This notice is intended for people who are located in the European Union (“EU”), European Economic Area (“EEA”) and Switzerland. Our processing of personal data of people who are in the EU, EEA and Switzerland are governed by the General Data Protection Regulation (the “GDPR”). The GDRP requires us to provide certain information to you about your personal data.
For purposes of this GDPR Privacy Notice:
“Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person.
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Sensitive Data” means data indicating racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sex life, or sexual orientation, or for any genetic data or biometric data.
Please note that, in certain circumstances, you may be required to provide the requested Personal Data by contract or law, and your failure to provide such Personal Data may mean we are unable to provide you with our Services.
Our legal bases for the Processing of Personal Data are: 1) consent and/or 2) any other applicable legal bases, such as our legitimate interest in engaging in commerce, offering products and services of value to users of our Services, preventing fraud, ensuring information and network security, direct marketing, processing Personal Data for internal administrative purposes, and complying with industry practices.
To the extent permitted by applicable law, your entry of any Sensitive Data on our Services is your consent to the Processing of such data as set forth in this GDPR Privacy Notice or as otherwise specified in the context of your submission of such sensitive information.
Your Additional Rights as an EU Resident
As a resident of the EU, you may have the following additional rights:
Consent: We may be required to obtain your consent for certain Processing of your Personal Data, such as Processing of Sensitive Data.
Access: You may request a copy of the Personal Data we have collected from and about you by contacting us. Please be advised that our personnel may have a limited ability to identify and access an individual user’s Personal Data if such information was submitted to us by their school, employer or another organization with whom they are affiliated. Thus, if you wish to request access, to limit use, or to limit disclosure of your Personal Data, we may first refer your request to the school, employer or other organization that submitted your Personal Data to us, and we will support them as appropriate in responding to your request.
Rectification & Erasure: You may request that we rectify or delete any of your Personal Data that is incomplete, incorrect, unnecessary or outdated.
Objection: You may object, at any time, to your Personal Data being Processed for direct marketing purposes. Restriction of Processing: You may request restriction of Processing of your Personal Data for certain reasons, such as, for example, if you consider your Personal Data collected by us to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration.Data Portability: You may request and receive the Personal Data we have collected on you in a commonly used and machine-readable form.
Right to Withdraw Consent: Where your Personal Data is Processed solely based on your consent and not for any other legitimate interest, you have the right to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for our products and services.
To exercise any of the rights listed above, please contact us as set forth below. We will process any requests in accordance with applicable law and within a reasonable period of time. We may require that you establish your identity and provide a clear and precise description of your request. Please note that in some cases, especially if you wish us to delete or cease the Processing of your Personal Data, we may no longer be able to continue to provide our Services to you.
Third Parties with Whom We May Share Data
We may use third-party providers to assist us in providing the Services to our users. Such third-party providers may perform technical operations such as database monitoring, data storage and hosting services and customer support software tools. Such third parties may access, process or store Personal Data in the course of providing these services.
To the extent permitted under applicable law, we may share information about your enrollment and participation in our Services, including your Personal Data, with your employer, governmental agencies, oversight organizations, professional organizations, accreditation organizations, educational institutions, and industry self-regulatory organizations.
We may also share information, including your Personal Data, with third parties for marketing, advertising, promotions, contests, or other similar purposes, with your consent or to the extent permitted under applicable law.
We will not sell your Personal Data.
International Data Transfers
Our Services may be provided using resources and servers located in various countries around the world, including the United States and other countries. Therefore, your Personal Data may be transferred and Processed outside the country where you use our Services, including to countries outside the EU, EEA or Switzerland, where the level of data protection may not be deemed adequate by the European Commission. To the extent permitted by applicable law, your use of our Services is your consent to the transfer of your information outside of your country or geographic region, including transfer to the United States, and to processing of your information in the United States by us or by a third party acting on our behalf.
If you wish to know more about international transfers of your Personal Data, please contact us.
Data Protection Contact
Your Data Protection Contact for the personal information you provide in connection with our Services is:
ATTN: Chief Compliance Officer/Data Privacy Officer – GDPR Inquiry
Ascend Learning, LLC
5 Wall Street, Burlington, MA 01803, USA
If you consider our Processing of your Personal Data to be inconsistent with the applicable data protection laws, you may lodge a complaint with your local supervisory Data Protection Authority responsible for data protection matters.
Please provide your identification information, a detailed description of the nature of your request, the name of or Services you use, and your country of residence.