Effective starting: May 20, 2018
Key changes are listed at the bottom.
This policy is to help you understand:
Some basic definition throughout this policy: “LearnCore”, “we”, or “us” refers to VLinks Media LLC dba LearnCore. “You”, “your” refers to the end user. And “administrator” refers to a person (typically your manager) who has a privileged permission set and full account access and control of your data. The words product or service refers to all commercial services including any websites as “Services” in this policy.
The LearnCore Service is provided under contract between us and an organization (for example your employer, or partner program) who purchased the Service. The organization who purchased the Services ultimately controls your information. LearnCore is a processor of your personal data on behalf of the organization granting You access to and managing your account to the LearnCore platform.
Information we process
LearnCore collects information about you when you, or other sources (e.g. your employer) provide it to us.
Personally provided information
LearnCore collects the following information about you when you input the data or provide it to us via a recording, upload, or similar.
Profile Information: LearnCore collects your registration information in order to create a personalized record of you. You have controls to edit, set up personal preferences, receive in app notifications and recommendations, be assigned courses, opt-in or out for email reminders and ultimately show if/when courses have been completed in reporting.
Metadata you provide through your use of the Service: LearnCore tracks certain information when you visit and interact with our Services. This information includes engagement patterns, the features you use; the links you click on; the courses you complete; various data regarding the uploaded content used in the delivery of training like type, size and filenames; documents or multimedia authored within the Services frequently used search terms in support; tagging elements, and how you interact with others on the Services. LearnCore also collects information about you that you or your manager choose to disclose. Examples of content we collect and store include: the digital documents, videos, and other training content, time spent across various pages and other click activity in order to make the service better.
Information you provide through our websites and support channels: The Services also include our websites owned or operated by LearnCore. We collect other content that you submit to these websites, which include support channels, social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive feature like surveys, social post, webinar, contests, promotions, activities or events.
Other information that is automatically collected
In an effort to continuously improve the Service, LearnCore uses analytic tracking tools like Google Analytics, to collect information about you in the anonymized and aggregated form when you use our Services. This information is also collected when browsing our websites or taking certain actions within the Services.
Device and Connection Information: In order to expedite support issues, we may collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and possible settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Information we receive from other sources
We may receive information about you from other Service users including peers, from third-party services like your HRMS, and from your business employer or channel partners.
Other Service users: Other users of our Services may provide information about you when they submit content through the Services. For example, LearnCore may receive your account information from your administrator.
Single-Sign-On: LearnCore collects and authenticates your information against a 3rd party set up by your training administrator for the purpose of sign-sign-on. This is controlled at the account admin level and not by LearnCore.
Using collected information
LearnCore collects information based on how you use the Service and the preferences you have set up. Further details are regarding the collection of your data is below.
Authentication and Personalization: Your information is used to provide the Services, including to authenticate you when you log in, provide customer support, and operate and maintain the Services. For example, LearnCore uses your email and password to authenticate into the Service. This may be directly within LearnCore or via a 3rd party single sign on provider (see directly above). The Service also allows for deep personalization by analyzing your activities and recommending the order in which you should conduct your training. For example, this is as simple as presenting all your over-due courses first, or showing the top ranked Pitch IQ’s from last week to watch.
Feedback: LearnCore uses your feedback alongside the data we track to improve the Services. For example, to improve the Course Dashboard page, we laid out a heat map of clicks across users and used this new intelligence to give you an improved layout. Further data is collected and supported with user surveys, and other feedback channels like support. In some cases, we apply such feedback directly into the Service for everyone, while other times we A/B test and analyze certain new features with some users before rolling the feature out to all users.
Communication: Your contact information is used to provide transactional communications via email, or in app notifications within the Services. Examples include: Pitch IQ Feedback required email, a weekly digest of activity, you have a new course waiting, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages among others. We also send you helpful communications as you onboard. Examples of these include, introducing new/unused features, or showing progress. Communication frequency can be controlled in your personal or admin profile or a global opt-out can be requested by emailing firstname.lastname@example.org.
Information used for marketing and promotion: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying LearnCore ads on other companies’ websites and applications, as well as on platforms like Facebook and Google; or by receiving a business card at an event like Dreamforce. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. We don’t like to be bothered either, so if you wish to no longer receive these communications simply click “unsubscribe” at the bottom of the email.
Customer support: LearnCore uses your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
Security: LearnCore uses information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
Protecting LearnCore’s business interests and legal rights: LearnCore, where required by law or where we believe it is necessary to protect our legal rights, our interests including 3rd parties, use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger, or sale of a business.
With your consent: LearnCore uses information about you where you have given us consent to do so for a specific reason not addressed within. For example, with your written permission, we may publish testimonials, case studies, featured customer stories to promote the Services.
Legal bases for processing (for EEA users):
LearnCore only collects and processes information on individuals in the European Economic Area (EEA) where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services used and how you use them. This means we collect and use your information where:
- LearnCore is providing you the Services, including providing customer support and personalized features and to protect the safety and security of the Services;
- LearnCore determines that a legitimate interest (which is not overridden by your data protection interests) is at play, such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- LearnCore receives consent from you; or
- LearnCore is compelled by a legal obligation to process your data.
Even if you have previously consented to our use of information about you for a specific purpose, you always have the right to change your mind. Naturally, any change will not affect any historical processing that has taken place. Disputes caused where we are using your information due to a third party (e.g. your employer) should be first resolved between you and that third party before bringing to LearnCore.
Sharing collected information
To be abundantly clear, LearnCore is not in the business of selling information about you to advertisers or other third parties.
LearnCore is in the business of making a world class integrated learning experience. We share collected information described below.
Sharing with other Service users
When you use the Services, we share certain information about you with other Service users. For example, your name may be posted to leaderboard, or be reportable by your employer.
For training: You can create content, which may contain information about you, and based on the settings your administrator sets you can grant permission to others to see, share, edit, copy and download that content as well. Some of the collaboration features of the Services display some or all of your profile information to other Service users when you share or interact with specific content. For example, when you launch a course we display your profile name next the Course Creator title. This is particularly helpful as end user questions come up, they know who to ask. Depending on the pitch type, content authored in Pitch IQ may also record your face as well as your narrate through a situation.
Administrators and Controllers: End user access to LearnCore is granted through an invitation system controlled by your employer, or a business partner. In order to gain entry, the administrator will input your name, email, and other profile information on your behalf in order to create and add you to the Service. Once added to LearnCore, your administrator can group you among other members, assign coursework, and collaborate with you directly through LearnCore tools. Given that the vast majority of usage is for required employer initiatives, you will need to contact your administrator directly to opt-out of these communications.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.
Service Providers and Partners: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to:
(a) comply with any law, regulation, legal process or governmental request,
(b) enforce our agreements, policies and terms of service,
(c) protect the security or integrity of our Services,
(d) protect LearnCore, our employee’s, our customers or the public from harm or illegal activities, or
(e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Change of Control and Business Transfers
LearnCore may share your information with the joining company upon merger, acquisition, sale of company assets, financing, or formal name change.
Secure storage of collected information
LearnCore uses hosting providers located in the USA to host the collected information. Strict technical measures are in place to make sure your data is safe and secure. All data is encrypted while at rest using 256 bit encryption and while in transit over the most up to date version of TLS. In addition, your information is also protected through your personal authentication credentials.
While we aim to implement industry leading safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
Unless otherwise specified in an organizational agreement, LearnCore retains your data across its production and backup databases for as long as you have a subscription with LearnCore + 30 days after termination.
Accessing and controlling your information
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. As Services are being administered for you by your employer, you will need to contact them first if you choose to exercise this right. For all other requests, you may contact us for help at email@example.com.
Requests and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Deactivate your account: If you no longer wish to use our Services, your administrator can remove and delete you from the Service.
Delete your information: In most cases, your administrator can delete or update information on your behalf. For all other cases, write in to firstname.lastname@example.org. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations. Deleting information may also be limited per the statement above.
Opting out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, or by contacting us at email@example.com. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
Transferring information we collect internationally
International transfers of collected information
We collect information globally and store that information in the United States. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
Other important privacy information
Notice to End Users
Our products are intended for use by organizations where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy requests to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Administrators are able to:
- require you to reset your account password;
- modify authentications;
- restrict, suspend or terminate your access to the Services;
- access information in and about your account;
- access or retain information stored as part of your account;
- install or uninstall third-party apps or other integrations
In some cases, administrators can also:
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information
Our policy towards children
The Services are not directed to individuals under 18. We do not knowingly collect personal information from minors under 18. If we become aware that a minor under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact firstname.lastname@example.org for immediate removal.
Your information is controlled by VLinks Media LLC dba LearnCore. If you have questions or concerns about how your information is handled, please direct your inquiry to LearnCore’s DPO Ethan Linkner at email@example.com.
ATTN: Ethan Linkner, DPO
222 N. LaSalle St., #1550
Chicago, IL 60601
- More user-friendly language and better navigation. We made the policy easier to understand, by using clear, plain language and examples that explain how we treat and protect data. The page has also been reformatted with active links, so it’s easier to find the information that matters most.
- Using our products for work. End Users gain access to LearnCore via their organizational (e.g., their employers), who ultimately control their accounts or use of our services. The updated policy clarifies our relationship to these users and explains the tools available to administrators of these users.