© 2019 - Erin Lebacqz - On the Job Global - Education for Today's Workplace - Sacramento, CA

ON THE JOB PRIVACY POLICY

Updated November 7, 2018

On the Job LLC, together with its subsidiaries and affiliates (collectively, “On the Job” “us,” “we,” or “our”) respects your privacy, and takes the responsibility of protecting the Personal Information (as defined herein) that you provide to us very seriously. This Privacy Policy describes how we collect, use, and disclose Personal Information we receive about individuals (collectively, “you” or “users”) using our products and/or services (our “Services”) and/or using our website or online features (each a “Site” or collectively, our “Sites”). 

We have adopted this Privacy Policy to explain what Personal Information may be collected in connection with the use of our Sites and/or Services, the purposes for which we may use that Personal Information, and under what circumstances we may disclose Personal Information to third-parties. For purposes of compliance with the EU General Data Protection Regulation (“GDPR”), where applicable, we are the Controller of the Personal Information that we receive about you in connection with your use of our Sites and/or Services.

This Privacy Policy also describes your rights, where applicable, and how to exercise them. You may contact us at any time with questions related to our Privacy Policy and the processing of Personal Information and privacy here.

This Privacy Policy applies regardless of whether you use our Sites and/or Services via a computer, mobile device, or any other platform or equipment (collectively, your “Equipment”). 


A. TYPES OF INFORMATION COLLECTED

We collect the following kinds of information about users:
 

(1)  Personal Information:  For purposes of this Privacy Policy, Personal Information means any information relating to an identified or identifiable natural person. This includes any information that may be used to directly identify or contact you, such as your name, address, or phone number. Personal Information also includes information that may be used to indirectly identify you in combination with other readily available information, including by reference, for example, to an online identifier, location data, or an identification number. Certain information may not be Personal Information when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and address). Personal Information, as defined herein, is intended to cover all information subject to personal data processing and privacy laws applicable to our business.   

Examples of Personal Information that we may collect from or about you include, among other things, your name, mailing address, phone number, email address, business contact information, payment information, username and password, demographic information, and any other information that meets the definition of Personal Information provided herein.

(2)  Non-Personal Information:  For purposes of this Privacy Policy, Non-Personal Information is any information that does not identify an individual, and cannot be used in combination with other readily available information to identify an individual.

(3) Device Information:  For purposes of this Privacy Policy, Device Information refers to information that may be automatically collected from devices that you use when visiting or using our Sites. Examples of Device Information that we may collect from or about you include, among other things, IP address, device identifier, cookies, log files, and any other information that may be collected from your devices. Under some circumstances, Device Information may constitute Personal Information (i.e., if it can be combined with other information to identify an individual). However, Device Information does not always constitute Personal Information, and whether it does will depend on the circumstances.


B. HOW WE USE AND SHARE YOUR INFORMATION

(1) General Uses: We may use the information we collect from you for the purposes described below. When necessary to comply with applicable law, we will obtain your consent before using your Personal Information for any of these purposes:

  • Provision of Services to Users of Our Sites. If you use our Sites, we may use your information, including your Personal Information, to provide you with our Services, and to process and respond to your requests, comments, inquiries, and other forms you submit through our Sites.

  • Processing Online Purchases. We may use your information, including your Personal Information, to process any purchases made on our Sites, including, when necessary, disclosure of your Personal Information to third-party payment processors.

  • Improving our Services. We may use your information, including your Personal Information, to enhance our understanding of our users’ preferences in order to improve the quality, performance, and delivery of our Sites and/or Services.

  • Disclosures to Service Providers. We may share your information, including your Personal Information, with third-party service providers that assist us with hosting and maintaining the Sites, processing credit card information, analyzing online activity on the Sites, marketing our services, and managing our daily business operations and delivery of the Sites. We share only the minimum amount of Personal Information with these third-party service providers that they need to perform their tasks. We also enter into contracts with these third-party service providers that require them to protect your Personal Information.

  • Compliance with Legal Obligations. We may share your information, including your Personal Information with law enforcement, government officials, regulatory agencies, or other parties when we are required to do so by applicable law. We may also disclose your Personal Information to comply with a judicial proceeding, court order, subpoena, or legal process.

  • Protection of Individual’s Vital Interests. In emergency situations, we may use or share your Personal Information when doing so is necessary to protect an interest that is essential for an individual’s life.

  • Other Legitimate Interests. We may use and disclose your Personal Information when necessary for our legitimate interests, including our legitimate business interests, as long as our legitimate interests are not overridden by your interests, rights, and freedoms with respect to your Personal Information.

  • De-Identified Information. We may also share and otherwise process aggregated or de-identified information that does not identify you individually, and such information may be shared with other parties. For example, from time to time, we may collect survey information from you on an aggregate and/or de-identified basis. We also de-identified information for various business purposes, including the creation, marketing, and sale of products and services to our customers and prospective customers. Such information is not traceable to any particular individual and will not be used by a third-party to contact you.

(2) Legal Bases for Processing: To the extent required by applicable law, the legal bases for processing your Personal Information for the purposes described above or elsewhere in this Privacy Policy include, without limitation, that (1) you have given consent to the processing of your Personal Information for one or more specific purposes, (2) it is necessary to perform a contract with you (e.g., for the sale of goods or services) or in order to take steps at your request prior to entering into a contract; (3) it is necessary to comply with a legal obligation (such as notifying you of Privacy Policy changes); (4) it is necessary for the pursuit of our legitimate interests or those of a third-party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Information; (5) it is necessary for your vital interests or those of another individual; and/or (6) it is necessary for the performance of a task carried out in the public interest.

(3)  Processing for Direct-Marketing Purposes: For customers or users of our Sites and/or Services, we may use Personal Information gathered from your use of our Sites and/or Services for direct-marketing purposes.  

To the extent required by applicable law, you have the right to object at any time to the processing of your Personal Information for direct-marketing purposes, and to opt-out from receiving such communications. If you no longer wish to receive electronic direct-marketing communications from us, you may opt out of receiving such communications by using the unsubscribe method provided in our communications or by contacting us here. You also have the right to object to our use of your Personal Information for direct-marketing purposes, where required by applicable law, by contacting us here.

(4)  Other: Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any Personal Information or Non-Personal Information about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property of our Services, or other users; or (d) in an emergency to protect the health and safety of our customers or the general public.


C. CHILDREN

The features, programs, promotions, and other aspects of our Services requiring the submission of Personal Information are not intended for children. We do not market and do not knowingly collect Personal Information from children under the age of 16. Certain benefits of our Services may be restricted to adults, age 18 or older. If you are a parent or guardian of a child under the age of 16 and believe he or she has disclosed Personal Information to us, please contact us here. A parent or guardian of a child under the age of 13 may review and request deletion of such child's personally identifiable information as well as prohibit the use thereof. If we discover that we have inadvertently collected information from a child under 13 years of age, we will promptly take all reasonable measures to delete such information from our systems.


D. KEEPING YOUR INFORMATION SECURE

We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse, and alteration of the information under our control. Please be advised, however, that while we strive to protect your personal data and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online or through our Services, and are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information. In the unfortunate event that your Personal Information (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by email (at our sole and absolute discretion) to the last email address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.


E. OTHER SITES/THIRD-PARTY LINKS

Our Services may link to or contain links to third-party websites that we do not control or maintain, such as in connection with purchasing products we may recommend or reference via our Services and/or advertisements you may see while using our Services. We are not responsible for the privacy practices employed by any third-party website. We encourage you to note when you leave our Site and to read the privacy statements of all third-party websites before submitting any Personal Information.


F. CONTACT & OPT-OUT INFORMATION

You may contact us as provided below if: (a) you have questions or comments about our Privacy Policy; (b) wish to make corrections to any Personal Information you have provided; (c) want to opt-out from receiving future commercial correspondence, including emails, from us or our affiliated companies; or (d) wish to withdraw your consent to sharing your Personal Information with others.

Email:  support@onthejobglobal.com
 

We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable, to the extent required by applicable law. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services. 

G. SOLE STATEMENT

This Privacy Policy as posted on this Site is the sole statement of our Privacy Policy with respect to our Services, and no summary, modification, restatement or other version thereof, or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to the Site.

H. YOUR RIGHTS

Users have the following rights:

  • To access the Personal Information we maintain about you;

  • To be provided with information about how we process your Personal Information;

  • To correct your Personal Information;

  • To have your Personal Information erased;

  • To object to or restrict how we process your Personal Information; and

  • To request your Personal Information to be transferred to a third-party.

To exercise the above rights, you may contact us here. We will consider and process your request within a reasonable period of time.

I. RETENTION OF PERSONAL DATA

We will retain your Personal Information only as long as necessary to process your request or other submission, fulfill the terms of our service contract with you, and comply with applicable law. 

J. HOW TO WITHDRAW CONSENT

At any time, users may withdraw consent you have provided to us for using, disclosing, or otherwise processing your Personal Information. You may withdraw your consent by contacting us here and following the instructions in our communication to you.

Please note that your withdrawal of consent to process certain Personal Information about you (1) may limit our ability to deliver services to you and (2) does not affect the lawfulness of our processing activities based on your consent before its withdrawal.


K. MODIFICATIONS TO THIS PRIVACY POLICY

We generally keep this Privacy Policy posted on our Site. You should review this Privacy Policy frequently, as it may change from time to time without notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy. WHEN YOU USE OUR SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP USING OUR SERVICES. Please note, however, that if we decide to use your Personal Information in a manner materially different than what is provided in this Privacy Policy or what we advised at the time it was collected, we will notify you of this change by email to the last email address provided to us or through our Sites and/or Services. You will have a choice (by means of an “opt-out” opportunity) as to whether or not we use your information in this different manner. If you opt out, we will use your Personal Information in accordance with the terms in place when the information was collected.