applications.  If you are under 13 or a minor in your country or state of residence, your parent or legal guardian must provide their information and agree to this Privacy Policy on your behalf and you may only access and use our Site and Applications with permission from your parent or legal guardian. We do not knowingly collect personal information from children under the age of 13 or equivalent minimum age depending on jurisdiction.  If we become aware that we have inadvertently received personal information from a child under the age of 13 or equivalent minimum age depending on jurisdiction, we will delete such information from our records.

ADVERTISING AND ONLINE TRACKING
We may allow third-party companies to serve ads and collect certain anonymous information when you visit our Site.  These companies may use non-personally identifiable information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you.  These companies typically use a cookie to collect this information.  Our systems do not recognize browser “Do Not Track” signals, but several of our Service Partners who utilize these cookies on our Site enable you to opt out of targeted advertising practices.  To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/.  We also provide you with additional tools to opt out of marketing from us (see “Unsubscribe from Cybrary updates” below). 

NOTICE TO CALIFORNIA RESIDENTS/YOUR CALIFORNIA PRIVACY RIGHTS
To opt out of sharing your personal information with third parties for their direct marketing purposes, please e-mail us at info@cybrary.it and clearly state your request, including your name, mailing address, e-mail address and phone number.  Please see “Unsubscribe from Cybrary updates” for additional information. 
 
Cybrary Updates and Unsubscribing
 
We can only send you Cybrary updates about our products, services and events with your consent. If you have provided your consent, you can withdraw it at any time (see “Unsubscribe from Cybrary updates” below).
 
If you have consented, we will send you Cybrary updates through the preferred communication via email.   We may also obtain personal information where you “like” us, create posts or otherwise interact with our pages on social media platforms and may in response, use this information to communicate with you or provide relevant content via those social media platforms about our products, events and promotions where permitted to do so in accordance with applicable laws. Please refer to the privacy policies of the social media platforms for information about how they collect and use your personal information.


UNSUBSCRIBE FROM CYBRARY UPDATES
If you have registered to receive Cybrary updates relating to our products, services and events, and you no longer wish to receive these, you can request that we amend your preferences. You can do that as indicated in the particular communication, e.g. by using the unsubscribe link which is included on all email updates. Cybrary will stop sending updates in respect of which you withdraw your consent within a reasonable period and in any event within 28 days of receiving your request, in order to allow sufficient time for the change to be administered.  
 
FINANCIAL INSTITUTIONS AND PAYMENT PROCESSING PARTNERS 
Payments using our Site or Application are made through our payment solutions providers. You will be providing credit or debit card information direct to our providers who process payment details further.



LEGAL DISCLOSURES
In certain circumstances (where required or permitted under applicable laws or with your consent (if so required by applicable laws), we may disclose personal information relating to you to third parties in other jurisdictions in order to conform to any requirements of law, to comply with any legal or regulatory process, for the purposes of obtaining legal advice, for the purposes of credit risk reduction, to prevent and detect fraud and/or to protect and defend the rights and property of Cybrary and other members of the Cybrary group. At all times where we disclose your information for the purposes of credit risk reduction and fraud prevention we will take all steps reasonably necessary to help ensure that it remains secure.



BUSINESS OR PROCESS CHANGE PARTNERS
In the event that we or a part of our business undergo re-organization or are sold or licensed to a third party, any personal information we hold about you may be transferred to that re-organized entity, licensee or third party.



OVERSEAS TRANSFERS OF DATA
The personal information that you provide through the Site and/or Applications is processed and is stored on servers in the United States of America.

We may transfer information that we collect from you to other companies in the Cybrary group, joint ventures, franchisees, licensees, other companies who promote and sell Cybrary products and services and to selected service providers who perform functions on our behalf (each as described above), based in countries outside of your country of residence and this information may be stored and processed in such countries.

Personal information stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in that jurisdiction according to its laws. Whether the personal information you provide to us is processed by us or our Affiliated Companies or services providers within the U.K. or EEA or outside of it, we will take steps to ensure that your personal information will be afforded the level of protection required of us under and in accordance with this Privacy Policy and applicable data protection laws and in accordance with current legally recognized data transfer mechanisms, such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient – https://www.privacyshield.gov/welcome) or appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm)

Personal information stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in that jurisdiction according to its laws. Whether the personal information you provide to us is processed by us or our Affiliated Companies or services providers within the U.K. or EEA or outside of it, we will take steps to ensure that your personal information will be afforded the level of protection required of us under and in accordance with this Privacy Policy and applicable data protection laws and in accordance with current legally recognized data transfer mechanisms, such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient – https://www.privacyshield.gov/welcome) or appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm)


 
Your Rights
 
You may have the right under applicable laws to ask for details of the personal information we hold about you, to amend, limit or delete your personal information, or ask for a copy of the personal information you gave us. You can also withdraw any consent you give to us at any time and object to us using your personal information for Cybrary’s legitimate purposes.
 
If you would like to exercise any of these rights in relation to the personal information we hold about you or wish to change your preferences at any time, please contact us at info@cybrary.it . Please note that we may require you to verify your identity before allowing you to access your personal information.
 
If you have an online customer account, you can also access, amend or update your information by logging into the Site or Application and amending your details as appropriate. 



EU-US and Swiss-US Privacy Shield
Cybrary, Inc. participates in the EU-US and Swiss-US Privacy Shield Framework regarding the collection, use, and retention of personal information from European Union member countries and Switzerland, respectively. We have certified with the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield Principles, visit here.
If you have any inquiries or complaints about our handling of your personal data under Privacy Shield, or about our privacy practices generally, please contact us at: info@Cybrary.it We will respond to your inquiry promptly. If we are unable to satisfactorily resolve any complaint relating to the Privacy Shield, or if we fail to acknowledge your complaint in a timely fashion, you can submit your complaint to TRUSTe, which provides an independent third-party dispute resolution service based in the United States. TRUSTe has committed to respond to complaints and to provide appropriate recourse at no cost to you. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. If neither Cybrary nor TRUSTe resolves your complaint, you may pursue binding arbitration through the Privacy Shield Panel. To learn more about the Privacy Shield Panel, visit here.

We sometimes provide personal information to third parties to perform services on our behalf. If we transfer personal information received under the Privacy Shield to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.
You can review our Privacy Shield registration here. Cybrary is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 
Retention and Deletion of Personal Information
 
We will only keep your information as long as you remain an active customer and for 5 years afterwards or otherwise as required for our business operations or by applicable laws. We may need to retain certain personal information even once a customer account has been closed or deleted to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes. We may also retain a record of any stated objection by you to receiving Cybrary updates for the purpose of ensuring we can continue to respect your wishes and not contact you further. If you request for your information to be deleted, your personal information will be deleted or destroyed in a manner that cannot be restored or reproduced.
 
 
Security and Third-Party Links
 
We use strict procedures and security features to try to prevent unauthorized access wherever possible. Personal information may be accessed by persons within our organization, or our third-party service partners, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by the applicable law.
 
Personal information provided to Cybrary via the Site, Application and online credit card transactions are transmitted through a secure server using Secure Socket Layering (SSL), encryption technology. When the letters “http” in the URL change to “https,” the “s” indicates you are in a secure area employing SSL; also, your browser may give you a pop-up message that you are about to enter a secure area or display a padlock image. The Site and the Application use this encryption technology to protect your information during data transport. SSL encrypts ordering information such as your name, address and credit card number. Our customer success also operates over a private, secure network. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting credit card information.
 
The Site and/or Application may from time to time contain links to other websites not controlled by us. We do not accept responsibility or liability for the privacypractices, data collected or the content of such other websites. The operators of these linked websites are not under a duty to abide by this Privacy Policy. If there are terms and conditions, other privacy statements or policies appearing on those websites, you should also review them carefully as your use of those sites may be subject to them.
 
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The amended Privacy Policy will be posted on the Site or Application. Please check this page regularly for changes to this Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you before they take effect either through the Site or Application or by sending you a notification.  Any such material changes will only apply to personal information collected after the revised Privacy Policy took effect.
 
Cookie Policy
 
Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of the site. We use cookies to elevate your user experience and the quality of our site and service. When you enter our site our web server sends a cookie to your computer which allows us to recognize your computer. By associating the identification numbers in the cookies with other customer information when for example you log-in to the site, then we know that the cookie information relates to you.
 
Local storage is technology which allows a website or an app to store and retrieve data on your mobile phone or other device. We use local storage to enable certain features, including to store certain parts of our site on your device so that those pages load more quickly when you next visit them. You can control the use of local storage using your browser settings.
 
By proceeding beyond this page, you consent to our cookie and local storage settings and agree that you understand this Cookies Policy which explains how you can manage your cookie and local storage choices and preferences. Please be aware that restricting cookies and/or local storage will impact on your user experience and may prevent you from using part of our website.
 
Using Cookies
·         Collect information about how you use our site, so that we can improve the quality of our site and service. This information is used by us to:
·         Provide statistics on how our site is used;
·         See how effective our promotions and site are by identifying where you click and which website you arrived from;
·         Provide feedback to our selected third-party partners that one of our visitors also visited their website (including details of any products you bought); and
·         Help us improve the site by measuring any errors which occur during your browsing experience.
·         Provide you with improved site functionality by allowing access to additional services such as our ‘click to chat’ service or to remember you if you have visited us before and which preferences you have applied so that we can enhance your future visits to our site. These cookies may share information with partners to provide services on our site. The information shared is only to be used to provide the service, product or function and not for any other purpose.
·         Offer you a customized browsing experience by providing you with interest-based services both on this site and on some other websites too. Some of these customized browsing experiences may be linked to services provided by third parties which provide these services for recognizing that you have visited our site. This information is used to inform you of Cybrary products and services which may be of interest to you. These cookies may also link to social networks such as Facebook or provide advertising agencies with information on your visit so that they can present you with adverts for Cybrary products and services which may be of interest to you.
 
Some of the cookies used by our site are served by us, and some are served by third parties who are delivering services on our behalf.
 
We have made it very easy for you to understand what cookies we store, and why and provided you with control over which cookies and/or local storage you choose to allow.
 
Please note however, that by blocking or deleting cookies and/or local storage used on our site you may not be able to take full advantage of our site if you do so.
 
Our Privacy Policy (see above) can provide you with further details about how we use any personal information you give us, although not all information captured by using cookies will identify you.
 
We are continually striving to develop improved ways of managing your cookie preferences. As new technologies and solutions emerge, this cookies policy may be updated to reflect any such advances in technology and preference management tools.

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