For purposes of the General Data Protection Regulation 2018 (“GDPR”), the data controller is Goghgo, Inc., an Arizona corporation, c/o Crampton Law Firm, P.C., 2155 W. Pinnacle Peak Road, Suite 201, Phoenix, Arizona 85027.
When users access the Site and view information about us and our technology, communicate with us, download whitepapers, and register for events etc, we are the data controller.
- the user’s employer is the data controller with respect to the user information it provides to us. This information typically includes first name, last name, and business email address. Where your employer is data controller in this way, we act as a data processor under data protection laws, meaning we use the information to provide a service to your employer.
- The ITIL Premier Club is the data controller for information provided directly by the individual or as a result of interacting with the Site, including assessment data, a secondary email address, additional profile details such as job title, personal website URL, a short bio, social platform handles, and demographic information such as your gender, year of birth, and your work industry. To be clear, none of these additional profile details are required to utilize the Site, but we can offer you an enhanced experience if you provide it.
Your trust is very important to us and we do our very best to adhere to ethical standards in gathering, using, and safeguarding any information you provide.
We may record information about your usage, such as when you use the Site, the contacts you communicate with and the videos you watch on the Site.
We may track your movement on the Site to enable you to download or print course transcripts and/or certificates of completion.
We may automatically collect information from you each time you visit the Site. This includes technical information, information about your visit, and information about your activity on our Site such as courses searched and viewed, page response times, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks and mouseovers), methods to browse to and away from a page, and methods used to contact our support team.
HOW WE COLLECT INFORMATION
We collect personally identifiable information directly from you when you create an account with us, complete a form on our Site, or otherwise interact with us via telephone, email or at a live event. We also use technology to collect information from you.
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser that enables the Sites or service providers’ systems to recognize your browser and capture and remember certain information. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.
We use the following types of cookies:
Strictly Necessary Cookies. These are cookies that are required for the operation of the Site and under our terms with you. They include, for example, cookies that enable you to log into secure areas of the Site, use a shopping cart or make use of e-billing services.
Analytical/Performance Cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Site. This helps us improve the way the Site works.
Functionality Cookies. These are used to recognize you when you return to the Site. This enables us, subject to your choices and preferences, to personalize our content and remember your preferences.
Targeting Cookies. These cookies record your visit to the Site, the pages you have visited and the links you have followed. We use this information to make the Site more relevant to your interests.
This Site also includes certain components transmitted by Google Analytics, a web traffic analysis service provided by Google, Inc. (“Google”). Also in this case, they are third party cookies collected and managed anonymously to monitor and improve the performance of the Site. Google Analytics uses the cookies to collect and analyze anonymously the information on the behavior of use of the Site. This information is collected by Google Analytics, which processes in order to prepare reports for the Company regarding activities on the Site. This Site doesn’t use the analysis tool of Google to track or collect personally identifiable information.
Web beacons (a.k.a. clear gifs) are tiny graphics with a unique identifier, similar in function to cookies, which are used on our Site to track online movements of web users and compile aggregated statistics to analyze how our site is used and may be used, in our services, or in our emails. Our use of Web beacons also includes to count visits and to tell if an email has been opened and acted upon. We do not link the information gathered from web beacons to any personally identifiable information.
As is true of most web sites, we gather certain information and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exist pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this data to personally identifiable information.
You have a variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies.
We also collect information we receive about you from third parties that we work closely with to provide, promote, and improve our services. These third parties include business partners, vendors who assist in technical and payment services, advertising networks, analytics providers, and search information providers.
SOCIAL MEDIA WIDGETS
HOW WE USE YOUR INFORMATION
Information you give to us:
We use your personal information to provide our services on our Site, including services arising from any obligations set forth in a contract between you and us. These services may include providing access to our course library, administration of your account, billing, and notifying you of changes to our service or your account. This data will also be used to allow you to participate in the interactive features of our Site or to provide you with information you may have requested from us, including whitepapers, access to webinars, or the like.
We also use your personal information together with other personally non-identifiable information to help us better understand our users, to personalize and improve your experience with our Site, and to improve the content and functionality of our Site. This may include providing information about our goods and services, and those of third parties, that we feel may interest you and enhance your interaction with our Site. We will communicate with you about these goods and services via email, direct mail, telephone, or on our Site. These communications may include newsletters, promotional emails, product updates, or market research requests. We will use your information for this purpose only if you have given your consent to receive marketing material from us at the point we collected your information, where required by law, or otherwise in our legitimate interests, provided these interests do not override your right to object to such communications.
Information we collect about you from your use of our Site:
We will use this information in our legitimate interests (where we have considered these are not overridden by your rights), to administer our Site, and for internal operations, including troubleshooting, data analysis, testing, research, and statistical survey purposes. We will also use this information to keep our Site safe and secure, for measuring the effectiveness of how we present content and how we market and advertise. We use Internet protocol addresses and non-personally identifiable information in our log files to analyze trends, to administer our Site, to track users’ movements in and around our Site, and to gather demographic information about our user base as a whole. We also utilize unstructured machine learning technologies to understand user behaviors and to provide user-specific recommendations and other personalization of our Site experience.
Information we receive from other sources:
We will combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR DATA TO THIRD-PARTIES
We consider your personal information to be a vital part of our relationship with you and do not sell your personal information to third parties. There are, however, certain circumstances in which we may share your personal information with certain third parties, as follows:
Agents, Consultants and Related Third Parties: We sometimes hire other companies to perform certain business-related functions, such as sending email on our behalf, payment processing, or conducting market research. We also share your email address with third parties, such as Facebook, LinkedIn, and Twitter in order to provide custom marketing materials for you on their platforms. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These companies are not permitted to use any personal information that we share with them for any other purpose aside from providing services to us.
Business Plan Subscriptions: We partner with certain third parties to provide our services to their employees. As part of such relationship, a third party may pay for the subscription for its employees or otherwise contract with us to make your subscription available to you, and we may share information about your use of our services with the third party. If your subscription was provided by your employer we may share information you provide, or information we may otherwise collect through your registration and use of our services, with such third party. This information may include course viewing history, course viewing time, course or assessment completion, course quality ratings and feedback, certifications, performance-related metrics, and other personal information.
Exam Institutes: We may give your information to applicable Exam Institutes if authorized by you.
Legal Process: We may need to share your information with law enforcement or government agencies in response to a subpoena, state and/or federal audit or as otherwise required by law.
Third Party Marketing: We will not sell your personally identifiable information to third parties for the purpose of such third parties' sending unsolicited offers or advertisements.
Platform Providers: Some of the courses available on the Site are delivered by other training platforms, which is plainly disclosed on the applicable courses. For courses offered on other training platforms, your name and email address are shared with that platform provider in order to make the course available to you. Third party platform delivery parties are contracted with us and have agreed to not to sell or market anything to you.
Business Transfers: In the event that we sell all or part of our stock or assets or enter into a merger, we reserve the right to include personally identifiable information and non-personally identifiable information among assets transferred to the acquiring or surviving company.
Data Analytics: We may provide non-personally identifiable information about our customers’ sales, Site traffic patterns and related Site information to third party advertisers.
Public Forum: The Site may, from time to time, make chat rooms, message boards, news groups, or other public forums available to its users, whether by way of our own services or by way of the services or features of a third party. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these areas and avoid posting any personal or sensitive information. If a separate login is required to use these areas, please be aware that you may need to also log out separately.
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
Right of Access and Portability. The right to obtain access to your personal information along with certain information, and to receive that personal information in a commonly used format and to have it ported to another data controller.
Right to Rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
Right to Erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
Right to Restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
Right to Object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
You have the right to request that we do not process your personally identifiable information for marketing purposes. You can exercise your right to prevent such processing by using the “Unsubscribe” link found in our emails or by contacting us at 877.546.4446 or [email protected] Please note that we may not include the opt-out information in e-mails that are transactional in nature and are not marketing communications.
If you are a California resident, California law permits you to request certain information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please use the contact information above.
You may exercise your rights via telephone or email. Please call 877.546.4446 to review, change or correct information or email a request to review, change or correct information to: [email protected]
You can delete your account and all personally identifiable information associated with your account at any time contacting us at 877.546.4446 or [email protected]
You should receive an email confirming the deletion of your account and all personally identifiable information. Please contact us if you do not receive confirmation within 30 days of your request.
The Company is not responsible for the privacy practices or policies of any third-party websites that are linked to the Site. The Site may contain links to other web sites not operated or controlled by us. The policies and procedures described here do not apply to web sites or other services that we do not operate or control. These links from our Site do not imply that we endorse or have reviewed those web sites or other services. We encourage you to read their respective privacy policies prior to providing any personal information at or to such sites.
DATA STORAGE AND SECURITY
The information that we collect is stored in our database, which is secured through password authentication. Your information may be stored on our servers and also on servers of companies that we hire to provide services. In each case, information may be stored in the United States and in other countries where we operate, and in countries where our respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that we may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region.
We understand that security of your personal and financial information is important to you, so we have taken steps to enhance the safety and confidentiality of personal and financial information sent to or from us. Company uses commercially reasonable efforts to maintain the security of the Site and your information.
Access by you to your account is available through a password and/or unique user name selected by you. This password is encrypted. You should not divulge your password to anyone. You should change your password often using a combination of letters and numbers, and you should ensure you use a secure web browser. We cannot be responsible for activity that results from your own neglect to safeguard the secrecy of your password and user name. If you share a computer with anyone, you should always log out of your account after you are finished, in order to prevent unauthorized access.
Please notify us as soon as possible if your user name or password is compromised.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personally identifiable information, you acknowledge that: (a) there are security and privacy limitations of the Internet that our beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.
If we become aware of a data breach that is likely to result in a risk for the rights and freedoms of individuals, we will notify you within 72 hours of first having become aware of the breach.
Notwithstanding the foregoing, Company provides the Site "as is" without any express or implied warranty of any kind, including warranties of merchantability, reliability, or fitness for a particular purpose.
To report any known or suspected privacy or security breaches or to submit privacy related questions or complaints please contact us at [email protected]