Argosy Publishing, Inc.，以Visible Body的名称开展经营（“公司”或“我们”），从事网络应用程序、桌面应用程序和移动应用程序的开发。公司重视我们应用程序之用户和其他个人（“您”）的信息和数据的隐私，我们可能会收集与您有关的信息用于识别您（您的“个人信息”）。本隐私声明阐述了有关我们收集和使用您的个人信息的政策和做法。如果您不同意本文规定的条款，请不要使用我们的网站或我们的网页版、桌面版和移动版应用程序。我们保留随时更新本隐私声明的权利；并且，以上修订日期为您提供隐私声明已更新的通知。
我们还使用第三方（例如Google Analytics）来帮助分析用户对本网站的使用情况。 Google为此目的使用了cookie并向我们提供汇总信息。
Courseware、Web Suite和某些移动应用程序用户的Visible Body帐户
如果您使用了我们的Courseware或Web Suite产品，将会需要您创建Visible Body帐户。此外，我们的某些移动应用程序可能会要求您创建Visible Body帐户，以便共享内容并跨设备访问您的用户创建的内容。在您创建Visible Body帐户时，我们会收集以下个人信息：
- 如果您索取有关我们的经销商或分销商出售的Visible Body产品的信息，会将您的个人信息披露给我们的授权经销商和分销商
除非本隐私声明中另有说明，本公司将保留个人信息，并保留到向您提供服务以及此后为遵守我们法律或合同义务所需的时长。 如果我们确定上述目的不再需要保留有关潜在客户的信息，我们会定期删除这些信息。经书面请求或在协议终止后的规定期限后，个人信息将从有效数据库中删除。备份中存储的信息不会被主动清除，而是随着时间自然清理。Visible Body保留个人信息备份的时间不会超过90天。
492 Old Connecticut Path, Suite 501
Framingham, MA 01701
对于受欧洲数据保护法律管辖的个人信息，Argosy Publishing, Inc.是这些个人信息的控制者。
EEA Privacy Disclosures
These privacy disclosures (the “Disclosures”) provide information about the collection, use, processing and sharing of data about individuals located in the European Union, Iceland, Liechtenstein or Norway (the “European Economic Area” or “EEA”).
These Disclosures also provide information about the collection, use, processing and sharing of data about individuals located in the United Kingdom, which has left the European Union but has adopted legislation substantially similar to the GDPR. With respect to individuals in the UK, references to the GDPR in these Disclosures are to be read as referring to the UK’s similar legislation, the Data Protection Act 2018.
In these Disclosures:
- GDPR means the European Union’s General Data Protection Regulation;
- Personal Data means information relating to an identified or identifiable individual; an identifiable individual is one who can be identified, directly or indirectly, by use of any identifier or factor specific to that individual; and
- GDPR Processing Activities means the collection, use, processing or sharing of Personal Data when those activities are within the scope of the GDPR.
These Disclosures apply only to the use of Personal Data in GDPR Processing Activities. In these Disclosures the words “Company,” “we,” “us” or “our” refer to Argosy Publishing, Inc. d/b/a Visible Body. These Disclosures apply to GDPR Processing Activities by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).
A. How We Collect and Use Personal Data
We collect several categories of Personal Data in circumstances that may involve GDPR Processing Activities, including data you provide, data collected automatically (potentially including location data), and data we obtain from third party sources.
We use the Personal Data that we collect to:
- Create and maintain your account;
- Process your account registration;
- Answer your questions;
- Send you newsletters, updates, and other communications that you have requested;
- Send you information about our services and resources; and
- If you use our products through your affiliation with an institution, such as a college or university, coordinate with the institution you are affiliated with, in order to track activation of applications and to provide learning management services.
As described in more detail below, we rely on a number of legal bases to lawfully process your Personal Data.
The ways in which we collect and use your data vary depending on the relationship between you and us. The following sections of these Disclosures describe in more detail how we collect and use Personal Data in various circumstances that may involve GDPR Processing Activities.
Please note that, depending on the situation, some of the processing of Personal Data we do in the various circumstances described below may not fall within the scope of the GDPR.
1. Personal Data We Collect
Websites and Mobile Applications
As is true of most digital platforms, we obtain certain data automatically when you use one of our websites or mobile applications, such as your IP address, browser type and device type. Certain web forms also collect Personal Data you provide, for example when you enter data into form fields, such as for the purpose of registration. If we also process data through our websites or mobile applications for one of the activities described further below, those descriptions will provide additional information about how those data are collected and used. We and our third-party vendors use this Personal Data for the primary purposes of conducting analytics, improving our websites, responding to your requests and providing you with relevant information.
2. Personal Data We Obtain from Third Party Sources
As part of our GDPR Processing Activities, we may obtain certain Personal Data about you from third party sources, which we may use for the purposes and in the ways described in “How We Collect and Use Personal Data” above and in “Additional Uses of Personal Data” below. In some cases, we may obtain your consent for additional uses.
Partners and Service Providers
We use partners and service providers to provide services for us. Some of these partners have access to Personal Data about you that we may not otherwise have (for example, when you sign up directly with that provider) and may share some or all of these data with us.
3. Additional Uses of Personal Data
In addition to the uses described above, including under “How We Collect and Use Information” and “Personal Data We Obtain from Third Party Sources,” we may use your Personal Data for the following purposes. These additional uses may under certain circumstances be based on your consent, or may be necessary to fulfill our contractual commitments to you, for legal compliance, or to serve our legitimate interest in the following activities:
- Conducting our operations and administering educational offerings;
- Responding to your requests for research assistance;
- Processing and responding to your requests or inquiries of any other kind;
- Providing you with newsletters, articles, service alerts or announcements, event invitations, and other information that we believe may be of interest to you;
- Conducting research, surveys and similar inquiries to help us understand trends and needs of our Members and customers;
- Performing marketing, promotions and advertising, either directly or through third-parties. These activities may include interest-based advertising, targeted advertising and online behavioral advertising in order to increase the likelihood that the content will be of interest to you;
- Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of Personal Data, our website or data systems; or
- Responding to subpoenas, court orders, or other legal process; enforcing our agreements; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.
4. Legitimate Interests
In addition to interests otherwise described in these Disclosures, we rely on other legitimate interests in using and sharing your Personal Data. These interests include:
- Providing, improving and customizing our educational offerings;
- Administering our operations;
- Furthering research and understanding in fields of academic study;
- Offering attendance to events and opportunities to participate;
- Understanding how our online platforms are being used;
- Exploring ways to develop and grow our operations;
- Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
- Meeting our obligations and enforcing our legal rights.
5. Data Retention
We will retain your Personal Data for as long as is necessary for the purposes set out in these Disclosures and for as long as is required under applicable law or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations. Consistent with the foregoing guidance, some data may be retained indefinitely.
Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased (see “Your Rights” below).
Where we are processing Personal Data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Where we are processing Personal Data based on the public interest, we generally retain the information for the period of time that continues to serve that underlying interest.
Where we are processing Personal Data based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects. In some cases, where Personal Data was primarily processed and retained on the basis of consent, contract, the public interest, or other bases described in these Disclosures, we may continue thereafter to retain the data based on a legitimate interest.
B. How We Share and Disclose Personal Data
We share your Personal Data with third parties in the ways described in these Disclosures, including the “How We Collect and Use Personal Data” section above. Additionally, we may share information as described below:
We share your Personal Data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:
- Marketing and analytics;
- Event registration and coordination;
- Providing course platforms or tools that enable or enhance our offerings;
- Research insights and analytics;
- Research collaboration;
- System maintenance and security;
- Facilitating other transactions with you; and
- Assisting with our legal compliance.
Social Media Platforms
Legal Process, Safety and Terms Enforcement
We may disclose your Personal Data to legal or government regulatory authorities as required by applicable law. We may also disclose your Personal Data to third parties in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.
C. International Data Transfers
Much of our Personal Data processing takes place in the United States, though sometimes we or third parties with whom we share data, as discussed above, may process data in other countries. The data privacy laws in the United States and other countries outside the EEA and the UK may provide less protection than such laws in the EEA or the UK. In the event we transfer your Personal Data outside the EEA or outside the UK as part of our GDPR Processing Activities, we rely where required on appropriate or suitable safeguards or specific derogations recognized under the GDPR or under UK law.
The European Commission has adopted standard data protection clauses, also applicable in the UK, which provide safeguards for Personal Data transferred outside of the EEA or the UK. We may use Standard Contractual Clauses when transferring Personal Data from a country in the EEA or from the UK to a country outside the EEA or the UK. If so and your Personal Data are affected, you can request a copy of the Standard Contractual Clauses relevant to your Personal Data by contacting us as set forth in the “Contact Us” section below.
D. Cookies and Similar Technologies
These small data files or graphic files serve various functions:
- Strictly Necessary: Necessary to deliver our services;
- Performance and Functionality: Enhance the performance and functionality of our services but are non-essential to their use;
- Analytics and Customization: Allow us to understand the effectiveness of our services and marketing campaigns, as well as to customize our services based on this information; or
- Advertising: Make advertising messages more relevant to you and your interests.
You can control the use of certain cookies and similar technologies by:
- Opting out of targeted online advertising through advertising networks (please visit http://www.aboutads.info/choices/, http://optout.networkadvertising.org/ or
http://www.youronlinechoices.com for more information);
E. Your Rights
Upon your reasonable, good faith request we will provide you with information about whether we hold any of your Personal Data as part of our GDPR Processing Activities, to the extent required by and in accordance with applicable law. In certain cases, you may also have a right, with respect to your Personal Data collected and used in the GDPR Processing Activities, to:
- correct or update any of your Personal Data that is inaccurate;
- restrict or limit the ways in which we use your Personal Data;
- object to the processing of your Personal Data;
- request the deletion of your Personal Data; and
- obtain a copy of your Personal Data in an easily accessible format.
To submit a request, please send an email message to firstname.lastname@example.org. Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we will ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.
Subject to certain legal limits, you also have the right to withdraw your consent to our processing of your Personal Data as part of our GDPR Processing Activities, where our processing is solely based on your consent. In some cases, you can do this by discontinuing use of the services involved in the GDPR Processing Activities. This would include by closing all of your online accounts with us and contacting us at email@example.com to request that your Personal Data be deleted. If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures or the other Visible Body privacy statements that link to or expressly adopt these Disclosures, you may not have access to some or all of the related services, and we might not be able to provide you some or all of the services. Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent and requested that we delete your Personal Data, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure or to safeguard our rights or the rights or safety of others.
If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority (i.e., supervisory authority).
F. User Generated Content
Some of our online activities enable users to submit their own content. Please remember that any Personal Data you submit or post as user-generated content in these circumstances could in some cases be seen by others or become public. You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts. We cannot prevent others from using that information in a manner that may violate these Disclosures, the law or your personal privacy and safety. We are not responsible for the results of such postings.
G. Updates to the Disclosures
We may update these Disclosures from time to time without prior notice by posting revised Disclosures to this site. You can determine when these Disclosures were last revised by checking the Last Updated date at the beginning of these Disclosures.
H. Contact Us
If you have any questions, comments, requests or concerns about these Disclosures or other privacy-related matters, you may contact us in the following ways:
- Email: firstname.lastname@example.org
- Mail: Visible Body
492 Old Connecticut Path, Suite 501
Framingham, MA 017014
CCPA Privacy Notice for CA Residents
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||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 identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A 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. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above directly and indirectly from activity on our website and in our applications. For example, from submissions through our website portal or website usage details collected automatically.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you share your name and contact information to request pricing information or ask a question about our products or services, we will use that personal information to respond to your inquiry.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- The institution you are affiliated with, if you use our products through your affiliation with an institution, such as a college or university
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, Deletion, and Opt-out Rights
To exercise the access, portability, deletion, or opt-out rights described above, please submit a verifiable consumer request to us by email at email@example.com or by mail at:
492 Old Connecticut Path, Suite 501
Framingham, MA 01701
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person or an authorized representative of the person we collected personal information on.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
492 Old Connecticut Path
Framingham, MA 01701