Version Date: March, 2018
- Notice - We will not collect or transfer your Personal Information without your knowledge.
- Choice - We will provide you with mechanisms that will allow you to opt out of (i) our direct marketing campaigns; (ii) the disclosure of your Personal Information to third parties who are not acting as our agents; and (iii) the use of your Personal Information for purposes that are materially different from the purpose for which we originally collected the Personal Information.
- Security - We will take reasonable measures to protect the security of your Personal Information, and our agreements with third parties with whom we share Personal Information will require similar protections.
- Data Integrity and Purpose Limitation - You will be able to (i) view the Personal Information that we have about you; (ii) correct or modify your Personal Information if it is inaccurate or incomplete; and (iii) limit the collection of data to such data that is relevant to the products and services we provide to you or on your behalf.
- Access - We will provide you with (i) the opportunity to confirm whether we are processing your Personal Information; (ii) a way to obtain a copy of your Personal Information within a reasonable time; and (iii) the ability to correct, amend, or delete information that is inaccurate.
- Recourse, Enforcement, and Liability - We have processes for handling complaints relating to use of your Personal Information (see “Complaints and Disputes”).
- Links to External Sites
- What Personal Information We Collect and How
- How We Use Personal Information
- To Whom We Disclose Personal Information
- Cookies and Other Technologies
- How We Retain Personal Information
- How We Protect Personal Information
- Data Accuracy
- Your Rights
- Privacy Shield
- Complaints and Disputes
- Contact Us
- “Assessment” means an instrument, questionnaire, or series of tests that are completed by one or more Respondents (i) for the preparation of one or more Reports; or (ii) to provide information about a Respondent to CPP and CPP’s Customers.
- “Certified Practitioner” means an individual (i) who has successfully completed one or more of our certification programs for certain Assessments, (ii) who administers an Assessment to one or more Respondents and (iii) who interprets the Reports or other output generated by CPP to provide feedback to the Respondent(s) about the results of the Respondent’s Reports. Certified Practitioners are a subset of Practitioners.
- “Customer” means an individual, business, or other entity that purchases CPP’s Products or Services, or with which CPP has a contractual relationship to provide Products or Services.
- “Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred from the information. This includes, for example, name, email address, mailing address, telephone number, billing information, account information, and other information incidental to providing or receiving Products or Services or which you may choose to provide to CPP. It also includes other information, such as IP address, device information, or other Session Data that can reasonably be linked to a specific individual, computer, or other device.
- “Practitioner” means an individual who administers an Assessment to one or more Respondents and who interprets the Reports generated by CPP to provide feedback for the Respondent(s).
- “Products or Services” means the products or services promoted, sold, or available for sale on the Site, such as our Assessments and Reports.
- “Reports” means an analysis of the scoring and responses provided in connection with an Assessment, which a Practitioner or Customer may use to interpret a Respondent’s responses to an Assessment. Some Reports, such as those generated on www.mbtionline.com, do not require an interpretation from a Practitioner.
- “Respondent” means an individual who takes, will take, or has taken an Assessment.
- “Session Data” means, as applicable, usage information, such as IP address, unique identifier of an individual’s mobile device, the type of browser, type of operating system, referring URL, date, time and duration of a visitor’s visit, the number of visits to a Site, the pages viewed, order of pages viewed, time spent on a particular page, the number of cookies accumulated, bytes sent, bytes received, protocol version, user agent, method, URI stem, URI query, or MAC address.
- “Site” means any websites that we may develop or have developed from time-to-time and includes, without limitation: www.cpp.com, www.skillsone.com, www.cppblogcentral.com, elevate.cpp.com, www.mbticomplete.com, and www.mbtionline.com.
If you reside in a country or territory that restricts the transfer of Personal Information out of that country or territory, you agree to the transfer, storage, and processing of your Personal Information to countries that may not have data protection laws that provide the same level of protection as those that exist in your country of residence.
Children under 13 are not permitted to use the Site without their parents’ or guardians’ consent. Should a child whom we know to be under 13 send Personal Information directly to us, we will use that information only to respond directly to that child to inform him/her that we must have parental consent before receiving his/her Personal Information.
If we become aware that a child under 13 has provided us with Personal Information without the consent of the child’s parent or guardian, we will promptly remove such Personal Information from our files. If the parent or guardian of a minor becomes aware that his/her child has provided us with Personal Information without his/her consent, he/she should contact as as indicated in the “How to Contact Us” section.
If you visit the Site—If you visit the Site, we automatically collect the related Session Data. Session Data is provided to us by your browser and through our log files, which record your activities while browsing our Site, such as when you click on a link. We may record some of this data in one or several cookies that we send to your browser (see “Cookies and Other Technologies”).
If you register or create an account—If you register or create an account, we require that you provide certain Personal Information during account registration. We collect your name, contact information, and other information, and may ask you for other optional information that helps us serve you better.
If you complete an Assessment—If a Respondent completes an Assessment, we collect the Respondent’s name, email address, contact information, Assessment responses, Session Data, and other information you may choose to provide or associate with your account. In some cases, we ask questions to which the response is optional (such as demographic questions), and these questions are identified as such. You are free not to respond to these optional questions.
If you participate in a survey—If you choose to participate in one of our surveys, we may collect Personal Information such as your name, email address, and any other Personal Information that you may provide in your survey responses.
If you sign up to receive marketing communications—If you sign up to receive our marketing communications, we may collect information on the open rate of the communications, and whether a specific individual has clicked on a link contained in a particular communication.
If you are a Customer or other business contact—If you are a Customer or other business contact, or if you are an employee or agent of a Customer or business contact, we may collect your name, email address, telephone number, and contact information in the regular course of our interaction with you.
If you interact with third parties regarding our Products or Services—We may receive Personal Information about you from third parties, such as from Customers, websites where we advertise, business partners, and service providers. Some of this information pertains to a specific individual; other information can only be linked to an access point or a device.
To facilitate the use of the Site—We use Session Data to ease navigation throughout the Site, to enhance navigation, keep track of login name and password in order to avoid requesting identity information when the visitor moves from page to page, and in general to enhance the quality of our Site and the content provided on the Site.
In connection with Assessments—We use the responses to an Assessment to score the Assessment and to generate Reports and other data related to the Respondent. We sometimes combine data from multiple Respondents (for example, in Team Reports). We may also combine Respondent data with our general research data, or compare or associate Respondent data with other Respondent data. Certain subsets of this data are made available to our Customers, but your Personal Information is only shared with our Customers if (i) you have elected to do so using the features made available on the Site; or (ii) you complete an Assessment that has been sponsored by a Customer.
For research purposes—We may use aggregated Session Data to better understand how our Site is navigated, how many visitors arrive at specific pages, which pages or content attract more viewers, the length and frequency of stays at our Site, the different types of searches of our Site content and databases, the types of browsers and computer operating systems that our visitors use, and the IP addresses from which visitors connect to our Site, in order to improve our Site and enhance our content. We may use IP addresses to gather broad demographic information—information that is not associated with any individual, and is therefore anonymous. We also use aggregated Assessment responses and other data to improve our Products and Services.
For maintenance purposes—We may use IP addresses and Session Data to diagnose problems with our server, and to administer our Site.
For marketing purposes—We may use email addresses or other contact information to send mailings, newsletters, and other marketing communications regarding product information and releases. We may use your telephone number to contact you for marketing purposes. We may use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of the communications that we send.
For survey analysis—The information that we collect through our surveys is not used other than to garner survey results and statistical analysis.
Customers—CPP provides its Customers with the information that they need to properly complete or interpret Assessments. If you take an Assessment at the direction of one of our Customers, that Customer will receive from CPP a Report or Reports based on the Assessment you took and the responses you provided to that Assessment so that the Customer may properly counsel or advise you or provide you with other services. If you purchase Products or Services for use by another individual (for example, as a gift), then we may provide the recipient of such Products or Services with your Personal Information.
Service providers—We may engage certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, order fulfillment, mass mailing, hosting and maintenance, database storage and management, business analytics, and direct marketing campaigns.
The Public—If you are or become a Certified Practitioner, we may share information regarding your certification, such as your name, the instruments in which you are certified/qualified, the date(s) of your certification/qualification, and the current status of your certification/qualification with the public. In addition, certain Sites offer publicly-accessible blogs or community forums and any Personal Information you provide on these blogs or forums may be read, collected, and used by others who access them.
To defend or enforce our rights—CPP may use Personal Information to protect itself or to protect the Site, to respond to a breach of its Terms of Service, to prevent fraudulent activity, or where it is necessary to pursue available remedies. If a Customer neglects to pay amounts due and owing to CPP, CPP may send that Customer’s name, contact information, and account information to a third-party service provider for collection of overdue payments.
Law Enforcement; Litigation—Certain federal, state, local, or other government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information (a) if we believe in good faith that a law, regulation, rule or guideline requires it; or (b) to a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person.
Aggregated data—Other than as stated above, if CPP provides a third-party with Personal Information, it will be in the form of aggregated data and used for product development, research, or statistical analysis. Aggregated data are created from records that are stripped of all personal identifiers, such as aggregated Assessment responses, or on-site behavior.
A cookie is a small text file that a website sends to a visitor’s browser and that sends back information each time the visitor makes a request from the website. A cookie contains a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. Cookies can be accepted, rejected, or identified by configuring a browser’s preferences or settings. Pixel tags or clear gifs are tiny graphics with a unique identifier that are embedded invisibly on a webpage and are used to track a visitor’s movements on a website. We use the information gathered by clear gifs to help us better manage content on the Site. Cookies and pixel tags are used to help recognize a returning visitor, and to help customize the visitor’s online experience. Unless a visitor specifically informs us of his/her identity (e.g., by registering with us), we will not know who the individual visitor is.
- to collect Session Data and other session information;
- to process orders and to store order and shopping cart information;
- to store and hash usernames and passwords so that users do not have to re-enter this information each time they log in; and
- to collect analytics relating to visitors’ use of the Site.
We retain your Personal Information for as long as your account remains active or for as long as you continue to do business with us. Thereafter, we may retain Assessment responses and other data in non-personally-identifiable format for as long as the information is needed for our research, statistical analysis, product development, or other commercial purposes.
We follow generally-accepted industry standards to protect Personal Information, both during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect Personal Information from any unauthorized access, loss, misuse, disclosure, alteration, or destruction.
When we need to transfer information out of our firewall, we use industry-standard technological means to protect Personal Information while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security.
No method of transmission over the Internet, or method of electronic storage, is fully secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
We exercise reasonable efforts to keep your Personal Information accurate. However, we need your help in making sure that your Personal Information is correct in our systems. Please notify us of changes to information that you have previously provided by contacting us as indicated in the “Contact Us” section.
Right of access, modification—If you wish to have access to your Personal Information, or to correct or update the Personal Information that you have provided to CPP, please contact us with proof of identity, as provided in the “Contact Us” section. You can expect a response to your request within 30 days.
Right of deletion—If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us with proof of identity, as set forth in the “Contact Us” section. We will accommodate your request to the extent practicable, and to the extent that it does not otherwise conflict with any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our contractual agreements.
Right to opt-out of marketing communications—If you are receiving marketing communications from us and you wish to unsubscribe, you may do so by clicking on the “unsubscribe” link provided in the communication.
Right to block cookies—You have the right to block cookies and pixel tags. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or prompt you before accepting a cookie from the Site that you visit. If you decide not to accept our cookies, you may not be able to access portions of our Products or Services.
CPP has established procedures for periodically verifying implementation of and compliance with the Privacy Shield Privacy Principles. CPP conducts an annual self-assessment of its Personal Information practices to verify that the attestations and assertions that it makes about its privacy practices are true and that its privacy practices have been implemented as represented. CPP is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield organization shall remain liable under the principles of the Privacy Shield if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, CPP commits to resolve complaints about our collection or use of your personal information. E.U. and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CPP at the information provided in the ‘Contact Us’ section below.
CPP has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit JAMS for more information or to file a complaint. The services of JAMS are provided to you at no cost.
CPP commits to cooperating with E.U. data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the E.U. and Switzerland in the context of the employment relationship.
Under certain conditions, EU Citizens may invoke binding arbitration by a Privacy Shield panel, as outlined in Annex I of the Privacy Shield Framework. More information is available at www.privacyshield.gov.
Except as otherwise set forth under the ‘Privacy Shield’ section above for personal information originating in the E.U. or Switzerland, if our efforts to resolve your complaint through CPP’s internal dispute resolution mechanisms are unsatisfactory, you agree to first attempt to settle in good faith the dispute through mediation administered by JAMS, under its International Mediation Rules, which are accessible on the JAMS website at http://www.jamsadr.com/international-mediation-rules/. The mediator may propose any appropriate remedy, such as publicity for findings of non-compliance, payment of compensation for losses incurred as a result of non-compliance, or cessation of processing of the Personal Information who has brought the complaint. The mediation will be held online and all documents and other correspondence will be transmitted through email.
If our efforts to resolve the dispute through mediation are unsuccessful, you agree to binding arbitration administered by JAMS pursuant to its International Arbitration Rules, which are accessible on the JAMS website at http://www.jamsadr.com/international-arbitration-rules/. Judgment on the award rendered by the arbitrator may be entered into any court having jurisdiction over the matter. The arbitration will be held online and all documents and other correspondence will be transmitted through email.
By email: firstname.lastname@example.org
By phone: 800-624-1765 (toll-free when calling from the United States)
By mail: CPP, Inc.
185 N. Wolfe Road
Sunnyvale, CA 94086
United States of America