Effective date: May 25, 2018
For US Version click here.
ExecOnline, Inc. (“ExecOnline”) operates a platform for delivering online executive education courses to high potential employees of our business customers. This Privacy Notice governs our practices in handling personal information we collect about or from individuals in the European Union who use the Services, both as participants in courses or programs (“Participants”) and administrators who manage enrollment for our business customers (“Enterprise Users”).
ExecOnline processes personal information as a co-controller with our business customers (“Sponsoring Organizations”) except where ExecOnline is a data processor by agreement with a Sponsoring Organization. Contact information for ExecOnline can be found at the bottom of this policy. ExecOnline may update this Notice if we change the way we process personal information.
Information Collection and Use
The types of information we collect and the purposes for processing are outlined more fully in the next section.
Obtained Directly From You
Enterprise Users: If you are an Enterprise User, ExecOnline may collect your name, email address, user ID, password, telephone, job title, job level, and job function/manager from you to facilitate your use of our Services. We may collect this information from you over the Internet via the Enterprise Portal, email or over the phone.
Participants: If you participate in a Program, ExecOnline collects information from you in order to help you enroll in the Program, and then to complete the Program, and to generally administer and maintain the Platform. We may collect personal information from you via the ExecOnline Platform (including our registration process, email and calendaring software) or over the phone.
Information Not Obtained Directly From You
In addition to the processing described above, we may obtain personal information about you from other sources. Currently, we obtain the following types of personal information from sources other than you:
- Customer Information: We obtain from third parties information such as name, job title, email or phone numbers of individuals at Sponsoring Organizations who may be interested in our products.
- Enrollment Information: We obtain from the Sponsoring Organization the name and email address of Participants the Sponsoring Organization has designated for enrollment in a Program. We collect and use the following types of personal information (information that can be used to identify a particular person):
Purposes of Processing of Personal Information
ExecOnline processes personal information for the following purposes:
- Request Information: We may process personal information to respond to a feedback questionnaire or request for information on products or services, including your name, business address, phone number and business email address.
- Registration: When you register for a Program you (or in some cases your sponsoring organization) provide profile information such as your name, title, years of service, work email, work phone, mobile phone, country of origin, location (time zone/city/state/country), position and job function. We use this information to administer and improve our Program offerings and the Platform. We may use this information to communicate with you about current Programs and future offerings.
- Credit card information: In most cases, Programs are paid for by your sponsoring organization. In certain cases, you may choose to pay using your own credit card. We do not process or store your credit card information. We use a third-party payment card processing company to process payments. This third party has committed to processing your payment card information in a secure, PCI compliant manner.
- Program content: We record and store Program participation activity, including Program video lectures and group discussions, comments and assignments submitted via the Platform. We use this information to deliver the Programs to you, to administer the Platform and to improve upon future offerings.
- Performance metrics: We keep track of your participation in Programs, such as your attendance record and progress, comments or assignments you submit during the Program, and data on how you performed. We primarily use this information for the benefit of your learning experience and to support feedback and interaction during the Program. We may share this data with your sponsoring organization or with Program instructors and their affiliated school, as described in the Sharing Your Personal Information section below.
- Platform analytics information: We use third party analytics tools to help us analyze how participants use Programs and the Platform. These tools may employ cookies or other technologies to generate information about your use of the Platform, including your IP address, general location, software and hardware characteristics, and the pages you visited before or after ExecOnline. We use this information to optimize the Platform and Program experience.
In addition to the purposes described above, we process your personal information to:
- Respond to your support questions or messages and fulfill your requests.
- Contact you for feedback about a Program, professor or the Platform.
- Recognize you as a returning user when you access the Services using different devices or browsers and to remember your account information or preferences.
- Send you email newsletters or product announcements.
- To understand whether and when you read our email messages and click on links in those messages.
- Generate aggregate or other information that does not directly identify you as an individual or the devices you use to access our Services, and use and share that information for the purposes described above.
- To meet our contractual obligations to Sponsoring Organizations.
We also may use the information collected from you for other purposes, that are described to you at the point of collection or for which we have obtained your consent.
Sharing Your Personal Information
In addition to the third parties described above, we may share your personal information with:
- Program instructors and partner schools in order to administer and improve the Platform or Program offerings.
- Your Sponsoring Organization (employer) for its own internal purposes.
- Other Program participants as part of the Program (for instance, when you submit a comment or feedback on a Program assignment).
- Our investors or service providers to the extent necessary to help us administer and improve our delivery of Programs via the Platform.
- To meet our contractual obligations to Sponsoring Organizations.
- We may also transfer your personal information to our successors as part of a sale, merger or restructuring. In that event, ExecOnline will make reasonable efforts to ensure that the successor handles your personal information in a way that is consistent with this Privacy Notice.
Legal Basis for the Processing of Personal Information
ExecOnline processes personal information as described in this Privacy Notice in order to fulfill its contractual obligations to Participants and their Sponsoring Organizations, and based on the legitimate business interest of ExecOnline or a Sponsoring Organization.
Consent: For certain Programs or initiatives, we may process personal information based on your consent. In those instance, we will provide you with notice, and ask for and obtain your consent for that specific processing or purpose. Once consent is provided, it may be revoked at any time for that specific purpose or processing.
Each Sponsoring Organization (e.g. your employer) is responsible for obtaining any consents required under European or EU member state employment or employee privacy law..
Retention of Personal Information
Your personal information is retained for the period of time that is reasonably necessary to conduct the processing described, to fulfill our contractual obligations to Participant or the Sponsoring Organization, or to comply with the law.
Your Rights and Choices
You have the right to request that certain actions be taken with respect to your personal information. You may make these requests by contacting your Sponsoring Organization. Or, you may submit your request to firstname.lastname@example.org and we will forward your request to the appropriate contact at the Sponsoring Organization.
You have the right to:
- Request a copy of your personal information.
- Request that your personal information be updated or corrected if it is inaccurate.
- Request that your personal information be deleted when it is no longer necessary to retain it.
- Withdraw consent to a particular processing or purpose if ExecOnline is relying on that consent to process the information.
- Request that the data controller transmit your personal information directly to another data controller, where applicable. This right is only available in certain circumstances.
- Object to or ask for a restriction on further processing of personal information, where applicable.
- Lodge a complaint with a supervisory authority.
In addition, if you would like to make changes to your account or update preferences you may:
- Withdraw consent to marketing emails or email newsletters by clicking the “unsubscribe” link on the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about your enrollment or participation in a Program).
- You may also update your profile information or manage your discussion group preferences by logging into your Platform account.
ExecOnline employs physical, technical and organizational safeguards to ensure an appropriate level of security for personal information, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
If ExecOnline plans to use personal information for a new purpose, we will update this Notice and communicate the changes to individuals before starting any new processing.
Questions and Complaints
If you have questions or complaints about our use of your personal information, please contact us via the Contact Details below. You can also contact your national data protection supervisory authority in order to lodge a complaint against us. At this time, ExecOnline has not established a representative in the EU who can respond to questions and complaints.
Data Protection Officer
New York, NY 10003
New York, NY 10003