Privacy Policy

Personal Information We Collect

We collect personal information about you in the following ways:

Information you give us

Personal information that you may provide through the Services or otherwise communicate with us includes:

• Personal and Business Contact information, such as your first name, last name, postal address, email address, telephone number, job title, and employer name;
• Profile information, such as your username and password; 
• Feedback, correspondence and reviews, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Sites, receive customer support or otherwise correspond with us, or reviews of the Services, including audiobooks that we offer for download through the Sites;
• Transaction information, such as details about purchases you make through the Sites, registrations you make through the Sites, and billing details (please note that all information relating to payments for our Services and Products is collected, stored and processed by Braintree, our payment processor. We do not collect or store card numbers or other payment information. All payment information you provide to us will be stored in accordance with the Braintree privacy policy, which you should read carefully);
• Usage information, such as information about how you use the Sites and interact with us;
• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;

Information from Social Networking Sites. Our Sites include interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Sites you authorise us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Notice. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information We Get from Others. We may also get information about you from other sources, for example through our analytics providers, and we may add this to information we get from our Sites or the Services. 

Information automatically collected

We may automatically log information about you and your computer or mobile device when you access our Sites. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Sites, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Sites.  We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section for more details.

Automated Decision Making.

We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.

Changes to your personal information

It is important that the personal information we hold about you is accurate and current.  Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at [email protected]– Send E-mail.  

Cookies and Similar Technologies

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.  

We use two broad categories of cookies:

•        first party cookies, served directly by us to your computer or mobile device; and

•        third party cookies, which are served by our partners or service providers on our Sites.

Cookies we use

Our Sites use the following types of cookies for the purposes set out below:

Type of cookie	Purpose
Essential Cookies	These cookies are essential to provide you with services available through our Sites and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies	These cookies allow our Sites to remember choices you make when you use our Sites. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered may include the number of visitors to our Sites, the websites that referred them to our Site, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information.  We use this information to help operate our Sites more efficiently, to gather broad demographic information, monitor the level of activity on our Sites, and improve the Sites.We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies hereMore information about Google analytics cookiesMore information about Google analytics cookies and about how Google protects your data hereLearn about how Google protects your dataLearn about how Google protects your data.
Targeted and advertising cookies	These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.
Social Media Cookies	These cookies are used when you share information using a social media sharing button or “like” button on our Sites or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings.  

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available herePrevent Google from tracking you, extensionPrevent Google from tracking you, extension.

Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Sites to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can manage our content more effectively.

How We Use Your Personal Information

To provide our Services

If you have a Company account or use our Sites, we use your personal information to:

• operate, maintain, administer and improve the Sites;
• manage and communicate with you regarding your Company account, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
• process and manage registrations you make through the Sites, including to track and administer trainings you have registered for and attended;
• better understand your needs and interests, and personalize your experience with the Sites; and
• provide support and maintenance for the Sites and our services;
• respond to your service-related requests, questions and feedback.

To communicate with you

If you request information from us, register on the Sites, or participate in our surveys, promotions or events, we may send you Company-related marketing communications as permitted by law (including audiobook recommendations). You will have the ability to opt out of such communications.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent

We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Sites, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.  

To create anonymous data for analytics

We may create anonymous data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.  

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share your Personal Information

Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations.  We disclose personal information to third parties under the following circumstances:

• Affiliates.  We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.  
• Service Providers. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as training, customer support, hosting, email delivery, email marketing, payment processing, analytics and database management services). These third parties may use your information only as directed by Company and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
• Professional advisors.  We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
• Compliance with Laws and Law Enforcement; Protection and Safety. Company may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
• Business Transfers. Company may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Choices

Access, Update, Correct or Delete Your Information

All Company account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. Company account holders may also contact us at [email protected] to accomplish the foregoing or if you have additional requests or questions.

Marketing communications

You may opt out of marketing-related emails by clicking on a link at the bottom of each such email, or by contacting us at [email protected].  You may continue to receive service-related and other non-marketing emails.

Testimonials
If you gave us consent to post a testimonial or review on our Sites, but wish to update or delete it, please contact us.

Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account.  We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.

Security

The security of your personal information important to us.  We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it.  However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

Children

Our Sites are not directed to children under 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

Sensitive Personal Data

We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Sites or otherwise to us.

If you send or disclose any sensitive personal data to us when you use the Site, you must consent to our processing and use of such sensitive personal data in accordance with this Notice. If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data to our Site.

International Transfer

Company is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

European Union users should read the important information provided hereImportant transfer information for European Union users about transfer of personal information outside of the European Economic Area.

Other Sites and Services

The Sites may contain links to other websites and services.  These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

User Generated Content

We may make available on our Sites, or link to, features that allow you to share information online, namely through reviews of our Services and audiobooks. Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Service that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Sites – or a specific announcement on this page or on our blog).

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at [email protected]

Additional Information for European Union Users

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller and EU Representative

Company is the controller of your personal information for purposes of European data protection legislation.  See the Contact Us section above for contact details.

As we do not have an establishment in the European Union, we have appointed a representative based in the United Kingdom, who you may address to raise any issues or queries you may have relating to our processing of your Personal Data and/or this Privacy Policy more generally.

Our EU representative is: W.F Howes Ltd. Our EU representative can be contacted directly by emailing them at the following address: [email protected]. 

Legal bases for processing

We only use your personal information as permitted by law.  We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below.  If you have questions about the legal basis of how we process your personal information, contact us.

Processing purpose (click link for details)	Legal basis
To provide the Services	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.
To communicate with you To create anonymous data for analytics  For compliance, fraud prevention and safety	These processing activities are carried out in pursuit of our legitimate interests in improving, marketing and monitoring the Sites and Services and keeping them safe and secure for you and other users.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with law	Processing is necessary to comply with our legal obligations
With your consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at [email protected].

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and

Transaction Information) for six years after they cease being customers for tax purposes.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out. Stop sending you direct marketing communications.  You may continue to receive service-related and other non-marketing emails.
• Access.  Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct.  Update or correct inaccuracies in your personal information.
• Delete.  Delete your personal information.
• Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict.  Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.  

You can submit these requests by email to [email protected] or our postal address provided above.  We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request.  If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction.  You can find your data protection regulator hereFind Your Data Protection RegulatorFind Your Data Protection Regulator.  

Data Transfers

We are a U.S.-based company. Although we do not have an establishment within the European Economic Area (“Europe”), because we target the Site at individuals who are located in Europe, the GDPR (which is a European piece of data protection legislation) applies to us.

For this reason, we take appropriate steps to ensure that when we process your Personal Data (despite the fact that we are not based in Europe) we do so in accordance with the GDPR.

In addition, where we transfer your Personal Data to any of the third parties outlined above, we also take appropriate steps to ensure that we have implemented appropriate safeguards to ensure that such protection is maintained and is not undermined as a result of that disclosure.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.