PRIVACY POLICY
Effective October 2024
We are CBT Nuggets, LLC (“CBT Nuggets,” “we,” “us” or “our”), a leading provider of IT training solutions. We are committed to protecting and respecting your privacy. By accessing or using the Services, you expressly agree to this Privacy Policy. This Privacy Policy describes the types of information that we may collect from you or that you may provide to us when you visit the CBT Nuggets website located at https://www.cbtnuggets.com, while logged into the Adept Learning Platform located at https://learn.adept.at (the “Website”) or the CBT Nuggets or its partner's applications (“Apps”) (collectively the “Services”), and our practices for collecting, processing, protecting and disclosing such information.
This Privacy Policy applies to information we collect: (i) through the Services, and (ii) in communications between you and CBT Nuggets. For the purposes of this Privacy Policy, we refer to individuals who utilize our Services as "Learners." For purposes of this Privacy Policy, we use the terms “personal information” and “personal data” interchangeably.
OVERVIEW
Except as otherwise expressly provided, this Privacy Policy only addresses the use and disclosure of information CBT Nuggets collects from you. The Website may contain hyperlinks to other third-party websites, which may collect and disclose information in a manner not consistent with this Privacy Policy, and such collection and disclosure would be governed by that website’s privacy policy, and any questions or concerns should be directed to that company’s site administrator or provided contact information. We are not responsible for the collection, use, or disclosure of information collected through any third-party websites, and we expressly disclaim any and all liability related to such collection, use, or disclosure.
By using or interacting with our Services, you agree to following:
The use of cookies, tracking pixels, and similar technologies;
The transfer of your data from, within, and between:
the European Economic Area ("EEA") and the United Kingdom and Switzerland;
the United States, Mexico, Australia; and,
countries that have received an adequacy determination by the European Commission under Article 45, as well as other countries subject to appropriate safeguards under Article 46, of Regulation (EU) 2016/679;
The processing of your data as described in this Privacy Policy; and,
The use of e-mail notifications as a primary source of communication between you and CBT Nuggets.
INFORMATION WE COLLECT
CBT Nuggets and our partners collect data from Learners in the following circumstances:
Website Visitors
When you use or interact with the Services, we and our partners may use a variety of technologies that collect information about those interactions. These technologies include cookies, web beacons, tracking pixels, and similar technologies. Learn more about cookies at www.aboutcookies.org. We use these technologies internally to customize your learning experience, such as keeping you in a logged-in state or providing you with the most relevant content. Disabling these technologies on your web browser may negatively impact your user experience.
We also have partners that use these technologies to provide us with measurement services of our Website and deliver advertisements to you as well as optimize your experience. These third-party partners may collect your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and attempt to aggregate data to deliver content and optimize your experience based on overall web browsing activity.
We may use vendors, who use first-party and third-party cookies together to inform, optimize, and serve ads based on your past visits to our Website. Google Analytics offers tools to manage your cookie settings at tools.google.com/dlpage/gaoptout and Google's My Ad Center (myadcenter.google.com) allows you to easily customize certain ad settings. Microsoft Ads allows users to opt out via their website at about.ads.microsoft.com/en-us/resources/policies/opt-out-of-the-microsoft-advertising-optimization-program. Quantcast has an opt out here at their website (www.quantcast.com/opt-out/). On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests. Additional information for mobile users can be found at: youradchoices.com/appchoices.
Additionally, we may provide these vendors with a hashed and anonymized version of your email address or other contact information, in a format not readable by humans, to support the delivery of tailored advertising.
Our Website does not respond to Do Not Track signals. You may visit aboutads.info to receive more information about the collection and use of information about your online activities for online behavioral advertising or to learn how to opt-out of having your data used for online behavioral advertising by Digital Advertising Alliance (DAA) participating companies. Canadian users can also visit youradchoices.ca. European users can also visit youronlinechoices.com to learn how to opt-out of having their data used for online behavioral advertising by European Interactive Digital Advertising Alliance (EDAA) member companies.
By interacting with our Website without disabling cookie functionality and other similar technologies, you hereby consent to the use of cookies and similar technologies as described above.
Learners
In order for you to access the CBT Nuggets content (training videos, quizzes, practice exams, virtual labs, and other tools), you must first register for a CBT Nuggets Learner Account by providing personal data. We and our third-party partners must process your personal data in order to make that content available to you as you have requested and pursuant to the terms of your access. The particular data that is processed, and by whom, is relative to the particular content you access and the particular service you interact with. We also collect Learner activity data which we use internally to keep track of your learning progress and ensure our Services are operating as expected for all Learners.
Account Administrators have access to certain account, subscription and enrollment information for Learners in their group. Account Owners, Group Administrators, Learning Administrators and Billing Administrators similarly have access to their group's Learner information, with Account Owners and Billing Administrators having additional access to payment and billing information.
Account Activity
When you register for a CBT Nuggets Learner or Administrator account we collect information about you for the following purposes. We collect your email to function as your username and provide a means of communication for important notices. We collect your first and last name in order to facilitate our licensing model of one license to one named individual. This allows us to provide a personalized Learning experience and comply with various reporting and recordkeeping obligations. We optionally collect your company/organization/school name, as well as other provided information, in order to enhance your Learner experience.
When registering on our site you may be asked to enter payment information, such as PayPal or a credit card. We collect your payment information, as well as your billing address, email address and telephone number for validation, compliance, and recordkeeping purposes. We further leverage third party email tracking pixels to track the opening of billing emails. Payment processing is securely handled by third parties. All information entered into the secure webform is done so via an encrypted session.
We may offer you the ability to link a third-party profile or identity provider for registration, authentication, or other account activities. You will be directed to that third party's page, where you can log in with your third-party account details and authorize the processing of your information for such account activity as described by that third party.
Accessing Services
When you access the Services, CBT Nuggets may collect and aggregate anonymized data related to the consumption of the Services, including what CBT Nuggets content users consume, to better curate learning experiences and generate content recommendations.
Accessing Exams
When you access the certification practice exams through the Services, you are accessing proprietary materials which have been provided to Learners through an agreement with our test provider. Your information is stored by the test provider and used to create a unique authentication token which provides you access to the practice exams. Your information is only transmitted to our test provider when you access the practice exams.
Accessing Labs
When you access the virtual labs through the Services, you are accessing our proprietary instances on a virtual computer hosted by our labs provider. Your information is used to create a unique authentication token which provides you access to the virtual labs. Your information is only transmitted to our labs provider when you access the virtual labs.
Learner Contributions
When you participate in the Learner Community, the Validated Minutes Leaderboard, or when posting comments, you are placing your information in a public forum, including your first and last name as applicable. Once you publish in any of the above forums, it becomes publicly available and we are restricted in our ability to delete that information. Before posting in a public forum, you should carefully review the Privacy Policies of the relevant third-party partners. Our Learner Community is a third-party hosted forum. The Validated Minutes Leaderboard is a semi-public forum hosted by CBT Nuggets and available to view by other CBT Nuggets Learners. If you choose to edit your Leaderboard profile picture, you are creating an account with that third-party. By default, your Validated Minutes are not displayed on the Public Leaderboard, you can opt-in via your Learner Account settings.
User Experience Research
We may provide Learners or Website visitors with the opportunity to participate in user experience research, and we may announce such opportunities, through our marketing email list or by invitation to our Learners. Additional details, as appropriate, of the data processing may accompany any such opportunity for feedback and engagement. Unless otherwise specified, the personal data collected during such surveys will be retained consistent with our data retention schedule. As with any consent, you may revoke this consent at any time. We may also provide Learners with customer feedback surveys for internal purposes only, or to follow up on prior activity with us.
Mailing List
When you sign up to receive marketing emails from CBT Nuggets, the personal information you provide is collected in order to identify you and personalize the email content we send to you. Marketing emails contain information, news, resources, special offers, and promotions related to CBT Nuggets which you otherwise have requested to receive. We may use Multipurpose Internet Mail Extensions in our emails to help inform us of the effectiveness of our content as well as provide an indication as to your level of interest in continued marketing.
You may unsubscribe from the marketing email list at any time by navigating to your Learner Account settings or by using the “Unsubscribe” link in the email, or by signing into your CBT Nuggets account and navigating to My Account>Settings>Manage Email Preferences. Please note that this does not unsubscribe you from System/Transaction Emails such as subscription notices, receipts, follow up communications, or other compulsory commercial or legal correspondence.
Contests, Drawings, and Promotions
When you enter a contest, drawing, or promotion you are agreeing for us to process your personal data and create a contact record. This contact record may be associated with your Learner account, social media profile and/or contest entry, as may be applicable. Your participation in such contests, drawings, or promotions are completely voluntary, as is your decision to submit entries. Please carefully review the applicable rules of any contest, drawing, or promotion you participate in. At all times, you may freely revoke your consent to participate in the contest, have your entry used in marketing materials, or any other data processing activity.
Communicating With Us
When you contact us for support, or otherwise communicate with us, we will attempt to connect that email, telephone call, or chat with your Learner account. If we are able to connect the communication to the account, this means your method of communication and the substance of the communication will become associated with your information. When you contact an Accountability Coach, we connect those communications to your Learner account as well.
CBT Nuggets expressly discourages any customers from sending or transmitting any sensitive data via any unsecured networks or channels, including, but not limited to, any customer primary account number (“PAN”) or other credit card or payment data. You assume any and all risk associated with such transmissions.
Accessing Services Via Apps
When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best application version to provide you with. During your use of the App, we and our partners may further collect data regarding your device, operating system, and location in order to optimize the Services. Our mobile Apps require Account Registration for full functionality, and the data collected during registration is described in the previous sections. Please note that, as applicable, your subscription may be managed through a mobile application store such as Apple or Google Play Store, etc.
INFORMATION WE DISCLOSE
We will NEVER rent, sell, share, or otherwise disclose your personal data with third-parties for their direct marketing purposes. Before disclosing your data with third-parties or controllers (respectively defined under applicable law), we will provide you with notice and an opportunity to opt-out.
Depending on your use of the Services, we may disclose your personal information and/or other information described in the INFORMATION WE COLLECT section of this Privacy Policy with:
Our contractors, service providers, processors and other businesses that we use to support our business and to fulfill services requested by you, including, without limitation, the following categories:
Website Hosting
Data storage centers, database solutions and internal development tools.
Administration Services
Billing, accounting, payment processing, customer relationship management (CRM), customer account maintenance, internal and external communication tools.
Service Delivery
Practice exams, virtual labs, certifications of completion, video encoding, content delivery, and customer service tools.
Mailing List
Email marketing as opted into by customers and other necessary transactional communications.
Website Interaction Technologies
Cookies, web beacons, tracking pixels and similar website interaction technologies
Contractor Services
Software engineering, video and written content creation and design, and other marketing services.
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 our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by CBT Nuggets about its Learners and Administrator account holders is among the assets transferred. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot ensure that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.
To your Account Administrator or owner or billing or coaching contact, if any.
To other third parties with your express consent or that of your Account's contacts, if any.
We may also disclose your personal information:
To comply with a lawful request by public authorities, including valid court orders or to meet national security or law enforcement requirements.
To enforce our agreements with you, including for billing and collection purposes.
To prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity; this may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We accept full responsibility for any and all transfers of your personal data to third parties acting as our agents unless we can prove we were not a party giving rise to the damages.
WHERE WE KEEP YOUR DATA
The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff both within and outside the EEA who work for us or for one of our service providers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and/or the provision of support services. Your data is maintained in servers that are located in the United States, and your data may be processed in the United States, Mexico, Australia, United Kingdom, and countries for which there has been an adequacy decision and/or with appropriate safeguards. Not all of these countries are considered by the European Commission to offer adequate protection of your personal data. For these cases, CBT Nuggets has put into place appropriate safeguards to ensure adequate protection of your data as well as other technical and organizational safeguards.
Data handled by our service providers is maintained in the United States. Our employees and contractors may, on occasion, process personal data through a dedicated and encrypted connection to this data. There is no data at-rest, only occasional data in-use. By submitting your personal data, you agree to this transfer, storing or processing as described in this Privacy Policy. CBT Nuggets will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
We retain personal data for seven years from a Learner’s last account access or termination of the last subscription period, whichever is later, unless such data must be retained for the establishment, exercise, or defense of legal claims.
YOUR RIGHTS
Through the Website you can access information regarding your recent orders, your personal information, marketing preferences, and payment settings. With respect to your marketing preferences, you can unsubscribe from CBT Nuggets marketing emails by following the unsubscribe link in any marketing email you receive or you can navigate to your Learner account and update your preferences there. We offer marketing email recipients the opportunity to unsubscribe from further communications in every email, with the exception of non-commercial service emails, such as service orders, system updates, or support issues.
If your password or username is compromised, please notify us as soon as possible by using the contact information below. We reserve the right to reset passwords for inactive accounts or due to suspicious account activity.
CBT Nuggets acknowledges that you may have certain rights relating to your personal information/data, subject to local data privacy laws (“Data Privacy Laws”). Depending on the applicable Data Privacy Laws, this may include the right to:
Access your personal information that we maintain;
Request that we correct any inaccuracies in your personal information;
Request that we erase or delete your personal information;
Request more information about how we process your personal information (subject to the public availability of such information in this Privacy Policy), including:
Categories of your personal information processed
Categories of the source of your personal information
Business purpose for processing the specific categories of your personal information
Categories of third parties that process your personal information
Specific pieces of personal information collected
To opt out of sharing your personal information with a “third party” or “controller” (excluding “service providers,” “businesses,” “contractors” or “processors”);
Not be discriminated against for exercising your rights under applicable Data Privacy Laws; and
Request that CBT Nuggets transfer your personal information to another controller/business to the extent possible.
APPEAL PROCESS
Should you decide to request to exercise a right under an applicable Data Privacy Law, CBT Nuggets may deny such request. If CBT Nuggets declines to act regarding your request, CBT Nuggets will notify you within 45 days of the receipt of the request and explain why. You may appeal the denial of your request by contacting the CBT Nuggets Learner Support team as described in the CONTACT INFORMATION section of this Privacy Policy.
DATA PRIVACY FRAMEWORK
Data Subjects of the United Kingdom, European Union and Switzerland, please review the following information:
CBT Nuggets complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. CBT Nuggets has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. CBT Nuggets has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (“Principles”), the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit www.dataprivacyframework.gov/
Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Please review the WHERE WE KEEP YOUR DATA section of this Privacy Policy for details on where data is processed and maintained. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to support@cbtnuggets.com. If requested to remove data, we will respond within a reasonable timeframe. For more information please review the YOUR RIGHTS section of this Privacy Policy.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents (contractors, service providers, processors and other businesses that we use to fulfill service delivery), or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to support@cbtnuggets.com.
Please review the INFORMATION WE COLLECT section of this Privacy Policy for details on the types of personal data collected.
CBT Nuggets commits to apply the Principles to all personal data received from the EU, Switzerland, and the UK in reliance on the Data Privacy Frameworks.
Please review the INFORMATION WE COLLECT section of this Privacy Policy for details on the purposes for which CBT Nuggets collects and uses personal data.
Please review the CONTACT INFORMATION section of this Privacy Policy for details on how to contact CBT Nuggets with any inquiries or complaints.
Please review the INFORMATION WE DISCLOSE section of this Privacy Policy for details on the type of third parties to which CBT Nuggets discloses personal data to, and the purposes for which it does so.
Please review the YOUR RIGHTS section of this Privacy Policy for details on the choices and means that CBT Nuggets offers individuals for limiting the use and disclosure of their personal data.
Please review the CONTACT INFORMATION section of this Privacy Policy for details on the independent dispute resolution body designated to address complaints and provide appropriate recourse free of charge.
With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, CBT Nuggets is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
In certain situations, individuals can invoke binding arbitration. For more information, please review the CONTACT INFORMATION section of this Privacy Policy.
CBT Nuggets remains liable to third parties in cases of onward transfers.
CONTACT INFORMATION
CBT NUGGETS:
Any individual who seeks to exercise a right under an applicable Data Privacy Law should direct their query to the CBT Nuggets Learner Support team:
CBT Nuggets, LLC
2850 Crescent Ave
Eugene, OR 97408
Toll-free, US only: 1-888-507-6283
International: +1 541-284-5522
UK DATA SUBJECTS:
If you are a Data Subject of the United Kingdom (UK), and have any concerns about our use of your personal information, you can make a complaint to us at support@cbtnuggets.com.
You can also contact the ICO if we have not addressed your concern in a satisfactory manner
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website:https://www.ico.org.uk
EU DATA SUBJECTS:
If you are a Data Subject of the European Union (EU), and have any concerns about our use of your personal information, you can make a complaint to us at support@cbtnuggets.com.
You can also contact the EDPS if we have not addressed your concern in a satisfactory manner.
See: https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en
EDPS website: https://edps.europa.eu/_en
DPF INDEPENDENT RECOURSE MECHANISM:
In compliance with the EU-U.S Data Privacy Framework (EU-U.S DPF), the UK Extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework (Swiss-U.S DPF) Principles, CBT Nuggets commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the EU-U.S DPF, the UK extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework Principles. European Union, United Kingdom, and Swiss individuals with inquiries or complaints should first contact CBT Nuggets at support@cbtnuggets.com.
CBT Nuggets has further committed to refer unresolved privacy complaints under the Data Privacy Framework program to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaintsmore information and to file a complaint. This service is provided free of charge to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction
CALIFORNIA CONSUMERS:
If you are a California Consumer, and have any concerns about our use of your personal information, you can make a complaint to us at support@cbtnuggets.com.
You can also contact the CPPA if we have not addressed your concern in a satisfactory manner.
How to file a complaint:https://cppa.ca.gov/webapplications/complaint
Contact Info:
CPPA
ATTN: PRA Coordinator
2101 Arena Blvd
Sacramento, CA 95834
PRA@cppa.ca.gov with the Subject: ATTN: PRA Coordinator
Unfortunately, no online data transmission can be fully guaranteed to be secure. Thus, by accessing the Website and/or utilizing the Services, you acknowledge that: (a) there are online security and privacy limitations that are beyond CBT Nuggets’ control; (b) the security, integrity and privacy of any and all information and data exchanged between you and CBT Nuggets through the Website cannot be fully guaranteed and we shall have no liability to you or any third party, unless otherwise provided by law, for loss, misuse, disclosure or alteration of such information not resulting from the direct fault or negligence of CBT Nuggets; and (c) any such information and data may be viewed or tampered with in transit by a third party.
CHANGES TO THIS PRIVACY POLICY
CBT Nuggets shall post any revisions to this Privacy Policy on this web page. The Effective Date of this Privacy Policy version is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Website and this Privacy Policy to check for any changes.
Your continued use of the Services after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to be bound by the modified Privacy Policy.