Pryor Learning, LLC Privacy Notice

Last Updated/Effective Date: May 4, 2024
Pryor Learning LLC, its affiliates and its subsidiaries (“Pryor Learning”, “we,” “us,” or “our”) respect your privacy. This Privacy Notice describes the processing of Personal Information (defined below) that is provided, collected, or shared on the sites, applications, social media pages, and other platforms that link to this Privacy Notice (collectively, the “Site”), or in connection with the provision of products or services to you (the “Services”). It also describes rights you may have under applicable laws.

1. PERSONAL INFORMATION WE COLLECT

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we collect may include:

• Contact Information – If you submit an inquiry, register for an account, or provide information on our Site or through our Services, we may collect your contact information. This may include your name, address, email address, demographic information, and phone number.
• Commercial information – This includes information about purchases, information about subscriptions, products and services you have shown interest in, payment processing information, and other commercial information.
• Usage Information – When you use our Site or Services, our servers may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, or other information regarding your interaction with the Site or Services.
• Communication Information – We may collect the contents of your communications with us, whether via email, chat functionality, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality. We also may engage a third-party chatbot service provider. The chatbot service provider has its own privacy policies and procedures with regard to the collection and processing of your Personal Information.

2. HOW WE COLLECT YOUR PERSONAL INFORMATION

• Directly From You – We collect Personal Information directly from you. For example, if you choose to contact us, request information from us, and/or use our Site or Services.

• From Third Parties – We collect Personal Information from third parties. For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.

• Online Tracking Technologies – We may use cookies and similar technologies such as pixels and web beacons to collect Personal Information related to your online activity on our Site. For additional information regarding our use of these technologies, see Section 5 below.

3. HOW WE USE PERSONAL INFORMATION

To the extent permitted by applicable law, we may use Personal Information to:

• operate the Site, provide our Services, and provide support to our business functions;
• fulfill customer requests or provide customer support;
• protect against criminal activity;
• protect or enforce our legal rights;
• send you information about our company or the Services;
• respond to reviews, comments, or other feedback provided to us;
• enhance, support, and personalize the Site and our advertising or marketing efforts;
• protect the security and integrity of the Site;
• develop new products or services
• engage in benchmarking, data analysis, or audits;
• meet our contractual requirements;
• market users for upselling and cross-selling purposes, which includes selling Personal Information;
• comply with applicable legal or regulatory requirements and our policies; and
• the extent necessary for any other lawful purpose for which the Personal Information is collected.

4. DISCLOSURE OF PERSONAL INFORMATION

We may disclose your Personal Information in the following circumstances:

• Service Providers – We disclose your Personal Information to third-party service providers as necessary to enable them to support the Site, our Services, or other aspects of our business.
• Affiliates and Subsidiaries –We may disclose your information to our affiliates and subsidiaries for their and our business purposes and for marketing purposes, including to provide you information about products or services we think may interest you.
• Business Partners – We may share Personal Information with trusted business partners. For example, we may share your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with. Additionally, with our approval, certain organizations have access to our customer list for marketing purposes. These organizations range from training providers, office suppliers, office equipment providers, business publications and other business service providers.
• Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Pryor Learning, its users, or the public against harm.
• Merger or Change of Control – If we are involved in a merger, acquisition, or any other transaction involving a change of control in our business including but not limited to a bankruptcy or similar proceeding, Personal Information may be transferred along with the business. Where legally required, we will give you prior notice prior to such a transfer.

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

We collect Personal Information and other data from cookies, pixel tags, and tracking technologies. We allow or enable third parties to collect Personal Information in order to provide their interest-based advertising services.

We use analytics services, including Google Analytics, to assist us with analyzing our website traffic. These services utilize cookies and other technologies that collect your Personal Information. We share this analytic information with HubSpot, Salesforce and Google Ads.

To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

In order to manage your preferences with respect to these technologies, please visit our preferences page. In addition, most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time.

6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. HOW WE PROTECT YOUR PERSONAL INFORMATION

We use commercially reasonable efforts to protect the confidentiality and security of Personal Information we collect and process. However, we cannot guarantee the security of Personal Information during its transmission to or from us, its storage on our systems, or that our security measures will prevent third parties from accessing or acquiring Personal Information we collect.

8. YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

Depending on where you live, you may have the following rights with respect to your Personal Information:

Privacy Right	Description
Access	The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Data Portability	The right to receive a copy of your information in a portable and readily usable format.
Deletion	The right to have your Personal Information deleted, subject to applicable exceptions.
Correction	The right to request that we correct any incorrect Personal Information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your Personal Information from our records, unless an exception applies. We may deny your correction request if (a) we believe the Personal Information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
Opt Out of Certain Processing	The right to: (a) opt out of the processing of your Personal Information for purposes of targeted advertising, (b) opt out of the sale or sharing of your Personal Information; (c) limit the use of your Sensitive Personal Information (if applicable), and (d) opt out of the processing of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effect concerning you. You can do so here.

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

You may only make a request for access or data portability twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To exercise any of the privacy rights afforded to you, please submit a request to us by one of the following methods:

• Calling us toll free at 1-800-780-8476
• Emailing us at customerservice@pryor.com
• Submitting a request through our web form https://www.pryor.com/privacy-options/

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Notice which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

9. MARKETING EMAILS

To opt out of marketing emails, please email us at customerservice@pryor.com Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our Services to you.

10. INTERNATIONAL USE OF THE SITE

This Site is hosted in the United States. As a result, the Personal Information that we collect and generate about you as you use the Site may be transferred, stored, or accessed in a destination outside of your country which may have less strict, or no, data protection laws, when compared to the laws in your country.

11. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any Personal Information from children under the age of sixteen. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information.

12. LINKS TO THIRD-PARTY WEBSITES

We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s Privacy Notice.

13. NOTICE TO CALIFORNIA RESIDENTS

California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act: This portion of this Section applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.

Sources of Personal Information

We collect Personal Information from the categories of sources detailed in the How We Collect Personal Information section above.

Use of Personal Information

We collect Personal Information for the business and commercial purposes detailed in the How We Use Personal Information section above.

Disclosure of Personal Information

The categories of third parties to whom we disclose Personal Information for a business or commercial purpose are detailed in the Disclosure of Personal Information section above. The categories of third parties to whom we sell or share Personal Information are summarized in the chart below. We do not knowingly sell or share the Personal Information of minors under the age of 16.

Categories of CA Personal Information We Collect	Categories of Third Parties to Which We May Sell or Share Personal Information
Identifiers	We do not sell this category of Personal Information. We do share this category of Personal Information with Advertising Networks, Social Networks and Third-Party Business Partners.
Personal Information, as defined in the California customer records law	We do not sell this category of Personal Information. We do share this category of Personal Information with Advertising Networks, Social Networks and Third-Party Business Partners.
Commercial Information	We do not sell or share this category of Personal Information.
Internet or other similar network activity	We do not sell this category of Personal Information. We do share this category of Personal Information with Advertising Networks, Social Networks and Third-Party Business Partners.
Inferences drawn from other Personal Information	We do not sell this category of Personal Information. We do share this category of Personal Information with Advertising Networks, Social Networks and Third-Party Business Partners.
Professional or employment-related information	We do not sell this category of Personal Information. We do share this category of Personal Information with Advertising Networks, Social Networks and Third-Party Business Partners.
Sensitive Personal Information	We do not sell or share this category of Personal Information.

California Shine the Light Act: Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us using the information in the Contact Us section below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

14. CHANGES AND ACCESSIBILITY

Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We will provide you with notice as required by applicable law if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the Site.

This Privacy Notice is available to consumers with disabilities. To access this Privacy Notice in an alternative downloadable format, please click here.

15. CONTACT US

If you have any questions about our practices or this Privacy Notice, please contact us at customerservice@pryor.com. You may also write to us at:

Pryor Learning
PO Box 783002
Dallas, TX 75373-8002