PRIVACY POLICY

Effective July 2016.

CBT Nuggets, LLC, a Delaware limited liability company is, located at 1550 Valley River Drive, Eugene, OR 97401, USA (referred to as “us”, “our”, “we”, “Company”, “CBT Nuggets”). We are committed to protecting and respecting your privacy. This Privacy Policy describes the types of information we may collect from you or that you may provide to us when you visit CBT Nuggets’ website located at https://www.cbtnuggets.com (the “Website”) or the CBT Nuggets mobile application (“App”) (collectively the “Services”), and our practices for collecting, using, maintaining, protecting and disclosing such information. This Privacy Policy applies to information we collect: (i) through the Services, (ii) in text and electronic messages between you and our Services, and (iii) via mobile applications you download from the Website or via third party vendors, which provide dedicated non-browser-based interactions between you and the Services. This Privacy Policy does not apply to any information collected by us offline or via third-party sites that may be accessed through hyperlinks on the Services.

By accessing or using the Services, you expressly agree to this Privacy Policy.
Please read the information below:

  1. YOUR CALIFORNIA PRIVACY RIGHTS
  2. Information we collect about you
  3. Where we store data
  4. How we use your information
  5. Disclosure of your information
  6. Updating or correcting your personally identifiable information
  7. Canceling your account or deleting your personally identifiable information
  8. Choices regarding control of your personally identifiable information
  9. Data Security
  10. Cookies
  11. Mobile Analytics
  12. Links to third party web sites and advertisers
  13. Changes to this Privacy Policy
  14. Communities, forums, chat rooms, and message boards
  15. How do you contact us with questions?

1. NOTICE TO CALIFORNIA RESIDENTS - “YOUR CALIFORNIA PRIVACY RIGHTS”
If you are a California resident and have provided us with any PII, California law gives you the right to request and receive from us, once per calendar year, information as to how we have shared your PII with third parties for their direct marketing purposes If applicable, such information would include a list of names and addresses of all third parties with whom such information was shared during the prior calendar year as well as a list of the categories of Personally Identifiable Information shared. To make such a request, please send an email to [email protected] and specify “California Privacy Request” in the subject line. Your request must also include your name, physical mailing address and email address. We will respond to you within thirty days of receiving such a request.

2. INFORMATION WE COLLECT ABOUT YOU
We collect several types of information about visitors and/or users of the Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Website or App.

(a) Personally Identifiable Information. ‘Personally Identifiable Information’ (“PII”) refers to information by which you may be personally identified, such as your name, email address, billing address, company, organization or school. We collect and process such data when you create an account. The relevant data is keyed into a secure webform through third party, cloud based services, via an encrypted session (https/tls). All data entered into this form is temporarily cached in third party cloud service provider’s memory only. There is no data at rest or long-term storage of any PII. The data is sent directly from the cloud service provider to the third party payment gateway service utilized by CBT Nuggets. The data in transit is encrypted.

When creating an account through the Website or App, you may also be asked to provide a credit card number and other payment-related information. Currently, CBT Nuggets’ cardholder dataflow includes only secure web transactions that transmit cardholder data to a third-party payment gateway provider. Electronic storage of cardholder data is not conducted or permitted.

You may also voluntarily provide information to be published or displayed (collectively “posted”) on public areas of the Website (such as blogs, forums, message boards, and the CBT Nuggets community), or transmitted to other users of the Website using ‘sharing’ features (collectively “User Contributions”). Your User Contributions are posted and transmitted to others at your own risk. CBT Nuggets cannot control the actions of other users of the Website with whom you may choose to share your User Contributions.

CBT Nuggets expressly discourages any customers from sending or transmitting any PII via any unsecure networks or channels, including, but not limited to, any customer primary account number (“PAN”) or other cardholder data. You assume any and all risk associated with such transmissions.

We may also collect your Internet Protocol (‘IP’) address. We use your IP address to diagnose problems with our servers, software, to administer our Services and to gather statistical information on country of origin.

We do not collect more Personally Identifiable Information than is reasonably necessary to participate in an activity on the Website.

(b) Non-Personally Identifiable Information. We may collect, or our third party ad server and/or content server may collect, certain Non-Personally Identifiable Information (“Non-PII”), that does not by itself identify a specific individual. Such information tells us about your equipment, browsing actions, the resources that you access and use through the Services, your operating system and browser type. The information that we collect automatically is ‘statistical’ in nature. It helps us to deliver a better and more personalized service to users, by enabling us to estimate usage patterns, customize our Services according to your individual preferences, and speed up your searches.

(c) Device Information. When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best application version to provide you with.

3. WHERE WE STORE DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. CBT Nuggets will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

4. HOW WE USE YOUR INFORMATION
CBT Nuggets uses information held about you in the following ways:

  • To ensure that content from the Services is presented in the most effective manner for you and for your computer or mobile device;
  • To provide you with information, products or services that you request from us or which we feel may interest you;
  • To carry out our obligations arising from any agreements or contracts entered into between you and us, including for billing and collection efforts (as applicable);
  • If you pay for the Services using a credit card, our cloud services will transmit your credit card data to the payment gateway service;
  • To allow you to participate in interactive features of the Services, when you choose to do so;
  • To notify you about changes to the Services, including updates to video and Website content; and
  • In any other way we may describe when you provide the information.
If you are an existing customer, we will only contact you by e-mail or telephone with information about renewing the Services.

If you use the Contact Us form on our site, we will keep a record of any information entered for internal purposes only. This information is not provided to any third parties. Additionally, this information will not be used for marketing communications from CBT Nuggets unless otherwise specified in an active account.

5. DISCLOSURE OF YOUR INFORMATION
We will share your Personally Identifiable Information with third parties only in the ways that are described in this Privacy Policy. We do not sell, trade, rent or disclose your information to others, except as provided herein:

(a) CBT Nuggets provides certain aspects of our Services through contractual arrangements with service providers and other third parties. In specific, and limited circumstances, CBT Nuggets and certain service partners use your PII to to deliver the Services. For example, the payment gateway service provider must have access to the financial card information, including PAN, to validate payment for the Services.

(b) Except as provided herein, CBT Nuggets will disclose PII in the following limited circumstances: (i) if required by law enforcement or state or federal court order or subpoena; (ii) if CBT Nuggets has a good faith belief that we are required or permitted to pursuant to governing law; (iii) to protect the rights, reputation, property or safety of CBT Nuggets, or its officers, agents, or employees; (iv) to defend or enforce our rights or your obligations; (v) if the disclosure is required by mandatory professional standards; (vi) to a third party with your prior consent to do so; or (vii) if we are under a duty to disclose or share your PII in order to enforce or apply any contracts or agreement that may exist between you and CBT Nuggets including this Privacy Policy or CBT Nuggets’ License Agreement. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

(c) In the event that CBT Nuggets decides to sell all or part of its membership interest or assets or enters into a merger, the CBT Nuggets expressly reserves the right to include PII and Non-PII among the assets transferred to the acquiring or surviving company.

(d) We may provide Non-PII about our customers’ sales, traffic patterns, and related Website information to third party advertisers.

For a list of third parties and the information that may be shared with or collected by them please click here: CBT Nuggets Third Parties

If you have any inquiries regarding our privacy practices, please contact us directly at [email protected].

6. UPDATING OR CORRECTING YOUR PERSONALLY IDENTIFYING INFORMATION
You may change any of your PII online by logging into ‘My Account’ through the Website.You may also change your personal information and privacy preferences by emailing us at [email protected] or [email protected].

You may ask to have your account disabled; however, you will not be able to delete information associated with past transactions on this Website. In addition, we cannot completely delete your information as some data may rest in previous backups. Financial information retained through the Website is never more than last four of card number, name, and expiration date.

7. CANCELING YOUR SUBSCRIPTION
If you are an active CBT Nuggets customer and would like to cancel your subscription, you can log into your account and select ‘My Account’ then ‘Subscription’. You can also contact your sales representatives (as applicable) or contact [email protected].

Due to CBT Nuggets offering an unpaid service by way of a ‘free-trial’ or ‘free-week’ we reserve the right to retain limited personal information for fraud prevention purposes. This may include information provided during the sign-up process such as name, address and phone number. We also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For security purposes, CBT Nuggets reserves the right to reset passwords for inactive accounts.

8. CHOICES REGARDING CONTROL OF YOUR PERSONALLY IDENTIFIABLE INFORMATION
Through the Website you can access information regarding your recent orders, PII, communication preferences; and payment settings.

With respect to your communication preferences, you can unsubscribe from CBT Nuggets email communications by following the unsubscribe instructions included in the email you receive or you can log into your account and update your preferences under “Notifications.” If you change your email address, you will need to access your account and update it accordingly.

Based upon your Notification preferences for your account, we may occasionally send you direct email about CBT Nuggets products and services that we feel may be of interest to you. Only CBT Nuggets will send you these emails. You may ‘opt-out’ of these messages after which you will no longer receive them.

We do not send unsolicited commercial emails or spam. We offer commercial email recipients the opportunity to opt-out of further communications in every email, with the exception of non-commercial Service emails regarding any Service order you place.

9. DATA SECURITY
Certain information you provide to us, such as name, address and telephone number, is stored on our secure servers hosted at Amazon Web Services. Any payment transactions made on our website will be encrypted using Transport Layer Security (“TLS”). We do not store financial card data or PANs on our servers. A PCI compliant payment gateway service is responsible for long term storage of all customer financial data.

To make online purchases you must use an TLS-enabled browser in order to protect the confidentiality of your personal and credit card information, including any PAN, while it is transmitted over the Internet.

Access to your account is granted through a password and unique username you select. This password is encrypted. CBT Nuggets expressly recommends that you do not divulge your password, that you change your password often using a combination of letters, numbers and symbols, and that you ensure access through a secure web browser. CBT Nuggets shall not be held accountable for any adverse effects or activity resulting from your own neglect to safeguard the secrecy of your password and username. If you share a computer, you should always logout of your account after you are finished, in order to prevent access to your information from subsequent users of that computer.

If your password or username is compromised, please notify us as soon as possible by calling (888) 888-507-6283 (for United States domestic calls) or (541) 284-5522 (for international calls) for assistance, or email [email protected].

Unfortunately, no online data transmission can be fully guaranteed to be secure. Thus, by accessing the Website and/or utilizing the Services, you acknowledge that: (a) there are online security and privacy limitations that are beyond CBT Nuggets’ control; (b) the security, integrity and privacy of any and all information and data exchanged between you and CBT Nuggets through the Website cannot be fully guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information not resulting from the direct fault or negligence of CBT Nuggets; and (c) any such information and data may be viewed or tampered with in transit by a third party.

If we believe that the security of your PII in our control or the control of identified service providers may be compromised, we will notify you as promptly as possible under the circumstances. To the extent we have your email address, we may notify you by email and you consent to our use of email as a means of such notification.

10. COOKIES AND OTHER TECHNOLOGIES
When accessing the Website, we may use cookies and other technologies in order to facilitate and customize your use of the Services.

What is a cookie? A cookie is a small data text file, which a website stores on your computer or mobile device (if your browser permits) that can later be retrieved to identify you to us. The cookies enable more efficient use of the Website, including making the Website run more smoothly and saving your logged-in state so that you do not have to login each time that you visit the Website. You may disable and/or delete all types of cookies by using your browser settings. Depending on which browser you use, Cookies are generally easy to disable and/or delete.

We partner with third party ad networks to manage our advertising on other sites. As part of their service, they use cookies and tracking pixels. We will not provide any third-party ad server with any of your PII or purchase/order information. We and our third party ad server will collect and use your IP address and certain Non-PII about you, such as your browser type, the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular advertisement.

11. MOBILE ANALYTICS
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often the app is used, events that occur within the app, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any PII you submit within the App. Analytics data cannot be linked with an individual user with exception to crash-reports. The crash-report may be used to identify the mobile device and account for further troubleshooting by software developers.

12. LINKS TO THIRD PARTY WEB SITES AND ADVERTISERS
Except as otherwise expressly provided, this Privacy Policy only addresses the use and disclosure of information CBT Nuggets collects from you. The Website may contain hyperlinks to other third-party web sites, which may collect and disclose information in a manner not consistent with this Privacy Policy, and such collection and disclosure would be governed by that website’s privacy policy, and any questions or concerns should be directed to that company’s site administrator or provided contact information. We are not responsible for the collection, use, or disclosure of information collected through any third-party web sites, and we expressly disclaim any and all liability related to such collection, use, or disclosure.

13. CHANGES TO THIS PRIVACY POLICY
CBT Nuggets shall post any revisions to this Privacy Policy on this web page link. The Effective Date this Privacy Policy version is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Website and this Privacy Policy to check for any changes.

Your continued use of the Services after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by the modified Privacy Policy.

14. COMMUNITIES, FORUMS, CHAT ROOMS, AND MESSAGE BOARDS
Any PII that you voluntarily disclose on any Website communities, message boards, forums, and blogs may be collected, accessed and used by third parties and may result in unsolicited messages from third parties. CBT Nuggets is unable to govern any third party’s use of PII that you voluntarily disclose or publish. To request removal of your PII from our blog or community forum, please contact us at [email protected], however note that although CBT Nuggets can remove the PII you posted or published to any such public or Website forum, CBT Nuggets has no ability to delete any copy of the PII made by any third party after your disclosure.

You acknowledge and accept that any submissions to chat rooms or other public areas on the Websites are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for all activity conducted by you via communities, forums, message boards, chat rooms, blogs etc.

CBT Nuggets expressly discourages any customers from sending or transmitting any PII via any unsecure networks or channels, including, but not limited to, any customer primary account number (“PAN”) or other cardholder data. You assume any and all risk associated with such transmissions.

15. HOW DO YOU CONTACT US WITH QUESTIONS?
If you have any questions about this Privacy Policy please contact us by email at [email protected] or by sending a letter to:

CBT Nuggets, LLC
Attn: Legal Department
1550 Valley River Drive
Eugene, OR 97401