Privacy Policy

COMMPARTNERS PRIVACY POLICY:

CommPartners, is a leading provider of Software as a Service Learning Management Solutions (ElevateLMS) as well as Webinar and Webcast services and is committed to protecting the privacy of our Customers and their Users.  CommPartners does not sell or rent the information or any Personal Data that our Customers/Users provide to any third party.  However, when processing e-commerce transactions, it is necessary for Commpartners to share your personal information with highly respected merchant service providers Authorize.net https://www.authorize.net/company/privacy/ and/or PayPal https://www.paypal.com/us/webapps/mpp/ua/privacy-full

Commpartners complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  CommPartners has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
In compliance with the Privacy Shield Principles, CommPartners commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CommPartners at:
Attention:  John Volentine  jvolentine@commpartners.com

CommPartners has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.  Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.  In cases of onward transfers of data, received pursuant to the EU-U.S. Privacy Shield, Commpartners, Inc. is potentially liable.

Services Provided by CommPartners

Each ElevateLMS website (the ‘Site’) is licensed, operated and maintained by our paying Customers, referred to as, the ‘Company’.

This page sets forth our policies regarding the use and disclosure of information we collect from or are able to obtain about the Site’s Users. We refer to these policies as our ‘Privacy Policy.’ In addition to the lower case words ‘we’, ‘us’ and ‘our’ defined above, you will notice that we capitalize certain words in this Privacy Policy even though the rules of grammar do not require that they be capitalized. We do this because these words have specific meanings in this Privacy Policy. These specific meanings are found where the capitalized words are placed in bold text and inside quotation marks.

We hope this Privacy Policy will answer your questions regarding how we treat information gathered from our Company Site(s). If you have questions or concerns regarding this Privacy Policy, other than requests for our information sharing practices as described in the first paragraph above, please feel free to contact us at jvolentine@commpartners.com

This Privacy Policy does not apply to information that you may provide to us, or that we may obtain through means other than from a Site, such as by phone or postal mail. But please note that information including your name, billing address, shipping address, e-mail address, phone number, and/or credit card number that you provide to us through such means will be treated in accordance with the first paragraph above and our use of such information will be consistent with this Privacy Policy. By accessing and using a Site, Users are agreeing to the terms of a Privacy Policy such as this. If the User does not agree to the terms of the Privacy Policy, they are not authorized to use the Site. Furthermore, by providing information on this Site, the User fully understands and unambiguously consents to the collection and processing of such information accordance with the Privacy Policy.

This Privacy Policy may change from time to time. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Please check this page for updates periodically. If we make any material changes to this Privacy Policy, we will notify you here. We generally do not provide notice of changes to this Privacy Policy and your use of the Site following any posted changes will indicate your acceptance of such changes.

What Information Do We Actively Collect and Inactively Gather?

Information You Provide

In order to process orders efficiently, when you create a Site account, access the Site from a third party website, or place an order, we may actively collect the following information: full name, billing address, shipping address, e-mail address, phone number, and during a financial transaction, temporarily collect your credit card number. Our Sites do NOT store your credit number or information. For your security, you will be required to enter your credit card information for each transaction.  Our Sites do not collect or store any special categories or criminal data as defined by the GDPR Guidelines.

We may also receive information about you from other sources such as from a Customers database that is connected to a Site via some kind of integration.

Lawful Basis For Processing Personal Data:

By voluntarily creating an account, all Users voluntarily consent to having their personal data processed.  Upon creating an account, Users may opt to process PCI DSS compliant credit card transactions, poll responses, test results, course registrations, record personal content interests and other course related activities within the Site.  During this voluntary process, a User may temporarily provide access to their credit card information (which is not permanently stored) in order to register for a course or gain access to digital content.  After the transaction has been successfully completed, the credit card data is erased from the system.  Once a User has acquired access to the content, the User may review course material, take a test, respond to a poll, respond to assignments, view videos or other multi-media content or volunteer their personal interest in subject categories.  Email addresses are used to send notices to the Users on a regular basis reminding or informing them of activities related to the content.  Please keep in mind that CommPartners is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and that Commpartners may be required to disclose personal information in response to a lawful request by public authorities, including national security or law enforcement requirements. In cases of onward transfers of data, received pursuant to the EU-U.S. Privacy Shield, Commpartners, Inc. is potentially liable.

Site Usage Information

We may inactively collect from you information that is not in the same category as your name, billing address, shipping address, e-mail address, phone number, or credit card number. For example, we might track information about the date and time you access a course, how long you were participating in the course, and page visits. We collect and use this and other information to analyze User course progress and activity as well as determine your interests regarding courses or content and how to further improve the Site. To accomplish all this, and also to allow us to offer our Users streamlined ordering and other useful features, we, as do many web sites, use and tracking technologies listed below and other similar technologies (the ‘Tracking Technologies’):

  • Cookies and Clear GIFs – Cookies are pieces of information that are stored by your browser on your computer’s hard drive. Cookies make web surfing easier for you by saving your customer identification information (i.e., username, password, shopping cart information, etc.) while you’re at a site. Cookies also track where you travel on a site and what you look at and purchase. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a web page or message.
  • IP Address Tracking and Clickstream Data – In addition to cookies and clear GIFs, our servers automatically collect data about your server’s Internet address when you visit our Site. This information, known as an Internet Protocol address, or ‘IP Address’, is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet. When you view pages from our Site, our servers may record or ‘log’ your IP Address and sometimes your domain name. Our server also may record the page that linked you to us and related information including any ads you may have clicked on. Such information is known as ‘Clickstream Data’.
  • Email Interconnectivity – If you receive email from a Site, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

In some cases, we may link the information collected through the Tracking Technologies with certain information that you provide us. WE WANT TO BE SURE THAT YOU UNDERSTAND THAT ACCEPTING TRACKING TECHNOLOGIES ONTO YOUR COMPUTER IN NO WAY GIVES US ACCESS TO YOUR COMPUTER OR ANY ADDITIONAL INFORMATION ABOUT YOU. YOU MAY SET YOUR WEB BROWSER SOFTWARE TO REJECT TRACKING TECHNOLOGIES, BUT, IF YOU DO SO, CERTAIN FUNCTIONALITY OF THE SITE MAY BE AFFECTED.

Security of the Information You Provide

Among our top priorities is keeping the information you provide to us secure. We use the latest Secure Sockets Layer (SSL) technology to encrypt all of the information that you provide to us before it is transmitted to us so that it can be safeguarded as much as possible from being read or recorded as it travels over the Internet. You can tell you are sending information securely by the unbroken key icon or closed lock icon that appears at the bottom of your Internet browser’s window. These icons will appear when you are placing an order on our Site. In addition, you will see “https:” indicating a secure server connection is being used. The computers that store the information you provide to us are located in a separate facility which employs firewall and security technology. We employ these procedures to help protect that information from unauthorized access, destruction, use, modification or disclosure.

You may be able to create an account on our Site with a username and password, including your interest profile and demographic information. We recommend you exercise extreme care in protecting your password information and do not publicly share any of your passwords. You are responsible for maintaining the strict confidentiality of your account password, and you are responsible for any access to or use of the Site by you or another person or entity using your password, whether or not such access or use has been authorized by or on behalf of you.

Information that you provide to us will be stored and processed on our computers in the United States. We will use commercially reasonable efforts to hold and transmit the information that you provide to us in a safe, confidential and secure environment. If you object to the information that you provide to us being transferred or used in this manner please do not register with or use the Site.

ALTHOUGH WE WILL TAKE REASONABLE SECURITY PRECAUTIONS TO PROTECT THE INFORMATION THAT YOU PROVIDE TO US, BECAUSE OF THE OPEN NATURE OF THE INTERNET, WE CANNOT GUARANTEE THAT SUCH INFORMATION STORED ON SERVERS SUPPORTING THIS SITE, TRANSMITTED TO OR FROM A USER, OR OTHERWISE IN OUR CARE (OR OUR THIRD-PARTY PROVIDERS’ CARE) WILL BE ABSOLUTELY SAFE FROM INTRUSION BY OTHERS, SUCH AS HACKERS. BY USING THE SITE, YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND AGREE TO ASSUME THESE RISKS.

Your Right to Be Informed:
How Do We Use the Information that You Provide and We Collect?

We collect information from you for the purposes of fulfilling registration transactions and tracking your progress as you complete a course and for a statistical analysis of your usage and progress, for content improvement, for protection against fraud and error, and to customize the content and layout of the Site (collectively, ‘Information Usage Purposes’). In performing the Information Usage Purposes, we may combine information we collect on the Site with information we receive from other sources. We do not sell the information that you provide to us and we do not disclose such information to any other party, except as set forth in this Privacy Policy. Unless otherwise provided in this Privacy Policy, information that you transmit to the Site or that we collect from the Site will be treated as non-confidential and non-proprietary and you agree that we may use any such information (together with any ideas, concepts, know-how, or techniques contained therein) in any manner, for any purpose, without credit or compensation to you.

Transfer of Your Information

If we merge, or sell or otherwise transfer our assets, Site or operations, we may disclose or transfer your information in connection with such transaction.

How to Opt-Out

The Site(s) will only send e-mail in conjunction with the purpose of the site, for customer service purposes, reminders, expiration notices, etc.  To opt-out of these notifications, please contact the “Owner” of the Site you are accessing.

Release of Information to Protect Our Site and Others

We may release the information that you provide us when we believe, in good faith, that such release is necessary to comply with the law, protect the rights, properties or safety of our Sites, our Users or others, or enforce or apply the terms of any of our user agreements.

Your Account Access Rights

You may review and make changes to the information that you provide us that is stored in your user account on the Site by visiting the ‘My Profile’ or ‘Profile’ area of the Site. Please note, if a third party integration was used to help facilitate auto-registration or entry, some Profile fields may not be editable.

Your Right To Rectification

All Users have access to the personal data/information that is stored on the Site.  Users may access this data and edit it by logging into the Site and navigating to the “Profile” page.  If there is any data that is not accurate and is not accessible to the User, please contact jvolentine@commpartners.com  CommPartners will respond to your request within 30 days.

Your Right to Erasure

All User data is stored for the duration that the account is active.  If you wish to have your account erased, please contact the “Owner” of the Site and ask for your records to be erased.  Keep in mind, this request will erase ALL current and historical data related to you.  This data includes all Personal Data as well as registrations, course completions, certifications, poll responses, assignments as well as any other activity data related to the courses/content that you have had access to.  If the “Owner” of the Site does not respond to your request within 30 days, please contact jvolentine@commpartners.com

Intended Users; Use by Children Under 18

The Site(s) is not purposefully directed at children under the age of 18 and all products available for sale on the Site are intended to be purchased by adults. We do not collect or maintain information, via the Site or otherwise, from those we actually know are children under 18 years of age. If you notify us that information has been provided by a child under the age of 18, upon verification, we will promptly delete such information.

Third Party Ad Servers; Links to Other Web Sites

The Site may contain links to other web sites that are not under our control. These links may include the use of so-called ‘share links.’ A ‘share link’ is a button and/or text link appearing on our Site that enables the launch of a sharing mechanism whereby you can post links to, and content from, the Site onto social networking web sites such as Facebook. The privacy policies of other web site operators or advertisers may significantly differ from our Privacy Policy. We urge you to read the privacy statements of each and every web site you visit and to contact the third-party Web site operators or advertisers directly if you have any questions or concerns about their data collection or privacy policies.

How We Respond to Do Not Track Signals

We do not currently recognize automated browser signals regarding tracking mechanisms, which may include ‘Do Not Track’ instructions. You can change your privacy preferences regarding the use of Tracking Technologies through your browser. However, as noted above in the Site Usage Information section, if you do adjust your privacy preferences, certain functionality of the site may be affected. For more information on Do Not Track please visit http://www.allaboutdnt.org

What is our Refund Policy?

Refund decisions are made by individual Site licensees.  Please refer to their Policy Statements.

Who created and owns ElevateLMS Software as a Service application?

Commpartners created, owns and maintains the software code that powers all ElevateLMS Sites. Feel free to visit them at http://www.commpartners.com

How to contact CommPartners:

CommPartners
7230 Lee Deforest Drive
Columbia, MD 21046