Last Updated: August 31, 2023
This Privacy Statement sets forth the information gathering, use, and dissemination practices of The Educe Group, Inc. (“Educe,” “we,” “us,” or “our”) as they regard consumers (“you” or “your”). We can be contacted by regular mail at 4550 Montgomery Avenue, Suite 980, Bethesda, MD 20814, by email at info@educegroup.com, or by phone at 301.215.7370.
Personal Information We Collect About You
We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
| Categories of Personal Information | Specific Types of Personal Information Collected |
|---|---|
| Identifiers (for example, a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifier) | First name, last name, company name, job title, email address, postal address, telephone number, IP address |
| Information that identifies, relates to, describes, or is capable of being associated with a particular individual, including, but not limited to, name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information | First name, last name, company name, job title, email address, postal address, telephone number, IP address |
| Commercial information (for example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | Information about Talent Management vendors used, purchasing interest in talent management software products & services, purchase history of Talent Management products & services |
| Internet or other electronic network activity information (such as browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement) | Pages visited, links clicked, non-sensitive text entered, mouse movements, referring URL, browser, operating system, Internet Protocol (“IP”) address, geographic region, forms completed |
| Professional or employment-related information | Company name, job title, department, business postal address, company phone number, company email address, reporting relationships (manager), purchase history |
2. How Your Personal Information is Collected.
We collect most of this personal information directly from you – whether in person, by telephone, text, or email, or via the Educe website located at educegroup.com. We may also collect information:
- From publicly accessible sources (for example, social media accounts)
- Directly from third parties (such as credit reporting agencies or customer due diligence providers)
- From a third party with your consent
- Via Educe’s IT systems and networks, including automated monitoring of Educe’s website and other technical systems and email systems.
Also, we may place Internet “cookies” on the hard drives of visitors to our website. Internet cookies save data about individual visitors, such as the screen preferences and the pages of a site viewed by the visitor. When the visitor revisits the website, we may recognize the visitor by the Internet cookie and customize the visitor’s experience accordingly. You may decline Internet cookies, if any, by using the appropriate feature of your web client software, if available.
When a visitor performs a search within the Educe website, we may record information identifying the visitor or linking the visitor to the search performed. We may also record limited information for every search request and use that information to solve technical problems with the services available directly or indirectly in connection with the website and to calculate overall usage statistics.
3. How and Why We Use Your Personal Information.
Personal data collected by us may be used for many reasons, for example, for editorial and feedback purposes, for marketing and promotional purposes, for a statistical analysis of visitors’ behavior, for product development, for content improvement, for fulfillment of a requested transaction or recordkeeping. Aggregate data on visitors’ home servers may be used for internal purposes, and individually identifying information, such as names, regular and e-mail addresses, phone numbers, and other personal information which you voluntarily provide to us may be added to our databases and used for future calls and mailings regarding website updates, product and service offerings, and upcoming and past events.
We also may use website visitor data to contact website visitors regarding changes to the website Terms of Use, this Privacy Statement, and any other policies, practices, or agreements relevant to website visitors. Identifiable or non-identifiable data also may be disclosed or distributed to another party with which Educe enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, or if determined by Educe in its sole judgment that such disclosure or distribution is appropriate to protect the life, health, or property of Educe or any other person or entity.
The following table additionally explains what we use (process) personal information for and the reasons for doing so.
| What Educe Uses Your Personal Information For | Our Reasons |
|---|---|
| To provide our (or our affiliates’) products or services to you | For the performance of our (or our affiliates’) contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you or us or our affiliates | For our legitimate interests or those of our affiliates or a third party, such as to minimize fraud that could be damaging for us and for you |
| Processing necessary to comply with professional, legal, and regulatory obligations that apply to our business or our affiliates, for example, under health and safety regulations or rules | To comply with legal obligations of ours or our affiliates |
| Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies | To comply with legal obligations of ours or our affiliates |
| Ensuring business policies are adhered to, such as policies covering security and Internet use | For our legitimate interests or those of our affiliates or a third party, for example, to make sure we are following our own internal procedures |
| Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of our affiliates or a third party, for example, to seek to be efficient in our delivery of products or services |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of our affiliates or a third party, such as to protect trade secrets and other commercially valuable information To comply with legal obligations of ours or our affiliates |
| Statistical analysis to help us manage our or our affiliates’ business, such in relation to financial performance, customer base, product or service range, or efficiency | For our legitimate interests or those of our affiliates or a third party |
| Preventing unauthorized access and modifications to systems | For our legitimate interests or those of our affiliates or a third party, for example, to prevent and detect criminal activity that could be damaging for us and/or for you To comply with legal obligations of ours or our affiliates |
| Updating and enhancing customer records | For the performance of our or an affiliate’s contract with you or to take steps at your request before entering into a contract To comply with legal obligations of ours or our affiliates For our legitimate interests or those of our affiliates or a third party, such as making sure that we can keep in touch with our customers about existing orders and additional products and services |
| Ensuring safe working practices, staff administration, and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, for example, to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services and those of our affiliates and selected third parties to existing and former customers, third parties who have previously expressed an interest in our services, and third parties with whom we have had no previous dealings | For our legitimate interests or those of our affiliates or a third party, such as to promote our business to existing, former, and prospective customers |
| External audits and quality checks, for example, for ISO accreditation and the audit of our accounts | For our legitimate interests or a those of our affiliates or a third party, such as to maintain our accreditations To comply with legal obligations of ours or our affiliates |
4. Opt-Out Right.
Except as necessary for us to provide the services, information, or products requested by you, you may opt out of having your personally identifiable information, which has been voluntarily provided to us, prospectively retained by us, used by us for secondary purposes, or prospectively disclosed by us to third parties by contacting us via regular mail, e-mail, or telephone at the addresses set out above. (This does not apply, for example, to collection of the type of web browser of visitors to our website or to information provided or collected that does not meet the above description.)
5. Who We Share Your Personal Information With.
We routinely share personal information with:
- Our affiliates
- Service providers we use to help deliver our products and/or services to you
- Other third parties we use to help us run our business, such as marketing agencies or website hosts
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with legal obligations of ours and our affiliates.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. The recipient of the information will be bound by confidentiality obligations.
While we may undertake efforts to see that any third party to which we share, rent, sell, or otherwise disclose personal data is under a contractual obligation to use the personal data solely for the purposes for which the data was disclosed, such third parties are independent third parties over which we exercise no control, and we are not responsible for their conduct, actions, omissions, or information handling or dissemination practices and we will not be liable therefor.
Our website may contain links to other websites or advertisements for or placed by third parties. Educe is not responsible for the privacy practices of such websites, advertisers, or third parties, or for the content of such sites or advertisements. It is possible that these links or advertisements, themselves, may be used by third parties or others to collect personal or other information about visitors from our website. It is solely the visitors’ obligation to review and understand the privacy practices and policies of these other websites and of these advertisers and third parties.
6. Personal Information We Sold or Disclosed for a Business Purpose.
We do not sell your personal information.
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name)
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number company affiliation, employment history,
- Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement)
- Professional or employment-related information
7. Where Your Personal Information is Held.
Information may be held at our offices and those of our affiliates, third party agencies, service providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information with”). Some of these third parties may be based outside the European Economic Area. (Please see the below section, Transferring Your Personal Information Out of the EEA.)
8. How Long Your Personal Information Will Be Kept.
We will keep your personal information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf
- To show that we treated you fairly
- To keep records required by law
We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Statement.
9. Transferring Your Personal Information Out of the EEA.
To deliver product or services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), for example,
- With our affiliates outside the EEA
- With your and our service providers located outside the EEA
- If you are based outside the EEA
- Where there is an international dimension to the services we are providing to you
These transfers are subject to special rules under European and/or UK data protection law. We may transfer personal information to countries that have been assessed by the European Commission as providing an adequate level of protection for personal information. When we transfer personal information to other non-EEA countries, we will seek to ensure the transfer complies with data protection law and that all personal information will be secure. We may do so, for example, buy using standard data protection contract clauses that have been approved by the European Commission.
If you would like further information, please contact us via regular mail, e-mail, or telephone at the addresses set out above.
10. Your Rights Under the GDPR.
If you are an individual whose personal data, and the processing of that personal data by us, are subject to the application of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), you have certain rights. These rights are identified below, along with a brief, non-exhaustive explanation. If your personal data and the processing of your personal data are not subject to the GDPR, the rights identified below do not necessarily apply.
| Rights | Non-exhaustive explanation |
|---|---|
| Right to Access | The right to be provided with a copy of your personal information (the right of access) |
| Right to Rectification | The right to require us to correct any mistakes in your personal information |
| Right to be Forgotten | The right to require us to delete your personal information – in certain situations |
| Right to Restriction of Processing | The right to require us to restrict processing of your personal information – in certain circumstances (for example, if you contest the accuracy of the data) |
| Right to Data Portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party –in certain situations |
| Right to Object | The right to object: (1) at any time to your personal information being processed for direct marketing (including profiling); (2) in certain other situations to our continued processing of your personal information, such as processing carried out for the purpose of our legitimate interests |
| Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
11. Your Rights Under the CCPA.
If you are an individual whose personal information, and the processing of that personal information by us, are subject to the application of the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”), you have certain rights. These rights are identified below, along with a brief, non-exhaustive explanation. If your personal data and the processing of your personal data are not subject to the CCPA, the rights identified below do not necessarily apply.
| Rights | Non-exhaustive explanation |
|---|---|
| Right to Know | You may request the following information covering the 12 months preceding our receipt of your request: (1) the categories of personal information we collected about you, and the categories of sources from which we collected your personal information; (2) the specific pieces of personal information we collected about you; (3) the business or commercial purposes for collecting personal information about you; (4) the categories of personal information that we disclosed about you, and the categories of third parties to whom the personal information was disclosed; and (5) the business or commercial purpose for our collection of your personal information |
| Right to Access | You can request a copy of the personal information that we have collected about you during the past 12 months |
| Right to Deletion | You may request that we delete your personal information (please note that deletion requests are subject to certain limitations, for example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, and consistent with our professional responsibility obligations) |
| Right to Non-Discrimination | If you exercise your CCPA rights, we will not unlawfully deny you services, charge you different prices or rates, or provide you with a different quality or level of service; if you ask us to delete your personal information, however, please be aware that it may impact our ability to provide our services to you, including our legal advisory services |
12. Keeping Your Personal Information Secure.
Educe has implemented and takes appropriate and commercially reasonable technical and organizational measures designed to protect personal data against unauthorized access, accidental loss or damage, and unauthorized destruction. Educe staff and third parties who handle personal data are required to treat it confidentially and are not permitted to not use or share it except as provided in this Policy Statement.
13. How to Exercise Your Rights.
If you would like to exercise any of your rights as described in this Privacy Statement, please:
- Complete a data subject request form available from us by contacting us via regular mail, e-mail, or telephone at the addresses set out below
- Call us at 301.215.7370
- Email us at info@educegroup.com
- Write to us at 4550 Montgomery Avenue, Suite 980, Bethesda, MD 20814
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by email, phone, or in writing, you will need to provide us with:
- Enough information to identify you
- Proof of your identity and address (such as a copy of your driving license or passport and a recent utility or credit card bill)
- A description of what right you want to exercise and the information to which your request relates
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
14. How to File a GDPR Complaint.
We hope that can resolve any query or concern you raise about our use of your information. The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
15. Changes to This Privacy Statement.
This Privacy Statement may be changed at any time. Notice of any new or revised Privacy Statement will be posted on this website page at least 30 days before the change. It is your obligation to visit this website to learn of changes to the Privacy Statement. Any change to this Privacy Statement shall be effective as to any person who was subject to the version of the Privacy Statement before the change was made.
