This Policy is effective as of: February 6, 2023.
For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:
- Scope of this Policy
- Information We Collect, Use and Share
- Processing by Others
- Your Rights and Choices
- Securing and Retaining Personal Information
- Children’s Privacy
- Annual Notice for California Residents
- Non-U.S. Concerns
- How We Handle EU Data
- Contacting Nuventive, LLC
Scope of this Policy
This Policy covers only the Services identified above, and does not apply to information which you may send us by other means. Other Nuventive sites, locations and services, whether online or offline, may have their own privacy policies, and you should consult those accordingly.
If you do not agree with the terms of this Policy, please do not provide any Personal Information to Nuventive or use our Services. However, please note that some of our Services can only be offered if you provide or allow us to collect your Personal Information.
Nuventive reserves the right to make changes to this Policy at any time. Since this Policy may change as we modify or expand our Services, we suggest that you check back from time to time in order to understand how we treat your information. Our Policy’s effective date will always be set forth at the beginning and end of the Policy. Any changes will be immediately incorporated into this Policy.
Any change to this Policy is effective immediately. Your continued use of the Services after any changes are made constitutes your acceptance of any new terms in the Policy, as revised. If any changes are unacceptable to you, you should cease all use of the Services.
Information We Collect, Use and Share
Personal information is generally defined as information that, by itself or in combination with other information, identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household (“Personal Information”). Personal Information can include, but is not limited to, your name, address, telephone number, email address, username and password, IP address or other online identifiers, browsing or search history, credit/debit card number or other financial information, professional or employment-related information, office address and other business information, demographic information, consumer preferences, biometric information such as fingerprints, precise location information, or any other type of information that, directly or indirectly, can be linked to or is reasonably capable of being associated with you.
When you use Nuventive’s Services, we may collect, use and share the following categories of Personal Information as described in this table:
|Categories of Personal Information we collect||We may collect this Personal Information from or about you when…||We collect this Personal Information so that we may…||Types of third parties that may receive this Personal Information|
|Contact information and other data that could be used to identify or communicate with you, including your name, alias, signature, mailing address, email address, telephone number, fax number, company name, job title, role or other professional or business information, and any inferences we might draw from such information.||Registering for a webinar;|
Submitting a request for information;
Signing up to receive mailings, newsletters, e-mail updates or other communications about Nuventive products and services which may be of interest to you;
Ordering and paying for Nuventive products and services;
Contacting Nuventive with questions or comments;
Interacting with us at conferences;
You allow us to visit you;
Supply it to customer lead generation providers;
We receive it through word-of-mouth referrals from Nuventive’s existing customers; or
It is otherwise provided to us in the content of any communications you direct to Nuventive.
|Process and respond to your requests for information;|
Administer webinar services;
Process payment information when you order a Nuventive product or service;
Communicate with you regarding the status of your subscription;
Respond to your questions and comments;
Provide you with information on other products, services, promotions and other updates in which Nuventive or our business partners think you may be interested;
Provide customer service; or
Verify customer information.
Marketing firms including email marketing vendors;
Web hosting and cloud service providers;
Data analytics suppliers;
Business partners that help us provide our products and services;
Product experts and technology consultants; or
Legal compliance advisors.
|Demographic information such as your job title, role, other professional interests, and any inferences we might draw from such information.||Applying for a position on the Careers section of our Site.||Process your application and contact you regarding the status of your job application.||Web hosting and cloud service providers.|
|First-party cookie identifiers set directly by Nuventive, which may include information on your interaction with the Services, any Nuventive application, or any Nuventive ad, and any inferences we might draw from such information.||Visit our Site or use the Services, automatically.||Recognize you on return visits to the Services;|
Analyze how you interact with our Services;
Detect security incidents;
Undertake activities to verify, maintain and improve the quality or safety of the Services;
Debugging to identify and repair errors that impair existing intended functionality with the Services;
Conduct internal statistical data analysis and service testing;
Undertake internal research for technological development and demonstration; or
|Web hosting and cloud service providers; or |
Data analytics suppliers.
|Third-party cookie identifiers, internet protocol (IP) addresses, pixels and other online identifiers, browsing history, search history, information on a consumer’s interaction with a website, app, or advertisement, and any inferences we might draw from such information.||Visit or use our Site, automatically, to the extent this information is collected from you and providers of data analytics and related vendors.||Monitor how you use our Services; or|
Provide you with information on new products, services, promotions and other updates in which we think you may be interested.
|Data analytics and related service providers.|
Nuventive collects certain aggregated data based on how educational institutions use our Services, which Nuventive uses to help providers of educational services improve strategy, accreditation, graduation rates, retention, learning outcomes, general education, housing, sustainability, administrative outcomes, program review, diversity, and more (“Educational Data”). Educational Data may include certain aggregated demographic information, such as statistics about the age or gender of students as a group, but Nuventive generally is not able to associate the Educational Data provided by educational institutions with any specific individuals. Nuventive may use and share aggregated Educational Data with your employing educational institution in a format that is not reasonably capable of identifying students and other individuals, but we cannot guarantee that educational institutions will be unable to combine Educational Data in such a way that it becomes Personal Information.
Nuventive does not knowingly collect “Sensitive Personal Information,” which is typically defined under privacy laws to include social security numbers, driver’s license or passport numbers, or private information about an individual such as a person’s race, ethnicity, sexual orientation, health, finances or precise geolocation.
In addition to the practices described in the table, above, we may also use or disclose any of the above categories of Personal Information we collect for one or more of the following reasons:
- To carry out our obligations and enforce our rights arising from any contracts related to your use of the Services, including for billing and collections;
- As necessary or appropriate to protect the rights, property or safety of Nuventive, our customers or others;
- To respond to law enforcement requests and as required by applicable law, subpoena, court order, other legal process or governmental regulations;
- As otherwise described to you at or before the point when we collect your Personal Information; or
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or to transfer 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 us is among the assets transferred.
Nuventive does not use your Personal Information in automated decision-making or for profiling purposes.
By providing to Nuventive the Personal Information and other data referenced above, you agree that we may use the Personal Information and other data in accordance with the terms of this Policy. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Processing by Others
We may disclose certain portions of your Personal Information to service providers, vendors or other third parties as necessary for the business purposes described above. These third-party providers will have access to certain data, which may include Personal Information, as needed to perform their functions but cannot use that information for any other purpose.
Data Processing through Nuventive’s Software Platforms and Solutions
The Services include a data integration and management platform and other software-based products and solutions for education organizations to unify and utilize data across software applications, which includes third-party technology and services provided by Microsoft. Microsoft may collect or have access to certain portions of your Personal Information as a result of this processing and your Personal Information may be held on a cloud platform located in a jurisdiction that may not afford the same level of privacy protection as the jurisdiction in which you reside. For more information about how Microsoft handles any Personal Information it receives through your use of Nuventive’s Services, please review Microsoft’s privacy practices as described at https://privacy.microsoft.com/en-us/privacystatement. If you would like to make any requests regarding Microsoft’s collection and use of your Personal Information, please see the options available at https://privacy.microsoft.com/en-US/privacy-questions.
Microsoft may provide Nuventive with crash data and other information related to “bugs” or other potential issues with our platforms and other software products or solutions (“Error Reporting Data”). Error Reporting Data may contain portions of your Personal Information. Nuventive uses Error Reporting Data solely for the purpose of testing and resolving compatibility issues, fixing and resolving bugs or other quality issues, and does not disclose it for any purpose.
Nuventive may share certain data that could be combined with other information to become reasonably capable of identifying you, such as your IP address or cookie identifiers, to Microsoft for use in connection with advertising services to send you information about products you might be interested in based on your use of the Services and your activity elsewhere online. You may be able to opt-out of Microsoft’s cross-product interest-based advertising at https://choice.live.com/advertisementchoice/.
Cookies and Data Processing through the Site
In the course of maintaining our Site, Nuventive may use third-party cookies to analyze how visitors and customers interact with our Site, and for other purposes as described above.
Nuventive does not currently sell Personal Information to third parties for monetary consideration, but certain third parties may get access to cookie-related information about you or your browsing history as referenced above, for the purpose of providing you online advertising that is personalized to your interests based on your browsing behavior. To the extent any of this sharing or third-party access may be considered a “sale” of your Personal Information under applicable privacy laws and regulations, or if you otherwise have the right to opt-out of sharing for targeted advertising purposes, you may exercise choices regarding such sharing or third-party access, as described in the “Your Rights and Choices” section, below. You are not required to accept Nuventive’s use of certain third-party cookies. However, certain functionality of the Site or other Services may not work properly (if at all) if you reject all cookies.
For example, Nuventive may use third-party analytics service providers such as Google Analytics, which could automatically collect certain Personal Information and other data about you through the Site including, but not limited to, your IP address and/or other online identifiers. Third-party cookies or other tracking technology may be used through this process to track data such as the times you most frequently use the Site, what devices you use to access the Site, what parts of the Site you visit and the links you use to get there. Nuventive may then use feedback from these analytics service providers to improve the Site and our interactions with you and other users of the Site. Our vendors, such as Google Analytics, may share this information with other third parties, if required to do so by law or if those third parties process the information on behalf of Google Analytics. An overview of Google’s data privacy practices for Google Analytics may be available at https://support.google.com/analytics/answer/6004245, and a general description of Google’s privacy practices may be available at https://policies.google.com/privacy. To opt-out of being tracked by Google Analytics, you may be able to download and install the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. Google’s analytics services also may cause you to receive personalized ads based on your browsing behavior. You may be able to opt-out of receiving these personalized ads by using the settings at https://adssettings.google.com/.
You can also generally opt-out of receiving targeted ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) by visiting http://optout.networkadvertising.org/. You may opt-out of receiving targeted advertisements from other companies that perform interest-based advertising services via the Digital Advertising Alliance (DAA) site at http://optout.aboutads.info/. Please note that when using the ad industry opt-out tools described above, you may need to execute opt-outs for each browser or device that you use, and that other companies’ opt-outs may function in different ways.
Certain areas of the Site may integrate with social media sharing services for which you have an account, which will let you share content from the Site with other third-party sites or online services. Your use of such features may enable the sharing of information with your friends or the public, depending on the settings you established in your account with the relevant social sharing service provider. Please review the privacy policies of those social media service providers for more information about how they handle the information you provide to or share through them and how you may be able to exert your privacy rights directly with such social media service providers.
Nuventive neither collects nor sells the Personal Information of minors under 16 years of age.
Except as noted herein, Nuventive does not share your Personal Information with any person or entity outside of Nuventive.
Your Rights and Choices
Depending on where you reside, you may submit requests related to one or more of the following rights that you may have under applicable law (subject to certain exceptions) with regard to Nuventive’s collection, use and sharing of your Personal Information on or through the Services:
- The right to request details about what Personal Information we collect, use, disclose or sell about you, including –
- The categories and sources of Personal Information that we collected about you;
- Whether we sold, shared or disclosed your Personal Information;
- Our business or commercial purpose for collecting, selling, or sharing your Personal Information;
- The categories of recipients of your Personal Information; or
- The specific pieces of Personal Information that we collected about you (also called a data portability request), unless the disclosure of such information is prohibited by law.
- The right to request the deletion of Personal Information we collected or maintain about you, subject to applicable legal exceptions.
- The right to opt-out of the sale of your Personal Information (if Personal Information is sold), or any sharing that could result in you receiving targeted advertising based on your online activity.
- The right to request that we correct inaccurate Personal Information that we have collected and maintain about you, subject to applicable exceptions.
- The right not to receive discriminatory treatment by Nuventive, in terms of the services and prices offered on or through our Services, because you exercised these rights regarding the collection, use and sharing of your Personal Information.
If you would like to submit requests to access, review, edit, delete or have us properly dispose of any copies of the Personal Information that Nuventive collected about you (subject to any applicable legal exceptions), if you would like to opt-out of receiving further information or limit what we share, or if you would like to exercise the above rights in any other way, please contact us at email@example.com or call us at +1 412 847 0280 (Toll Free: +1 877 366 8700).
You may be able to opt-out of Nuventive sharing your Personal Information with certain entities identified in this Policy for purposes of targeted advertising by sending us an email at the address above or by visiting this portal, unless the sharing of your Personal Information is necessary to perform a legitimate business purpose permitted under applicable law.
Nuventive will do its best to accommodate any request to delete or properly dispose of any copies of your Personal Information, but we cannot guarantee we can eliminate all Personal Information from the specified uses beyond what is required under applicable law. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information. Therefore, please be as specific as possible in any request to delete or dispose of copies of your Personal Information. If the request relates to information that Nuventive needs to make certain Services function properly for you, you may not be able to use those Services properly moving forward.
If you choose to delete certain portions of your Personal Information, it may affect your ability to use certain Nuventive Services. If the request relates to information that Nuventive needs to make certain Services function properly for you, you may no longer be able to use those Services. Any removal of content by Nuventive does not ensure or guarantee complete or comprehensive removal of the content in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information.
You may grant an authorized agent written permission to submit requests regarding your Personal Information, but we may deny authorized agent requests absent proof that you authorized such agent to act on your behalf, or if we are unable to verify your identity directly as the subject of the Personal Information at issue.
You are permitted to make a verifiable consumer request to know information twice within a 12-month period. Each verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person who is the subject of the Personal Information at issue (or an authorized representative of such person). Any request you submit also must include enough detail so that we can properly understand, evaluate, and respond to it. Nuventive is required to verify the identity of any person or entity that requests the disclosure or deletion of Personal Information. For most consumer requests, Nuventive will ask you to provide information that matches at least two pieces of Personal Information we store about you before responding to your request. If you would like to request the specific pieces of your Personal Information that Nuventive has collected, or if you would like us to delete highly sensitive information, you will need to match at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the person whose Personal Information you are requesting.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us. We do not charge a fee to process or respond to your verifiable consumer 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.
Nuventive reserves the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain portions of your Personal Information.
By using the Services, you agree that Nuventive may send you promotional emails about other Nuventive products, services and features you may find useful. If you would like to opt-out of receiving promotional emails from Nuventive, please follow the opt-out instructions at the bottom of the email or send Nuventive a detailed email at firstname.lastname@example.org.
As mentioned above, Nuventive does not currently have the capability to process “do not track” signals or other automated technical requests. To learn more about ways to opt-out of certain kinds of targeted advertising networks, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific, and there is no guarantee that these industry-provided opt-out tools will prevent all targeted advertising.
Also as noted elsewhere in this Policy, it is possible that certain third parties may collect or receive data from you when you use our Services, such as analytics providers or other entities that collect and process device-related information for Nuventive or on our behalf. Since some of these third parties may respond differently than Nuventive to “do not track” and similar automated requests that may relate to tracking for purposes of targeted advertising, you should consult the applicable privacy policies of those third parties for that information.
Securing and Retaining Personal Information
Nuventive has physical, electronic and procedural safeguards in place, including an information security policy, to protect Personal Information provided to Nuventive or stored in Nuventive software applications from loss, theft, misuse and unauthorized access, disclosure, copying, use, alteration and destruction. Such safeguards, however, do not and cannot prevent other users from gaining access to the program, with the permission or by the designation of the licensed subscriber, from being able to view, copy, modify or disclose information contained within the application. Although we cannot guarantee the security of Personal Information provided to Nuventive or stored in a Nuventive software application, Nuventive believes that its security policies and safeguards are reasonable and appropriate to adequately protect such information, regardless of the format in which such information is held. Nuventive intends to review and update its security policies and safeguards on a regular basis. Nuventive requires that its employees keep all Personal Information confidential and comply with its information security policy and privacy practices. Nuventive uses reasonable efforts to ensure that upon disposal or deletion of Personal Information, confidentiality of the information is maintained.
While Nuventive takes the issue of protecting your Personal Information seriously, you should exercise discretion in what you disclose and/or transmit through the Services. Nuventive cannot guarantee that information sent over the internet is fully secure, and therefore the transmitted information may be intercepted by others before it reaches Nuventive. If you are concerned about sending information to Nuventive over the internet, please send the information by mail or call us to make other arrangements. Nuventive is not responsible for the security of information sent over the internet.
For each category of collected Personal Information described in this Policy, Nuventive retains each such collected category of information for a reasonable amount of time in order to fulfill the stated purpose for why the applicable information was collected. The retention periods for each category of collected Personal Information will depend on the relative sensitivity of the data at issue, and whether the applicable Personal Information is subject to retention due to contractual or legal requirements. For example, with respect to contact information like your email address and other data that could be used to identify or communicate with you, we may maintain that data to the extent you continue to have an ongoing contractual relationship with us. Similarly, demographic or professional information such as your job title may be retained for as long as you maintain an ongoing relationship with us. Cookie-related data such as IP addresses and other technical identifiers related to the devices you use generally will only be stored for as long as there is a reasonable basis for such data to be retained.
Further information regarding Nuventive’s retention periods is available, below:
|Contact information and other data that could be used to identify or communicate with you||Retained for 3 years after last interaction|
|Contact information and other identification data used in the context of the receipt or provision of goods or services||Retained for 7 years after the end of the relationship|
|Demographic information (in an employment or recruitment context)||Retained for 1 year after the employment or contractor relationship ends|
Information collected through first-party cookies generally will be retained until you log out of your account for our platform or stop using Nuventive’s Services.
Any Personal Information collected through the use of third-party cookies on our Site may be retained for a 24-hour period, with respect to cookies that monitor page views and other Site usage data. Other third-party cookies that are used for technical monitoring purposes may store the online identifiers they collect for 1 year. For more information about how third-party cookie providers such as Google Analytics may retain the Personal Information and other data they collect, an overview of the data privacy practices for Google Analytics may be available at https://support.google.com/analytics/answer/6004245, and a general description of Google’s privacy practices may be available at https://policies.google.com/privacy.
Nuventive will also retain collected information connected to business records for periods of time required by law, which may be longer than the timeframes listed above. If Nuventive determines that collected information is no longer needed, it will delete such information. Our collection times will be consistent with applicable law. If you have any questions about the security or retention of your Personal Information, you can contact us at email@example.com.
Nuventive’s Services are intended for individuals 16 years of age and older. Our Services are not directed at, marketed to, nor intended for, children under 16 years of age. Nuventive does not knowingly collect, process or sell any information, including Personal Information, from children under 16 years of age. If Nuventive learns that it has collected any information regarding a person younger than 16 years of age, Nuventive will delete or destroy the information immediately.
If there is concern that information regarding a person younger than 16 years of age was somehow collected by Nuventive, any minor, or the parent(s) or legal guardian(s) of such minor, who wishes to request the removal of the minor’s information should submit their request by using the contact details provided in the “Contacting Nuventive, LLC” section below.
Annual Notice for California Residents
In the preceding 12 months, we have collected Personal Information from the sources identified, above, and used and shared Personal Information with the categories of recipients for the business and commercial purposes described in the table that is included as part of the section titled “Information We Collect, Use and Share.”
For example, over the past 12 months, Nuventive has permitted analytics service providers and online advertising providers to process cookie identifiers and IP addresses collected through Nuventive’s Site for purposes of cross-contextual advertising based on your browsing behavior, which may be considered “sharing” or a “sale” of Personal Information under California law, as described above. California residents may learn about how to exercise their rights under California law in the “Your Rights and Choices” section above. For example, you may be able to opt-out of Nuventive sharing your Personal Information with certain entities identified in this Policy for purposes of targeted advertising by sending us an email or by visiting this portal, unless the sharing of your Personal Information is necessary to perform a legitimate business purpose permitted under applicable law.
If you provide information to Nuventive from outside of the United States, you do so at your own risk. If you are outside of the United States, you are responsible for complying with any local laws regarding use of the Services, and related data collection. You also agree and acknowledge that by providing any information, including Personal Information, through the Services, that such information will be transmitted to, and stored in, the United States.
How We Handle EU Data
If you reside within the European Economic Area (the “EEA,” which includes the 27 European Union Member States, Iceland, Norway and Liechtenstein), Switzerland or the United Kingdom (collectively, the “EU”), then Nuventive handles your Personal Information and data according to the terms of this Policy, unless the exceptions in this section apply, pursuant to the General Data Protection Regulation (“GDPR”).
Nuventive will collect, process and use your Personal Information as described in this Policy and for the purposes set forth in this Policy. With the exception of uses for which we have obtained your consent, your Personal Information is processed in support of legitimate interests as described in this Policy.
If you reside within the EU, we will seek your consent before using your Personal Information to serve you relevant content and educational materials based on your personal preferences, interests, location and other information that you provide to Nuventive in connection with your use of the Services.
Under the GDPR, users in the EEA have the following rights regarding Nuventive’s processing of Personal Information:
- the right to request details on the Personal Information we hold about you at any time;
- the right to update and correct any inaccurate Personal Information Nuventive holds about you;
- the right to withdraw any consent for marketing activities or processing of Personal Information that you might have provided to Nuventive;
- the right to request erasure of Personal Information;
- the right to request restriction of Nuventive’s processing of your Personal Information;
- the right to object at any time to Nuventive’s processing of Personal Information concerning you; and
- the right to request the portability of Personal Information you provided to Nuventive.
If you would like to review, edit or delete any of the Personal Information Nuventive collected from you, if you wish Nuventive to stop using your Personal Information in the manners specified in this Policy, or if you would like to exercise the rights listed above in any other way, please contact us using the contact details provided below.
Under the GDPR, users in the EEA also have the right to lodge a complaint about Nuventive’s processing of your Personal Information with a supervisory authority. In particular, such users may lodge a complaint in the Member State where the user lives or works or where the alleged violation took place.
To protect your Personal Information, Nuventive’s Services use appropriate technical and organizational security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information and other data stored on our Services.
Nuventive retains Personal Information only for as long as necessary to fulfill the stated purpose for which the Personal Information was collected or otherwise processed, and thereafter for a variety of legitimate legal or business purposes. These may include retention periods that are: (i) mandated by law, contract or similar obligations applicable to Nuventive’s business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records. We will delete your Personal Information as soon as the respective purpose of use is not applicable anymore and no legal obligation to retain such data exists. If you have any questions about the security or retention of your Personal Information, you can contact us at firstname.lastname@example.org.
Your Personal Information may be disclosed to and processed by staff operating in the United States. Disclosure will be to individuals who work for Nuventive, our subsidiaries, related companies, and companies with which we have contracted to process or store this data on Nuventive’s behalf. The individuals and organizations that receive Personal Information as a result of international transfers out of the EU must follow our express instructions with respect to the use of Personal Information and they must comply with appropriate security measures to protect your information.
Contacting Nuventive, LLC
If you have any questions or comments about this Policy, the Services, or your other interactions with Nuventive, you can contact:
9800B McKnight Road
Pittsburgh, PA 15237 USA
Phone: +1 412 847 0280 (Toll Free: +1 877 366 8700)
Fax: +1 412 847 0285
Nuventive intends to strictly enforce this Policy. If you believe there has been some violation of this Policy, please contact Nuventive.
This Policy was last updated on February 6, 2023.