CPP Privacy Policy

Version Date: May 1, 2016

 

This website is owned and operated by CPP Inc. (“CPP,” “we,” or “us”), a California corporation.  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 privacy principles:

  • 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.
  • Accountability for Onward Transfer - We will not disclose your Personal Information to third parties other than as described in this Privacy Policy, and our agreements with third parties with whom we share Personal Information will reflect our privacy principles.
  • 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”).

 

Quick Links

  • Definitions
  • Consent
  • 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
  • Safe Harbor
  • Complaints and Disputes
  • Changes to the Privacy Policy
  • Contact Us

 

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 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.

 

Consent

By creating an account, using the Site, and/or submitting Personal Information to us, you consent to the practices described in this Privacy Policy, and you agree that we may collect, use, disclose, store, transmit, and/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 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.

 

Links to External Sites

This Site may link to websites that are operated by third parties.  Because such websites are not operated by CPP, they 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 (i) provide our Products or Services to you; (ii) inform you about our Products and Services; (iii) continue our research in the field; and (iv) improve our Site, Products or Services, and your experience interacting with us.  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 (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.

 

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 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. 

 

To Whom We Disclose Personal Information

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

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. 

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 privacy principles articulated in this Privacy Policy.

Foreign Distributors -- We may provide Personal Information to our distributors in foreign markets.  We only do so when we believe that providing such information will permit us to improve the Products or Services provided to Customers in that distributor’s territory, and only when the distributor’s use of such Personal Information is in accordance with the privacy principles described in this Privacy Policy.

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.

Co-Marketing Partners -- We may collaborate with other companies to offer you additional Products or Services.  We may 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 affected Products or Services. 

Mergers & Acquisition; Bankruptcy -- If any or all of CPP’s 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 privacy 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 aggregated Assessment 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 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. 

The Site uses cookies as follows:

  • 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.

 

How We Retain Personal Information

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. 

 

How We Protect Personal Information

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.

 

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.

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.

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.

 

Privacy Shield

For Personal Information of individuals that CPP receives from the European Economic Area, CPP has committed to handling such information in accordance with the U.S. – EU Privacy Shield framework.  CPP adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability (as described at the beginning of this Privacy Policy). 

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.

 

Complaints and Disputes

If you have questions or complaints regarding our Privacy Policy or practices, you should first contact us as indicated in the “Contact Us” section below. 

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. 

EU Citizens may also direct complaints to local Data Protection Authorities or to the Ombudsperson designated by the U.S. government, which work with the Federal Trade Commission in the United States to resolve complaints. 

 

Changes to this Privacy Policy

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

 

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.

            185 N. Wolfe Road

            Sunnyvale, CA 94086

            United States of America