Online Tech Study for Business Privacy Statement

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Online Tech Study for Business Privacy Statement

This Online Tech Study For Business Privacy Statement was updated on June 30, 2019.

In the course of providing Online Tech Study for Business ( “OTSFB”) services and related services to its corporate, non-profit organization and governmental customers ( “Customers”), Online Tech Study will receive and have access to personal data of individual users to whom customers grant access ( “Users”). For the purposes of this privacy statement, Customers are data controllers and Online Tech Study is a data processor. Online Tech Study’s processing of User data and the security measures implemented to protect such data are detailed in and governed by a written agreement between Online Tech Study and each of its Customers.

As a data processor, Online Tech Study will access, store and use the personal data of individual Users solely for the purpose of providing the OTSFB services to its Customers and will process the data as instructed by its Customers.

As data controllers, Customers decide which of their employees or other authorized personnel are given access to the OTSFB services. They do this by designating one or more OTSFB account administrators or group administrators ( “Administrator”) who have the ability to customize the Customer account, manage individual User accounts, access the OTSFB Insights tool and related reporting features, access the OTSFB Administrator tools, and, when instructed by the Customer, populate the Customer account with Customer-provided courses. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, relating to the collection of personal information relating to individual Users selected by Customers for accessing the OTSFB services. Online Tech Study has no direct relationship with individual Users, who should contact Customers (their employer) for assistance with any requests or questions relating to the processing of their personal information.

For avoidance of doubt, this Privacy Statement does not apply to:

1. any processing of data for the purpose of marketing the OTSFB service to enterprise and corporate prospects;


2. any other offerings available at Online Tech Study.com separate from the OTSFB services, for which the Online Tech Study Privacy Policy is applicable. A User may already have a account with Online Tech Study to access Online Tech Study’s marketplace educational content, and data processed as a result of the use of the Online Tech Study marketplace from a User account is governed by the Online Tech Study Privacy Policy.

In the event where Online Tech Study makes any material changes to the manner in which it processes User data to provide its services to Customers, it will notify Customers.

Online Tech Study for Business Privacy Statement

1. 
   Information about Users collected and stored by Online Tech Study
   


2. 
   Purpose of User Data Processing
   


3. 
   Cookies and other Tracking Technologies
   


4. 
   Sharing User Information with Sub-Processors
   


5. 
   Processing of User Data outside of the EEA
   

1. Information about Users collected and stored by Online Tech Study

1. When a User is given access to the OTSFB services by the Administrator, a User may set up an individual User account and Online Tech Study will collect information provided by the User or the Administrator. The Customer can customize the type of data requested to create an account, which may include the following:
   
   
   • first name, last name, and email address required
   
   
   • photo, areas of interest, job skills, goals, and role (optionally provided by User or Customer)
   
   
   • other personal data, as allowed by the Customer
   
   
   A unique identifying number is assigned by Online Tech Study upon the creation of a User account.


2. Individual User account information may be set to private or public, as selected by Users. If set to public, the information is searchable via search engines and viewable by anyone, including by other Users and the Customer.


3. Administrators may assign a User to a group membership


4. Customers may select to integrate with OTSFB a Single Sign On (SSO) identity provider to enable Users to log in to OTSFB User accounts without the need to disclose passwords to Online Tech Study. In such case Users may log in by providing their individual SSO credentials to the SSO identity provider, which will authenticate them and allow or deny access to the Customer account. In such case, SSO identity providers share with Online Tech Study a unique cookie ID and authentication “token” information to recognize the User as an authorized user of Customer.


5. At the option of the Customer, the OTSFB service may enable Administrators and Users to interact with others, including with instructors, teaching assistants, other students, and the Customer, by posting reviews on a course, sending messages to or chatting with others, posting questions or answers, or posting other content. Such public or shared content is stored by Online Tech Study and may be publicly available or viewable by others, including Administrators, Users, or instructors and teaching assistants, depending on where such content is posted.


6. Online Tech Study stores information relating to the activities of Users as they use and interact with the OTSFB services, such as courses enrolled in and viewed (and information relating to these courses); interactions with instructors, teaching assistants, Administrators, and other Users; and progress within a course; as well as answers, essays and other items submitted by Users to satisfy the course requirements. This information is linked to a User’s unique account ID and is shared with Customers via the Customer Account reporting tools or upon request of the Customer.


7. The OTSFB service enables Users to contact the Online Tech Study Support Team for assistance or to report a problem, concern, potential abuse or other issues regarding the OTSFB services or other users. Online Tech Study may collect and store the User’s name, email address, location, operating system, IP address as well as the User’s activity on the Online Tech Study platform and communications with the Online Tech Study help desk team. Online Tech Study may request additional information from Users in order to resolve any issue reported by a User or by another user.


8. When a User uses the OTSFB services, Online Tech Study collects and stores certain information by automated means: (a) technical information about the User’s computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain, and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies, such as: (i) cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and (ii) other tracking technologies (see below for more detailed information).


9. IP addresses received from browsers or devices of Users may be used to determine the approximate location of Users.


10. If a Customer makes purchases via credit card, Online Tech Study collects certain data about the purchase (such as name and zip code) as necessary to process the order. Customers must provide certain payment and billing data directly to Online Tech Study’s payment processing partners, including name, credit card information, billing address, and zip code. For security, Online Tech Study does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

2. Purpose of User Data Processing and Retention Period

Online Tech Study processes the information collected about Users and Administrators for the purpose of providing the OTSFB services to its Customers, specifically:

• Providing, administering, and facilitating access to the OTSFB services, for Customers and Users, and managing Customer or User account preferences


• Fulfilling Customer’s instructions with respect to personal data of Users


• Displaying and sending via email notifications to Users for:
  
  
  • Responding to User questions or concerns
  
  
  • Making notifications to Users at the request of the Customer
  
  
  • Sending Users administrative messages and information, including confirmation of account creation, course enrolment, course progress and notifications of responses from instructions to User questions
  
  
  • Providing information to Users about courses available to Users, available and new OTSFB service features; personalized course recommendations, which Users can opt out of at any time
  
  
  • Sending push notifications to User wireless devices to provide updates and other relevant messages, which can be managed from the “options” or “settings” page for the mobile application.
  
  
  
  


• Enabling communications among Users and instructors or teaching assistants


• Soliciting feedback to improve OTSFB User experience


• Resolving User support requests or claims

Email Preferences

Users can individually opt out of receiving non-transactional emails by: (i) following the unsubscribe instructions provided in the email communication; or (ii) managing User account email preferences. A Customer can also instruct Online Tech Study to configure email preference settings for all Users of a Customer.

Retention of Personal Data

Online Tech Study will retain the data of Users for as long as instructed by the Customer. Online Tech Study will delete certain or all personal data relating to Users upon request of the Customer. Online Tech Study may retain aggregated or anonymized data as set forth below.

Use of aggregated data

In addition, User data is aggregated with other Online Tech Study marketplace user data to enable Online Tech Study to improve its products and services and develop new products and services, including:

• Reviewing and analyzing User browser and wireless device technical information


• Reviewing user activity across OTSFB and the Online Tech Study marketplace (for example, Online Tech Study analyzes trends and User traffic and usage information to identify which courses are most popular)


• Facilitating the technical functioning of the OTSFB services and Online Tech Study marketplace, including to troubleshoot and resolve issues, secure the OTSFB services, and prevent fraud and abuse


• Developing a personalized course content recommendation engine

When User data is used for the above purposes, it is aggregated and/or anonymized so that no personal data of Users is processed.

3. Cookies and other Tracking Technologies

Like many online platforms, Online Tech Study and its analytics vendors use server log files and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable Online Tech Study to understand how Users interact with the OTSFB services. Online Tech Study and its analytics vendors may tie the information gathered by these means to the unique account ID of Users.

Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about User activities. Online Tech Study uses both session cookies and persistent cookies.

• A session cookie is used to identify a particular visit to the OTSFB services and collect information about interaction with the OTSFB service. These cookies expire after a short time, or when the User closes their web browser after using the OTSFB service. Online Tech Study uses these cookies to identify a User during a single browsing session, such as when you log into the OTSFB services. This helps Online Tech Study improve the OTSFB service as well as improve the Users’ browsing experience.


• A persistent cookie will remain on a User’s device for a set period of time specified in the cookie. Online Tech Study uses these cookies to identify and recognize a specific User over a longer period of time. They allow Online Tech Study to:
  
  
  1. analyze the usage of the OTSFB services (e.g. what links Users click on) in order to improve our OTSFB offering
  
  
  2. test different versions of the OTSFB services to see which particular features or content Users prefer to optimize the OTSFB services
  
  
  3. provide a more personalized experience to Users with more relevant content and course recommendations and
  
  
  4. allow Users to more easily log in to use the OTSFB services. Persistent cookies include:
     
     
     • preferences cookies to remember information about a User’s browser and settings preferences, such as preferred language. Preference cookies make User experience more functional and customized
     
     
     • authentication and security cookies to enable a User to log in or stay logged in and access the OTSFB service, to protect User accounts against fraudulent log-ins by others, and help detect, fight, and protect against abuse or unauthorised usage of User accounts.
     
     
     • functional cookies to make the experience of using the OTSFB service better, like remembering the sound volume level selected by the User.
     
     
     
     
  
  
  
  

• Instructors who upload courses on the Online Tech Study platform and made available through the OTSFB services as well as their teaching assistants, who may receive names and account profile information of Users, to enable them to respond to user questions and feedback.


• Other service providers of Customer, as instructed by Customer.


• To perform its services, Online Tech Study leases servers from data centers. Online Tech Study also contracts with Amazon Web Services (AWS) for hosting services, and certain content and User data relating to OTSFB is hosted via AWS’s cloud hosting solutions.


• Online Tech Study’s help center platform vendor (Zendesk as of the effective date of this Privacy Statement) hosts and stores all communications between Administrators or Users and the Online Tech Study support team. Zendesk is contractually required to store and process User related data solely as directed by Online Tech Study for the purpose of providing services to Online Tech Study. Online Tech Study also partners with a chat messaging tool for support to Users and Administrators and for collecting their feedback, as well as in-app messages such as feature announcements or onboarding for new users.


• Online Tech Study shares User information with third party companies that perform email services to enable Online Tech Study to send email communications to Users and to manage email preference settings of Users.


• Administrators of existing Customers are able to access our list of current sub-processors on the left sidebar of this page while logged in to Online Tech Study for Business.


• Online Tech Study shares User information with third party companies that perform data analysis services to enable Online Tech Study to better understand how Users use the OTSFB service. To prevent Google Analytics from collecting information for analytics, a User may install the Google Analytics Opt-Out Browser by clicking here, and may also use Mixpanel’s opt out by clicking here.

Any other sharing of User data is subject to the consent and instructions of Customer.

5. Processing of User Data

All data processing described in this Privacy Statement occurs in the India. If personal data processed by Online Tech Study originates from a User or Administrator, Online Tech Study will ensure, that such processing will only take place if: (a) the any country in question ensures an adequate level of data protection; (b) the transfer is made pursuant to a Data Processing Agreement (“DPA”) executed between Online Tech Study and the Customer and subject to the standard contractual clauses designed to facilitate transfers of personal data to all third countries.