Privacy Policy

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CPP PRIVACY POLICY

Version Date: January 3, 2013

This website is owned and operated by CPP, Inc. (“CPP”, “we”, or “us”). We work diligently to protect the privacy, confidentiality, and security of the Personal Information that we receive. This Privacy Policy describes the principles and practices that apply to the Personal Information (defined below) that we collect from individuals online or offline (“visitor” or “you”), such as individuals who browse through our Site (defined below), register on the Site, use the services provided on the Site, interact with the Site, communicate with us through telephone, email, text or other communications means, participate in our interviews, surveys, or promotions, or read or receive our newsletters.

This Privacy Policy is based on the following values:

  • We will not collect your Personal Information without your knowledge
  • We will take reasonable measures to protect the security of your Personal Information
  • We will not disclose your Personal Information to third parties other than as described in this Privacy Policy
  • You will be able to view the Personal Information that we have about you, and to correct or modify it if it is inaccurate or incomplete.

QUICK LINKS

DEFINITIONS

In this Privacy Policy, the following terms are defined as set forth in this section:

Assessment” means an instrument, questionnaire, or series of tests that are completed by an Assessment Taker in view of the preparation of a Report or to provide information about, or to, an Assessment Taker, Customer, or Test Administrator.

Assessment Taker” means an individual who takes, will take, or has taken an Assessment.

CPP Proprietary Methodology” means and includes, without limitation CPP’s proprietary scoring methods and algorithms and the research and training that has been developed by, or for, CPP as pertaining to Products or Services developed, or licensed by CPP.

“Customer” means an individual, business, or other entity that purchases CPP’s Products or Services, including, without limitation: (a) an individual or business that purchases books or other materials sold by CPP; (b) an individual or business that purchases online Assessment services and Assessment Reports; (c) a Test Administrator (or employer of Test Administrator) who has a contractual relationship with CPP; and (d) an entity with which CPP has a contractual relationship to provide other 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. 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.

Products or Services” means the Products or Services promoted, sold, or available for sale from the Site or through CPP personnel, such as the CPP online assessment center—currently www.skillsone.com—the CPP MBTI® Complete service, the iStartStrong service, or the CPP books and materials.

Report” means an analysis of the scoring and responses provided in connection with an Assessment, that is developed using the CPP Proprietary Methodology, and which (i) a Test Administrator, using the CPP Proprietary Methodology, may interpret for an Assessment Taker during one or several feedback sessions or interpretation sessions; or (ii) a Customer may use in its business with the Assessment Taker.

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 of the following websites (or any other websites that CPP may develop or have developed from time to time): www.cpp.com, www.skillsone.com, online.cpp.com, www.cppiconsuccess.com, fulfillment.cpp.com, www.cppsurveys.com, mbtiresearch.skillsone.com, www.mbtitalk.com, www.cppccac.com, people.cpp.com, www.cppnavstore.com.

Test Administrator” means an individual who has been trained in the CPP Proprietary Methodology or otherwise qualified to review Assessments using the CPP Proprietary Methodology, and who administers Assessments to Assessment Takers, analyzes the scores and Reports generated by CPP from these Assessments, interprets these scores and Reports using the CPP Proprietary Methodology, and, at the Test Administrator’s discretion provide these scores and reports to Assessments Takers.

CONSENT

By using the Site and/or submitting Personal Information to us, you consent to the practices described in this Privacy Policy and on the Site and agree that we may collect, use, disclose, store, transmit, or process such Personal Information in accordance with this Privacy Policy or as required by law.

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, including the United States, that may not have data protection laws that provide the same level of protection as those that exist in your country of residence.

No children under 13 -- Children under 13 are not permitted to use the Site without their parents' or guardian’s 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 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 automatically remove such 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 us as indicated in the How to Contact us section.

LINKS TO EXTERNAL SITES

This Site may link to websites that are operated by third parties. These websites are not subject to this Privacy Policy. We recommend that you read the privacy statements that are posted on these third-party websites to understand their procedures for collecting, using, and disclosing Personal Information.

WHAT PERSONAL INFORMATION WE COLLECT AND HOW

We collect only such Personal Information as necessary to provide our Products or Services to you, inform you about our Products and Services, continue our research in the field, and improve our Site, Products, Services, and your experience interacting with CPP. In some cases, we ask questions to which the response is optional, and these questions are identified as such. You are free not to respond to these optional questions. We describe below the different ways in which we collect or obtain Personal Information.

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.

If you register or create an account -- If you register or create an account, we require that you fill out a form to register as a purchaser or Customer (as applicable). We collect your name, contact information, and other information, and may ask you for other optional information that helps us serve you better.

If a potential Test Administrator creates an account, we collect additional information about the person’s practice, credentials, and education, as necessary to assess the qualifications of the applicant to purchase Assessment services.

If you purchase a Product or Service -- If you purchase a Product or Service, we collect your contact information as necessary to fulfill the order (such as name, address, shipping information, email address, or telephone number) and optional information if you provide it.

If you purchase a Product or Service for delivery to, or use by, another person, we collect your Personal Information as the person initiating the purchase, and Personal Information about that other person (such as name, shipping address, telephone number or email address) as necessary to fulfill the order. By providing another person’s Personal Information, you represent that you have that person’s permission to do so.

If you pay for a Product or Service -- When you make a purchase online, we do not collect payment information ourselves. Instead, you are redirected to our payment processor’s website, which collects directly your payment information. CPP only receives a notice of the receipt of the payment, a confirmation number (for verification purposes), the name and contact information of the recipient of the Product or Service, and the name and contact information of the cardholder if different from the name of the person receiving the Product or Service.

If we take an order over the phone or by fax, we collect the payment information directly from the person placing the order, transfer it to the payment card processor, and, after receiving confirmation of the payment from the payment card processor, we retain this payment information in a secured location, with restricted access, and in accordance with our internal record retention policy.

If you complete an Assessment -- If an Assessment Taker completes an Assessment at the direction of a Customer (e.g., an employer, a Test Administrator, etc.), whether online or offline, we collect the Assessment Taker’s unique identifier and in some cases, the Assessment Taker’s gender. The Assessment Taker also has the option to provide demographic information such as highest level of education attained or occupation. We collect the responses provided to the questions in the Assessment. In this case, we do not know the identity of the Assessment Taker. We only know the identity of the Test Administrator, and the unique identifier that has been assigned by the Test Administrator.

If an Assessment Taker completes an Assessment on his own initiative (i.e., outside the scope of a relationship with a Customer), using our online service, we collect the Assessment Taker’s contact information, and in some cases, gender. The Assessment Taker also has the option to provide demographic information such as highest level of education attained or occupation. We collect the response provided to the questions in the Assessment. In this case, we know the identity of the Test Taker and that of the person who paid for the Assessment, if applicable.

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 (to avoid duplicate responses), as well as any other Personal Information that you may provide in your survey responses. The responses from survey participants are compiled in an anonymized format.

If you sign up to receive a CPP newsletter -- If you sign up to receive a CPP newsletter, we may collect information on the open rate of the newsletter, and whether a specific individual has clicked on a link contained in a particular issue of our newsletter.

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 email address, telephone, contact information, and correspondence in the regular course of our interaction with you.

If you participate in our blogs or forums, or if you write to us -- We may collect the Personal Information that you provide in your correspondence and communications with us, or through your participation in surveys, blogs, and forums.

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, CPP distributors, Test Administrators, Test Administrators’ employers, 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.

If you become certified or qualified in our Products or Services -- If you become certified or otherwise qualified in one or more of our Products or Services, we collect information regarding the details of your certification or qualification, such as your name, the instruments in which you are certified/qualified, the date of your certification/qualification, and the current status of your certification/qualification.

HOW WE USE PERSONAL INFORMATION

We use Personal Information in order to provide and enhance the Products or Services that we offer as explained below:

To facilitate the use of the Site -- We use the Session Data to ease navigation throughout the Site, to enhance navigation, such as to determine the language of the country where the visitor is located, keep track of the shopping cart or 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 prepare the related Report about the Assessment Taker. The Report is delivered to our Customer. We retain a copy of your responses and the related Report in accordance with our record retention policy.

To provide our Products and Services -- The Personal Information collected from purchase order forms is used to send orders to our Customers. The limited payment information that we receive from our payment processors is used to verify that a Product or Service has been paid for.

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. The IP addresses are then disposed of in accordance with our record retention policy.

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 collateral 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. Such data are used in aggregate form only and never disclose an individual's identity.

TO WHOM WE DISCLOSE PERSONAL INFORMATION

From time to time, we may disclose Personal Information to someone other than the individual who provided this information, as follows:

Assessments Reports -- CPP provides its Customers with the information that they need to properly counsel or advise their clients, customers, and employees, as applicable. If you are taking an Assessment at the direction of one of our Customers, that Customer will receive from CPP a Report on the Assessment that you took, so that he or she may properly counsel or advise you or provide you with other services.

The Public -- If you are or become certified or qualified as a Test Administrator for our Products and Services, we may share information regarding your certification, such as your name, the instruments in which you are certified/qualified, the date of your certification/qualification, its scope, and the current status of your certification/qualification with the public, and you hereby authorize us to do so.

Foreign Distributors -- CPP may provide its distributors in foreign markets with a list of Customers (including name and contact information) or prospective Customers residing in that distributor’s CPP-approved area of distribution. CPP will do so only when it reasonably believes that providing such information will permit to improve the service to CPP Customers or prospective Customers in that distributor’s area, and only when the distributor’s use of such information is in accordance with CPP’s privacy policies in general.

CPP Sites -- We may combine the information that we collect from different CPP Sites to supplement an individual’s profile, for example to combine the records of different purchases or different activities made or conducted from different CPP Sites.

Public Forums -- The Sites www.cppiconsuccess.com and www.mbtitalk.com offer publicly accessible blogs or community forums. Any Personal Information that you provide on these blogs or forums may be read, collected, and used by others who access them.

Service providers -- We may engage certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, shipment, order fulfillment, payment credit card processing, mass mailing, hosting and maintenance, database storage and management, business analytics, fraud prevention, and direct marketing campaign service providers. For example, If during the creation of your account, you affirmatively indicate to us that you are exempt from taxes, we share your email address with our service provider who will email you a link describing how you can use their service to verify your tax-exempt status.

Pursuant to written agreements between CPP and these service providers, each of these service providers only has access to such Personal Information as necessary to fulfill its obligation to CPP, is not permitted to use Personal Information for any purposes other than those directed by CPP, and is required to act in a manner consistent with the relevant principles articulated in this Policy.

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 and Conditions, 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 CPP customer’s name, contact information, and account information to a third-party service provider for collection of overdue payments.

Co-marketing -- We may collaborate with other companies to offer you additional Products or Services (e.g., book publishers). We will share Personal Information that is necessary for these other companies to provide the Products or Services that you have requested. This Privacy Policy does not cover the use of your Personal Information by these companies. We encourage you to read a company’s privacy policy before requesting any of its Products or Services.

Mergers & Acquisition; Bankruptcy -- If any or all of the CPP assets are acquired by, or merged with those of another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all of our users’ personal information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing our services to our users. If the recipient of the personal information has personal information practices that do not meet the substance of this Privacy Policy, you will be given the opportunity to exercise your rights with respect to your Personal Information..

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 a combination of thousands of answers to survey questions and instrument responses, or on-site behavior.

COOKIES AND OTHER TECHNOLOGIES

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. 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 do not tie the information gathered by clear gifs to Personal Information. You can learn more about cookies by visiting www.allaboutcookies.org or http://networkadvertising.org.

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. The Site uses cookies as follows:

Cookie Type and Content

Site

Session based information

online.cpp.com

fulfillment.cpp.com

www.cppsurveys.com

people.cpp.com

mbtiresearch.skillsone.com

Order and shopping cart information

www.cpp.com

Order processing

www.skillone.com

Store and hash the user name and password so that users do not have to re-enter this information each time they comment on the blog or log in

www.cppnavstore.com

www.cppiconsuccess.com

www.mbtitalk.com

www.cppccac.com

User account information and eligibility to make a purchase; deleted when the visitor logs out or when the browser is closed.

www.skillsone.com

Third Parties Tracking Technologies -- Our third party advertising partner employs pixel tags that help us better manage content on our Site by informing us what content is effective.

HOW WE RETAIN PERSONAL INFORMATION

We retain scored item responses and the related Report associated with the user ID or transaction number that our Customer provided us in accordance with our internal record retention policy and for at least two (2) years from the date when an Assessment Taker took an Assessment. Thereafter, we retain the scored item responses and Report in an anonymized format, for as long as the information is needed for our research, statistical analysis, or product development.

CPP will not be able to identify an individual from the records who is identified only with a transaction number provided by our Customer because CPP does not have access to the information in the Customer’s custody that would allow identifying the individual who completed a particular Assessment.

HOW WE PROTECT PERSONAL INFORMATION

Security -- We follow generally accepted industry standards to protect Personal Information, during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect it 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.

Identity Theft -- Identity theft and the practice currently known as “phishing” are of great concern to us. For more information about protecting yourself from these practices, you may want to visit http://www.ftc.gov/bcp/edu/pubs/consumer/alerts/alt127.shtm. Please understand that you also have a responsibility in protecting your information. The only time when a CPP associate may contact you (via electronic communication, postal mail, telephone, etc.) about your credit card or payment information is in connection with a transaction that you have initiated. Otherwise, no one from CPP is permitted to contact anyone to request your credit card information, user ID, password, national identification number, or other identifier or sensitive information in a non-secure or unsolicited email or telephone communication.

DATA ACCURACY

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 .

YOUR RIGHTS

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.

If you are an Assessment Taker, and you wish to have access to a copy of your responses to an Assessment, or a copy of the Assessment Report that CPP prepared from the evaluation of your responses, please contact the Test Administrator who is managing your specific Assessment.

If you wish to have access to the Assessment Report that CPP prepared about a third party, for example if you paid for a third party to take an Assessment, please contact the Test Administrator who is managing this specific Assessment.

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 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 agreements.

Right to opt-out of the use of your Personal Information -- You may unsubscribe from receiving any of the CPP surveys by selecting the appropriate option during account setup or modification once you are logged into your account. You may unsubscribe from receiving a newsletter by clicking on the unsubscribe link provided in the newsletter.

If you wish to opt-out of the use or sharing of your Personal Information, or if you wish that your Personal Information be removed from our blog or community forum, www.cppiconsuccess.com and www.mbtitalk.com, you can always do so by contacting us as set forth in the “Contact Us” section. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

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 will be able to access those parts of our Site that are available to the general public, but you will not be able to access most of our Products or Services.

California Privacy Rights -- California law requires that individuals be informed when their Personal Information is shared with third parties for these third parties’ direct marketing purposes. Other than as described in this Privacy Policy, we do not disclose your Personal Information to third parties for the direct marketing purposes of these third parties. If our practices change in the future, we will inform you of the change and will provide you with an opportunity to opt out of such information sharing for direct purposes of a third party.

SAFE HARBOR

For Personal Information of individuals that CPP receives from the European Economic Area or Switzerland, CPP has committed to handling such information in accordance with the U.S. – EU and the U.S. – Switzerland Safe Harbor Principles. CPP adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Information regarding the U.S. - E.U. & U.S. - Swiss Safe Harbor Frameworks can be found at: http://export.gov/safeharbor. CPP’s Safe Harbor certification can be found at http://safeharbor.export.gov/companyinfo.aspx?id=14621. To learn more about the Safe Harbor program, please visit the US Department of Commerce website at http:// export.gov/safeharbor/.

CPP has established procedures for periodically verifying implementation of and compliance with the Safe Harbor 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.

COMPLAINTS AND DISPUTES

If you have questions or complaints regarding our privacy policy or practices, you should first contact the Legal Department of CPP as indicated in the section “Contact Us” below. We will respond to your questions and will attempt to resolve all complaints promptly.

If our efforts to resolve your complaint through CPP’s internal dispute resolution mechanisms are unsatisfactory, you agree to first attempt 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 administrated 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 in any court having jurisdiction over the matter. The arbitration will be held online and all documents and other correspondence will be transmitted through email.

READER PRIVACY ACT

CPP complies with the Reader Privacy Act, California Civil Code §1798.90. Because CPP has received fewer requests for personal information than is specified in the Act, CPP has not prepared a report of those disclosures of personal information.

CHANGES TO THE PRIVACY POLICY

We may from time to time change this Privacy Policy. If we make material changes, we will place a prominent notice on the Site or will send you a notice to the email address that you provided to us.

CONTACT US

If you have any question about (a) this Privacy Policy, or (b) the collection, use, management, or disclosure of your Personal Information, or (c) accessing, modifying, or closing your account, please contact us as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them.

By email: custserv@cpp.com

By phone: 800-624-1765 (toll free when calling from the United States)

or

(1) 650-969-8901

By mail: CPP, Inc.

Legal Department

1055 Joaquin Road, Suite 200

Mountain View, CA 94043

USA