NuWest Privacy Policy

 

Our LearnBIG platform monitors time, click, and responses in an effort to build a solid picture of participant performance. This enables big data-style queries of trends and various aggregates to give unique business insight to our customers.

By default, the course database never stores or even handles any Personally Identifiable Information (PII).  The database allows customers to distinguish between users without identifying them because clients use a one-way hash to irretrievably scramble their IP address into what we refer to as an anonymous ID.  It is this anonymous ID that the course servers receive from the client that permits distinguishing between, but not identification of, users.

Information is anonymized such that it is possible to understand user behavior both in aggregate and individually, but, subject to the caveat above, information about activity is not attributable to specific individuals.

The course does store answers typed in by users and the authorized user identifier handed to it by a Learning Management System (LMS) if in use.  Unless specifically requested of us by the customer, we avoid requesting PII-related information from either the course participant or from the LMS.

COOKIES

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

 

Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about;
• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so.
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we receive from other sources

• We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR INFORMATION

You agree that we have the right to share your personal information with:

• Any member of our group, which means our subsidiaries.
• Selected third parties including:
  
  • service providers with which we have an agreement. These third-party service providers assist us in assessing our information security controls, maintaining our site, analyzing our site traffic, and in providing services and information to us and to users of our site;
  • advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others. We do not disclose information about identifiable individuals to our advertisers and advertising networks, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;
  • analytics and search engine providers that assist us in the improvement and optimization of our site.

We will also disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Direct Apps, Inc. or substantially all of the assets of any of the foregoing, is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of Direct Apps, Inc., or its subsidiaries, our customers, or others.

Unless permission is expressly granted, we will not share your Personal Information obtained as part of SMS consent with third parties and affiliates. However, if you divulge information in a public forum offered on our site such as a chat room, message board and/or news group, this will be considered public information and may be disclosed and used by third parties.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers or at our third party data centers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Please find the Microsoft Privacy Policy here.

YOUR RIGHTS

Depending on where you are located, you may have the right, under law, to ask us not to process your personal data for marketing purposes. Where you have the right, under law, to prevent such processing, you can exercise your right by contacting us at privacy@nuwestgroup.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

ACCESS TO INFORMATION

Depending on where you are located, you may have the right, under law, to access information held about you. Your right of access can be exercised in accordance with applicable law, which might be the Act. Any access request may be subject to a fee as may be notified to you from time to time, to meet our costs in providing you with details of the information we hold about you.

Any request should be made in writing, and the best way for you to do so is to contact us at the address stated below. As we must be able to identify the person making the request, and because a fee may be due, we request that you confirm any request made by you via different means by contacting us at the address stated below. Due to technological constraints and/or information security considerations, it may be inappropriate to use social media to supply information in response to any request by you for access to information, and so please provide an alternative delivery address for our response.

CHANGES TO OUR PRIVACY POLICY

We may modify this privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

CONTACTOur Data Protection Officer is Peter Buck. Questions, comments or requests regarding this privacy policy are welcomed and should be addressed to privacy@nuwestgroup.com. or by mail at NuWest Group, ATTN: Peter Buck, 325 118th Ave SE, Suite #300, Bellevue WA 98005.