Effective Date: January 1, 2020
We at the D2L family of companies (“we”, “our” or “us”) are committed to protecting the privacy of our users. This privacy notice (“Notice”) supplements the information in our Privacy Statement and describes how we collect, use and share personal information about California residents and their rights with respect to that information.
This Notice applies only to “personal information”, as defined in the California Consumer Privacy Act of 2018 (the “CCPA”), that we collect as a “business” as defined in the CCPA, for example, when we collect personal information through our websites and marketing efforts.
Where we provide our offerings to consumers on behalf of our customers, we are considered a ‘service provider’ under the CCPA and we only use personal information to provide our services in accordance with our written agreement with our customers. In this case, the customer’s privacy notice governs the use of personal information (which could be your school, place of business, or organization).
What Personal Information We Collect
In the last 12 months, we have collected and/or disclosed for a business purpose the following categories of personal information:
- Identifiers, such as your name, work address, telephone number, email address, job title and organizational affiliation. Online identifiers, such as your username for any of our websites, or the information we automatically collect through cookies and similar technologies used on our websites, as described in our Cookies Policy.
- California Customer Records, (Cal. Civ. Code § 1798.80(e)) such as name, contact information, financial information (payment details you provide)
- Protected classification characteristic, such as a disability (that you choose to provide to us for accommodation purposes)
- Commercial information, such as the billing details we use to bill you for our services, your billing and payment history. We also collect information about your preferences regarding marketing communications and your participation in our events.
- Internet activity or electronic network activity information, that we collect about your interaction with our websites, emails and other online content. We also collect information about your preferences for the marketing emails that we send.
- Audio, electronic, and visual information, such as video or audio recordings of conversations with you made with your consent.
- Geolocation Data, such as location information from your device or rough location generated based on IP address.
- Professional or employment-related information that we collect in connection with our services to you, such as your job title, and employer information
- Inferences drawn from the above information about your predicted characteristics and preferences.
- Other Personal Information about you that is linked to the personal information above.
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our customers. For example, from documents that our customers provide to us related to the services for which they engage us.
- From your education institutions, business or organization.
- Indirectly from our customers. For example, through information we collect from our customers in the course of providing services to them.
- Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically and from your browser or device.
- From third parties that interact with us in connection with the services we perform. For example, from business partners, service providers, and affiliates.
How we use Personal Information
We use the categories of personal information from and about you for a variety of business purposes as described in our Privacy Statement. For example, we use personal information to respond to your inquires made through our websites; to organize and host events (webinars, conferences, meetings); to market to you; to operate our websites and services including personalization; To help maintain the safety, and security of our websites; To maintain and improve our services; and as otherwise permitted or required by law.
How We Share Your Personal Information
We may disclose your personal information 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. The categories of third parties to whom we may have disclosed personal information for a business purpose include:
- Service Providers. Companies that provide us with services that help us provide services or operate our business, such as IT and software services, mailing services, marketing services, event management services, and cyber security services.
- Affiliates. Our affiliates and subsidiaries, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
- Third parties. With your consent or as described to you at the time of collection of your personal information.
- Data analytic providers. Providers that deliver the information we need to improve the user experience and serve up the content our visitors find most useful.
- Business Partners. Such as technology partners, content partners, event sponsors, resellers
- Social Networks. As described in our Cookies Policy.
- Professional advisors. Our lawyers, accountants, bankers and other outside professional advisors in the course of the services they provide to us.
We do not sell your personal information for any monetary consideration. However, we do share your information (that is common with companies with an online presence) for other purposes that may be considered a “sale” under the broad definition in the CCPA. This includes sharing identifiers, commercial information and internet or other electronic network activity with advertising networks, website analytics companies, and event sponsors for a business purpose.
Your California Consumer Privacy Rights
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.
Please note: If you are a user of our products and services on behalf of your organization (school, workplace, etc), contact your institution to exercise your rights.
The Right to Know
Information. You can request the following information about how we have collected and used your personal information during the past 12 months:
- The categories of personal information that we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting and/or selling personal information.
- The categories of third parties with whom we share personal information.
- The categories of personal information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
Access. You can request a copy of the personal information that we have collected about you during the past 12 months.
The Right to Request Deletion
Deletion. You can ask us to delete the personal information that we have collected from you.
The Right to Opt-out of Sales
Opt-out. While we do not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. You have the right to direct us to not sell your personal information
Nondiscrimination. You are entitled to exercise the rights described above free from discriminatory treatment prohibited by the CCPA.
If you would like to exercise your Right to Know or Right to Deletion, please fill out this request form, email email@example.com with the subject line “California Rights Request”, or call 1-888-772-0325. Our privacy team will examine your request and respond to you as quickly as possible.
To exercise the Right to Opt-Out of personal information disclosure, you may submit a request by clicking the button below:
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.
The Right to Opt in for Minors Under Age 16. We do not sell the personal information of minors we know to be under 16 years of age.
We reserve the right to change this Notice at any time. If we make any material changes to this Notice, we will post the revised version to https://www.d2l.com/legal/ccpa and update the “Effective Date” at the top of this Notice. Except as otherwise indicated, any changes will become effective when we post the revised Notice on our website.
Please address any questions or concerns relating this Notice to D2L’s Data Protection Officer at firstname.lastname@example.org