EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Aperian Global participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List.
Aperian Global is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Aperian Global complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Aperian Global is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
In compliance with the Privacy Shield Principles, Aperian Global commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Aperian Global at: email@example.com
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Upon request and within 30 days, Aperian Global will grant individuals reasonable access to personal information that it holds about them. In addition, Aperian Global will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Please contact firstname.lastname@example.org to change your personal information gathered on the Site.
Upon request Aperian Global will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at email@example.com.
INFORMATION COLLECTED AND ITS USE
From the Aperian Global Learning Portal Registration page: When a User registers for the Aperian Global Learning Portal, the following information is collected:
- User's internet protocol ("IP") address is collected for the purpose of system administration, to report traffic patterns through the Aperian Global Learning Portal and related webtools, and to audit the use of the Aperian Global and related web tools (e.g. GlobeSmart ®, GlobeSmart Teaming AssessmentSM, GlobeSmart Leadership AssessmentSM, Assessments, Learning Paths, Webcasts, etc.)
- User's name and email address are collected in order to allow a record of their activities in the Aperian Global Learning Portal and related websites to be available to them upon subsequent visits. These activities include, but are not limited to:
- Results from the GlobeSmart ProfileSM
- List of whom the User has invited to take the GlobeSmart® Profile
- Scores from Tests
- Record of which Case Studies have been read
- Optional Contributions (including Ask an Expert and Share My Experience an)
- Password — generated by the User — is used to enable a secure login procedure for the User when entering GlobeSmart from a computer other than the one on which the User initially registered for GlobeSmart.
- Organizational Demographics are used by Aperian Global to provide Usage Reports to the User's organization broken down by the demographics selected by the organization (e.g. Business Unit, Region, Job Title, etc.)
The following demographic information is collected either at the point of registration or prior to the use of one of our tools that makes use of demographic information as part of its function, such as the GlobeSmart Profile, GlobeSmart Leadership Assessment , GlobeSmart Teaming Assessment or the Ask a Question/Share My Experience features within GlobeSmart. This information also aids Aperian Global in its ongoing research efforts and is used for improvement of assessment tools.
- Home Country
- Current Location
- Job Type
- Languages with professional proficiency
- Years of International Work Experience
- Up to three Client-defined "custom demographics"
This demographic information is displayed in collective form only. However, answers for the three Client-defined "custom demographics" may be reported back to your organization upon request, as this information is helpful for organizations to better understand their user population.Invite a Colleague
If a user chooses to use the Invite Others feature to compare GlobeSmart Profiles with their colleagues, they will be asked to enter their colleague(s) email address(es). An email will then be automatically sent to their colleagues inviting them to visit the site, complete their profile and share it with the user. Aperian Global stores this information for the sole purpose of sending this email and enabling the user to compare their profile with that of their colleagues.
Any individual invited to share their profile can send a request to Aperian Global at firstname.lastname@example.org to have their personal information deleted at any time.
Other Information Collected: Aperian Global may also collect certain information about a User's computer hardware and software automatically and store it in log files. This information may include: User's IP address, browser type, domain names, access times and referring Web site addresses.
We do not link this automatically collected data to other information we collect about you.
Cookies, Web Beacons and Other Similar Technologies
A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available. Web beacons and tags are small strings of code that are used in conjunction with a cookie and that allow us to record activity on our websites.
When you visit our website, we may use both a session and a persistent cookie. This Aperian Global-placed cookie may contain information (such as a unique user ID) that is used to track your usage of our website and, in some cases, your email address. Your email address is only saved in this Aperian Global-placed cookie if you register with us. A web beacon allows us to capture certain additional types of information about a visitor’s actions on a website, such as a visitor’s cookie number, the time, date, duration and number of page views, a description of the page where the Web beacon is placed, and details about any items that were purchased.
Aperian Global will retain your information for as long as your account is active, as needed to provide you services and will use your information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.Unless requested sooner,Aperian Global will delete all client and associated User information 6 months after the last end date of client's subscription.
In addition, for users not associated with a subscription to our services or for users associated with an organization that licenses our services for multiple years: a user's account will be considered "idle" and access will be locked after 1 year of inactivity. The user can regain access to an idle account by resetting the password on their account. After 2 years of inactivity, a user's account will be purged from our database.
THIRD PARTY LINKS: Our site contains several links to third party websites. If a User clicks on an external link the click will transfer the user off the Aperian Global-controlled site. These third party sites may include sites of the User's organization and/or Aperian Global partners that may use Aperian Global and/or its affiliates' logo as part of a co-branding agreement. These third party sites may send their own cookies, collect data or solicit information. Please note that if you click on social media links that are featured on our site, such links when followed may collect your IP address, which page you are currently visiting on our site, and may set a cookie to function properly.
Single Sign-On: You may be able to log in to our site using an OpenID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.
Service Providers: Aperian Global's computer servers are hosted by third party providers which are SOC2 compliant and are prohibited from using personal information for any purpose.
PROTECTION OF USERS' INFORMATION: The security for all Information associated with GlobeSmart Users is of utmost importance to Aperian Global. Once Aperian Global receives a transmission from a User, it uses industry standard efforts to safeguard the confidentiality of the User's information. For example, Aperian Global stores and protects the personal information Users provide using computer systems with restricted access, located in controlled facilities using standard safeguards such as firewalls and secure socket layers.
Aperian Global and its service providers also exercise reasonable care in providing for secure transmission of information between a User's PC and Aperian Global's servers. Aperian Global cannot, however, guarantee that data transmission over the Internet is 100% secure. Therefore Aperian Global and its service providers cannot guarantee the security of any information transmitted to them from a User, nor can they guarantee the security of any information transmitted to the user from GlobeSmart or a third party link.
- Account Settings: The Account Settings page in the Aperian Global Learning Portal allows Users to view and change their account information. On this page, Users can change their email, password, demographic and other information collected in the Registration process. Aperian Global will respond within thirty days to all offline requests to provide access to personal information.
- GlobeSmart Profile: The GlobeSmart Profile page allows the User to re-take the survey at any time.
- Choice/Opt-out: There are certain system emails for which Users may not opt-out. These include the account activation email and invitations from colleagues or team members inviting them to share GlobeSmart Profiles.
Disclosure: In certain situations, Aperian Global may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We reserve the right to disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our website. If Aperian Global is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Company Contact Information Attn: Privacy Officer, Aperian Global, 1 Kaiser Plaza, Suite 785, Oakland, CA 94612 email@example.com