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Taylor Protocols, Inc. Privacy Policy
Version 2.0.1 Effective Date: 5/25/2018, Last Modified: 5/24/2018
1. Introduction
This Privacy Policy describes how Taylor Protocols, Inc. collects and uses Personal Data about you through the use of our Websites, our products, and through email, text, and other electronic communications between you and Taylor Protocols.
Taylor Protocols, Inc. (“Taylor Protocols” or “we”) respect your privacy and are committed to protecting it through our compliance with this policy
This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the websites members.taylorprotocols.com, ws.taylorprotocols.com, taylorprotocols.com, taylorprotocolsinc.com, store.taylorprotocols.com (each, a “Website”). It also delineates practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- on our Websites and through the use of our products;
- in email, text, and other electronic messages between you and our Websites (including our technical support services).
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by Taylor Protocols or any third-party; or
- any third party, including through any application or content that may link to or be accessible from or on the Website or with our products.
Please read this policy carefully to understand our policies and practices regarding your information and how we will address it. If you do not agree with our policies and practices, your choice is not to use our Websites and/or not to sign up for our Customer Experience Program. By accessing or using these Websites and joining our Customer Experience Program, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of these Websites and our products after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.
2. Summary EEA, Privacy Shield and GDPR
Taylor Protocols’ policy is to globally adhere to the most stringent privacy protection laws enacted. Our objective is to maximize our clients’ security and privacy at all times and in all places.
The European Commission has determined that the transfer of personal information of its residents outside of Europe must be subject to a legal framework that adequately protects it. We transfer personal information of European Economic Area ("EEA") and Swiss residents to the U.S. or elsewhere based upon the following legal frameworks:
- Legitimate business interests: We could not provide our services or comply with our obligations to you without transferring your personal information to the U.S.
- Consent: We may transfer your personal information when we receive your express, revocable consent.
- Our use of Standard Contractual Clauses (also known as “Model Clauses”) where appropriate.
- Our self-certification with the EU-US and Swiss-US Privacy Shield frameworks ("Privacy Shield").
We adhere to the Privacy Shield principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Information about Privacy Shield (and our self-certification) can be found here: https://www.privacyshield.gov. Our Privacy Shield compliance is subject to the enforcement authority of the U.S. Federal Trade Commission. In addition, EEA and Swiss residents may invoke binding arbitration as set forth below.
We comply with the European Union’s General Data Protection Regulation ("GDPR"), which governs the protection of personal data of EU residents. To find out more about GDPR, please visit the European Union’s website, at https://ec.europa.eu/info/law/law-topic/data-protection_en.
EU users have the rights to: opt out of cookies; access, correct, delete, restrict or object to our use of their personal information; be forgotten; and data portability. We enable exercise of these rights through our products (which we reserve the right to modify). For example, we allow users to change their information, grant and revoke access to products and services, and close their accounts. We also fulfil our obligations in response to direct requests.
If you require assistance, please contact our Data Protection Officer. We may require additional information from you to fulfill your requests. We may charge a reasonable fee if your request imposes an unreasonable cost on us.
We will afford all users with all rights available to EU users, regardless of their location. We will upgrade our products, services and policies in a reasonable timeframe when necessary by GDPR or any subsequent law providing more privacy protection.
3. Data Controller, Data Protection Officer, and Representative
Taylor Protocols is the data controller of the Personal Data you provide on the Websites and has appointed a Data Protection Officer.
Some laws, including the GDPR, differentiate between controllers and processors of data. A "controller" has a direct relationship with you and exercises control over the use of your data. The third-party vendors that help a controller provide a service are considered "processors" because they process the controller’s customer data at the controller’s request (examples are payment processors and cloud-based hosting providers).
Taylor Protocols is the data controller of your Personal Data. Taylor Protocols has appointed a Data Protection Officer and a representative in compliance with the General Data Protection Regulation. Taylor Protocols, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Policy.
Taylor Protocols is the data controller for all client entities with accounts to issue CVIs, TPPs and all other products or services. Taylor Protocols is the data controller of personal data of end users who take the CVI and view the associated CVI report as these entities have direct relationships with Taylor Protocols and their own CVI.
4. Information We Collect About You and How We Collect It
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or by other means. Most users provide the limited information of name, email address and CVI word selections.
Generally
We collect several types of information from and about users of our products and Websites, specifically information:
- by which you may be personally identified, such as name, postal address, e-mail address, telephone number, credit card information (for payment processing) and any other identifier by which you may be contacted online or offline (“Personal Data”);
- that is about you but individually does not identify you, such as Website traffic data, location data (through IP address), logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access and use on the Websites;
- about your internet connection, the equipment you use to access our Websites and usage details.
We collect this information:
- directly from you when you provide it to us;
- automatically as you navigate through the site. Information collected automatically may include usage details (including the number of installations for products you have purchased), IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
- From third parties, for example, our corporate working with job applicants, VARs, coaches or current clients who wish to share the CVI with you.
Information You Provide to Us
The information we collect on or through our Websites includes:
- information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, posting material, or requesting further services (such as technical support). We may also ask you for information when you enter a contest, sweepstakes, or promotion sponsored by us, and when you report a problem with our Websites;
- records and copies of your correspondence (including email addresses), if you contact us;
- your responses to CVI, evaluations and surveys;
- details of transactions you carry out through our Websites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites.
The Personal Data we collect from you is required to enter into a contract with Taylor Protocols, for Taylor Protocols to perform under the contract, to provide you with our products and services, and to provide you with license keys to our products. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
You also may provide information to be published or displayed (hereinafter, “posted”) to other entities for which you grant access. Taking a CVI automatically grants access to you, the inviting entity and Taylor Protocols administrative staff. A common example would be a job applicant receiving a CVI link which grants the hiring company and Taylor Protocols access to the CVI results to fulfill contractual product and service agreements. Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
- details of your visits to our Websites, specifically traffic data, location data (through IP addresses), logs, referring/exit pages, date and time of your visit to our Websites, error information, browser type and operating system;
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Websites accordingto your individual interests;
- prevent or deter software piracy and protect our intellectual property;
- speed up your searches; and
- recognize you when you use and return to our Websites.
Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.
5. Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data to fulfill our obligations to you under a contract with you and/or associated entities, and required by law, and with your consent.
Regardless of your location, whether within the European Union or elsewhere, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
- Consent. By using our Websites, you consent to our collection, use, and sharing of your Personal Data as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Websites.
- Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Specifically, our legitimate interests are to: facilitate communication between Taylor Protocols and you; detect and correct bugs and to improve our Websites, products, and services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime (including misappropriation of intellectual property); promote and market our business; perform risk assessments; and develop our product and services.
- To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you. Specifically, we use your contact information to provide you with the products, license keys, and support services that you, or associated entities, order from us.
- As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
6. Special Categories of Information
We generally do not request you provide and do not process any special categories of Personal Data.
Taylor Protocols does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you, such as Personal Data that reveals your racial or ethnic origin, political opinions, religious, philosophical beliefs, or trade unions membership, or the processing of data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions.
7. Automated Decision Making
We generally do not use your Personal Data with any automated decision making processes.
Taylor Protocols does not use your Personal Data with any automated decision making processes.
8. How We Use Your Information
We use your Personal Data for various purposes described below, including to:
Taylor Protocols does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you, such as Personal Data that reveals your racial or ethnic origin, political opinions, religious, philosophical beliefs, or trade unions membership, or the processing of data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions.
- provide our Websites to you;
- provide you with information you request from us;
- enforce our rights arising from contracts;
- notify you about changes; and
- provide you with notices about your account
We use information that we collect about you or that you provide to us, including any Personal Data:
- to present our Websites and their contents to you;
- to provide you with information, products (including license keys), or services that you request from us;
- to provide you with information about security advisories regarding the products or services that you have purchased from us;
- to fulfill any other purpose for which you provide it;
- to provide you with notices about your account, including expiration and renewal notices, invoices, and receipts;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes or updates to our Websites or any products or services you have purchased or that we offer or provide though our Websites;
- to allow you to participate in interactive features on our Websites;
- when necessary to contact you about processing an order or transaction, to contact you through phone or SMS messages;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
With your consent, we may also use your information to send you newsletters and contact you about our own goods and services that may be of interest to you, including events and other activities that may be in your area or may be of interest to you. If you wish to consent or change consent to this use, please check the relevant box located on the form on which we collect your data. Your choices may be found within your CVI report under account settings. If you wish to change your choice, you may do so at any time by checking or unchecking the relevant boxes in this “Notifications” section or by sending us an email stating your request to support@taylorprotocols.com.
9. Disclosure of Your Information
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:
- our third-party service providers that we use to support our business, such as our payment processors and hosting providers;
- to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
- to comply with our legal obligations;
- to enforce our rights; and
- with your consent.
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this privacy policy:
- to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Specifically, these entities provide IT and infrastructure support services and payment processing services. Our payment processor is Authorize.net and its privacy policy may be found at https://www.authorize.net/company/privacy.
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Taylor Protocols Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Taylor Protocols about our Websites’ users is among the assets transferred;
- to fulfill the purpose for which you provide it. For example, if you give us a name and/or email address and post in public comments to a page, we will transmit your name and/or email address to anybody who views that comment page;
- for any other purpose disclosed by us when you provide the information; and with your consent.
We may also disclose your Personal Data:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Taylor Protocols Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
10. Choices about How We Use and Disclose Your Information
We offer you choices on how you can opt out of our use of disclosure of your Personal Data to clients using our services, our advertising to you, and other legitimate purposes.
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to you and/or us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
- Promotional Offers from Taylor Protocols. We will only use your email address to promote our own products and services with your express consent which is given by taking the CVI. If you wish to revoke consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. You may also send us an email stating your request to support@taylorprotocols.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link at the bottom of the email. This opt out does not apply to information provided to Taylor Protocols as a result of a product purchase, support emails, product service experience, or other transactions.
11. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.
- Access and Update. You may notify us through the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing, but we have retained it as permitted by law.
- Portability. To the extent the Personal Data you provide Taylor Protocols is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
- Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by notifying us through the contact information below. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
- Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your CVI, user account and any other associated product or service, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. We also cannot delete your User Contributions, however proper access and use of information provided on the Websites, including User Contributions, is governed by our Terms of Use.
- Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
- How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.
12. Do Not Track Signals
We do not track you over time and across other third-party websites or services and therefore we currently do not honor do-not-track signals that may be sent by some browsers.
We do not track you over time and across third-party websites or other online services for any purpose. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received.
13. Data Security
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password and/or CVI report links to our Websites confidential.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas. The information you share in public areas may be viewed by any user of the Websites
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.
14. Consent to Processing of Personal Data in the United States
We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
Taylor Protocols, Inc. is based in the United States. We provide services globally using computer systems, servers, and databases located in the U.S. When you use our services from outside of the U.S., your information will therefore be transferred to, stored in, and processed in the U.S. Data is collected, stored, used, and shared as set forth in our privacy policies. We are adhering globally to the most stringent privacy protection to date under the European Union’s General Data Protection Regulation ("GDPR").
If you are a resident of the European Economic Area (“EEA”), in order to provide our Websites, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located.
Your Personal Data is transferred by Taylor Protocols to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Websites, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Websites. To ensure your Personal Data processed by other recipients is treated in accordance with this Privacy Policy, Taylor Protocols uses Data Processing Agreements between Taylor Protocols and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party. You may request a copy of the Data Processing Agreement by contacting us through the contact methods below.
15. Data Retention Periods
We retain your Personal Data from initiation of first consent until consent is entirely revoked with following exceptions:
- on our backup and disaster recovery systems;
- for as long as necessary to protect our legal interests; and to comply with other legal requirements.
Taylor Protocols will retain your personal data from the time you first open an account or take a CVI. After you close your account and/or CVI and request your information be deleted, we may retain your Personal Data:
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.