Common Sense Media: Premium Membership Privacy Policy

Effective Date of Policy: August 07, 2017

Welcome! Below you will find the privacy policy for the Premium Membership from Common Sense Media, Inc. ("we" or "us"). We are dedicated to protecting your privacy and handling any personal information we obtain from you with care and respect. The Common Sense Media: Premium Membership Privacy Policy (the "Policy" or the "Privacy Policy") is designed to answer your questions regarding how we collect, protect, use and share information obtained through the Common Sense Education Professional Development website located at: https://commonsense.csod.com (the "Site"), the Cornerstone OnDemand (“CSOD”) mobile application, and other applications ("apps") that we operate and that link to this Privacy Policy (collectively, the "Services"). Common Sense Media maintains other websites and apps, which are governed by their own privacy policies. If you are using another Common Sense Media website or app, please be sure to consult the applicable privacy policy, as it may differ from this Policy. We hope this information increases your confidence in Common Sense Media’s Premium Membership and enhances your experience on our Services.

We encourage you to read our Policy before using the Services, and not to use the Services if you disagree with any part of this Policy. By using the Services or by clicking a box that states that you accept or agree to this Policy, you signify your agreement to the terms and conditions of this Policy. In addition, please see our third-party service provider, CSOD’s privacy policy in the Appendix, which also govern the use of the Services. We also address CSOD in Section IV below.

The Services are controlled and operated by Common Sense Media, a nonprofit organization, in the United States and are not intended to subject Common Sense Media or any affiliated entity to the laws or jurisdiction of any state, country or territory other than that of the United States. We may limit the availability of the Services, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time in our sole discretion.

I. INFORMATION THAT WE COLLECT ON OR THROUGH THE SERVICES

Through the Services, you can be a part of an active and vibrant community of educators interested in premium training and professional development resources that will have a direct impact on your classroom and students. Districts who join can allow their educators to become members ("Premium Members"). Premium Members can engage in a full range of activities on our Services, such as professional development that includes, but is not limited to: completing training lessons, posting content, social interactions, earning badges, accumulating points, and participating in educator community forums.

A. Personal Information

In this Policy, when we use the term "Personal Information", we mean any information that can be used to identify or contact a specific individual, such as the individual's name, email address, or telephone number.

If you wish to become a Premium Member, your District must provide us with certain Personal Information as part of the registration process, including, for example, your name and email address. Once we have initially registered you, you will receive an email with instructions on how to complete registration, which requires additional information, such as job role, phone, zip code, location, school name, screen or preferred name, and password. You may optionally choose to provide us with certain additional information at registration, such as: interests, teaching subjects, teams and any posted articles, comments, and/or connections created through use of the Services. A district or school administrator or organizer may also provide information to the Services on behalf of an educator user that may include, but is not limited to: grade taught and school location.

Your first name and the first initial of your last name will be displayed on your public user profile (“Profile”) page and next to any reviews or comments that you post on our or Services. If you do not provide us with your name or opt out of using it, then your screen or preferred name will be displayed in your Profile and in connection with reviews and comments that you write.

You can update your Personal Information at any time by accessing your account. To do this, just click on the "My Account" or "My Profile" link.

If you decide that you no longer want to be a Premium Member, you can delete your account at any time. To delete your account, contact us at [email protected] and request that we delete your content and account for you. Once you delete your account, your Personal Information stored in your account and Profile on our site will be removed, but it is possible that Personal Information and other data that you furnished through the Services may remain in our system. We may need to retain certain information for recordkeeping purposes, and there also may be some residual information that will remain within our databases and other records (such as in backups of the Service's data), which may not be removed. In addition, please note we are unable to update or delete any of your Personal Information that has already been shared with a third party as permitted in this Policy or with your consent.

If you decide that you would like your posted comments deleted from our Services, you can do this at any time by logging into your account, viewing the comment, and clicking the "delete" button. You can also send us an email at [email protected] with your screen name, date of submitted comment, and title of media type that was commented. Please note that your request or deletion does not ensure complete or comprehensive removal of the comment, as, for example, your comment may have been reposted by another user.

PLEASE NOTE THAT WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF ANY PERSONAL INFORMATION YOU DISCLOSE IN YOUR PROFILE OR ON PUBLIC-FACING AREAS OF THE SERVICES.

We may combine the Personal Information we collect from you with Personal Information about you that we receive from other sources, such as Common Sense events, Common Sense education partners, activity on Common Sense social media platforms, and public databases.

B. Physical Location

Our Services will collect the location of your device when you are using the Services. This location information is used to allow our third-party service provider, CSOD, to provide you with school related contacts and information tailored to your school or District’s location.

C. Cookies and Other Technologies

We and our service providers may collect certain information automatically when you visit the Services, including through the use of cookies and web beacons. "Cookies" are small data files stored on your computer and identify you as a previous visitor to the Services and help us to personalize your experience when you arrive. Most web browsers are set to accept cookies. You can instruct your browser not to accept cookies. However, if you disable this function, you will not be able to use some of the features on our Services.  

Web beacons are small pieces of data embedded with images on pages of the Services or in emails, which allow us to collect information such as the number of users that have visited a web page or opened an email. We use web beacons to measure the effectiveness of our content and campaigns and how visitors use our Services. This allows us to learn what pages are most attractive to our visitors, which parts of our Services are the most interesting and what kind of offers our visitors like to see.

In addition, the information we collect may include the browser you are using (e.g., Safari, Internet Explorer, Chrome, Mozilla Firefox, etc.), the internet address from which you linked to the Services, the operating system of your computer (e.g., Microsoft Windows, iOS, Android, etc.), the unique IP address of the computer you use to access our Services and usage and browsing habits. CSOD, our portal provider, may also collect training progress, transcripts of active training, and session interaction with completed documents, badges, and points awarded through use of the Services. Please see the CSOD privacy policy in the Appendix, to learn about CSOD’s information practices.

We use the information we collect automatically to administer and improve your experience on our Services, to help diagnose and troubleshoot potential server malfunctions, and to gather use and demographic information. Some of these third parties may use this information for other purposes.  

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

D. Non-Personal Information

Non-Personal Information is aggregated information, demographic information, high-level location information (such as the browser language and country during the user session), and other information that does not reveal a person's specific identity or relate to an identifiable individual. We may collect Non-Personal Information (e.g., interests, etc.) when you voluntarily provide such information to us, such as through survey responses or upon Registration. Such information constitutes Non-Personal Information because, unless combined with your name or other Personal Information, it does not personally identify you or any other user.

Additionally, we may aggregate Personal Information in such a manner that the end product does not personally identify you or any other user of the Services. For example, we might use Personal Information to calculate the percentage of our Premium Members who live in a particular state. Such aggregate information is considered Non-Personal Information for purposes of this Policy.

II. HOW WE USE INFORMATION COLLECTED ON THE SERVICES

A. How We Use Personal Information

Fulfillment of Requests. We may use your Personal Information to fulfill the purpose for which such information was provided (e.g., to respond to your requests or inquiries and provide related customer service).

Communications. If you register to become a Premium Member of our community, we may use your Personal Information to contact you with surveys, updates, or important communications regarding Common Sense Media, such as changes to our terms, conditions, and policies. We may additionally use Personal Information to contact you about Common Sense content, features, opportunities, and products, such as our newsletters, that may be of interest to you.

Membership. If you become a Premium Member, we may use your Personal Information to maintain and update your Profile and postings in our online reviews, surveys and polls.

Internal Operations and Analysis. We may use your Personal Information for our internal business purposes, such as data analysis, audits, enhancing or modifying our products and services, and so forth.

Marketing and Advertising: We may use Personal Information to personalize your experience on the Services by presenting content and market opportunities and products tailored to you and by tailoring emails to you, and to allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. However, we do not provide any advertising on the Services.

B. How We Use Information Collected Via Cookies and Other Technologies

We use information collected via cookies, web beacons and other technologies as described above, under "Cookies and Other Technologies."

C. How We Use Non-Personal Information

Because Non-Personal Information does not personally identify you, we may use or disclose such information for any purpose. For instance, we may compile and share aggregate data about the geographic locations or other demographics of our Premium Members, provided that this information does not personally identify any of these Premium Members. Common Sense Education may share aggregated de-identified information that does not describe or identify any individual user with affiliated funders and partners. We may also use information about eLearning user activities in order to measure the effectiveness of eLearning training materials and to improve them.

III. HOW WE DISCLOSE INFORMATION COLLECTED ON THE SERVICES

Except as expressly provided in this Policy, we will not share your Personal Information without your prior consent.

Profile Information. Each Premium Member has a Profile on the Site, which includes the Premium Member's name or preferred screen name, photo, registration date, and links to the Premium Member's posted content and comments. You can change or remove any information from your Profile (except for your screen name) by logging into the Site and clicking the "My Account" or "My Profile" links located in your personal Account section.

Your Posted Comments. If you post comments on the Services, the contents of those postings may be displayed on the Services along with your name (first name, and first initial of last name) or screen name, photo, and school information.

Third Party Service Providers. In addition to CSOD, described above in sections I.C and “Cookies and Other Technologies”, we work with third parties who provide services such as data analysis, payment or donation processing, order fulfillment, infrastructure provision, information technology, content personalization, email delivery, market research and other services. We may share Personal Information about you with such third parties solely for the purpose of enabling them to provide these services to us.

Social Login: If you choose to register or login to the Services through a Social Networking Service, we will ask you for your permission to access your data on the Social Networking Service to create an account and Profile. In addition, we may use this data for several purposes, including:

  • Populating Account and Profile Fields: When you are connected via a Social Networking Service, we will pre-populate and update your account and Profile fields with data from the Social Networking Service that you allow us to access. You can update this information at any time on your Account and Profile pages.
  • Personalizing the Services: When you are connected via a Social Networking Service, we may personalize the Services experience by displaying your name (first name, and first initial of last name) and profile picture or avatar (which you can choose to not display and instead show your anonymous screen name and no image) on your public profile page, next to your posted reviews and comments, and on other areas of the site where your posted content is displayed. We might also display lists of content for you that similar users like. We may additionally use information from your social media profile or your social media activities on our Services to personalize content for you and offer features and opportunities tailored to your interests.
  • Aggregate Reporting: When you are connected via a Social Networking Service, we may use data from the Social Networking Service that you allow us to access to learn more about the demographic information of our users.

You may disconnect from a linked Social Networking Service at any time by visiting the "My Account" or "My Profile" section of the Site.

We will not share any information about you collected on the Services with a linked Social Networking Service without your approval. This means that we will not post anything to your Facebook wall, Google account, or Twitter feed unless you give us specific permission to do so, and we will not contact your friends or followers at any time. We do not store or utilize the names of your friends or followers even if they are passed to us by a social sign-on service in the initial registration process.

Social Networking Services provide varying levels of control over the extent to which content or information you submit to the Services is also made public and shared on linked Social Networking Services. When you use a Social Networking Service to log into the Services:

  • You share your information with it and its privacy policy applies to the Social Networking Service's collection, use, and disclosure of such information.
  • In addition, the Social Networking Service may be able to collect information about you, including your activity on the Services, and it may notify your connections on the Social Networking Service about your use of the Services.
  • Such services may also employ unique identifiers which allow your activity to be monitored across multiple websites for purposes of delivering targeted advertising to you.

Please note that the privacy policies and terms of use of linked Social Networking Services are different from our own and we encourage you to read them. We also encourage you to familiarize yourself with the privacy controls and account settings on linked Social Networking Services for information on how to customize your privacy settings with respect to content or information submitted to the Services.

Authorized Third Parties: Personal Information may be disclosed to authorized third parties, such as District and School Administrators, who may use and generate aggregated deidentified reports of user activity—such as individual information, transcript, training activity, badges, and leaderboard progress--only in their specified District or School for their own educational purposes. Please see your School or District’s policy for more information.

Law Enforcement; Emergencies; Compliance. Notwithstanding any other provision of this Policy to the contrary, we reserve the right to use your Personal Information, and to disclose it to others, as we believe to be necessary or appropriate: (a) under a requirement of applicable law, (b) to comply with legal process, (c) to respond to governmental requests, (d) to enforce our Terms of Service, (e) to protect our operations, (f) for assistance in fraud detection and prevention; (g) to protect the rights, privacy, safety or property of Common Sense Media, you or others, (h) to permit us to pursue available remedies or limit the damages that we may sustain, and (i) in connection with a disposition of all or a substantial portion of our business, assets or stock, such as the sale of the Site or Services, a merger, consolidation, reorganization, joint venture, assignment, or bankruptcy or similar proceedings.

IV. Collection and Use of Information by CSOD/Cornerstone

To create a better user professional development experience, we use a third party service called CSOD to provide our training materials in an easy to use online portal. CSOD collects all of the information collected by the Services.

CSOD may use Personal Information to generate aggregated statistics regarding user behavior as a measure of interest in, and use of, the Services, and it may disclose such aggregated, non-personally identifiable data, such as overall patterns or demographic reports that do not describe or identify any individual user, to third parties. Information relating to aggregated statistics will be collected through the use of third-party cookies and other third-party tracking devices. CSOD is otherwise restricted from using Personal Information for purposes other than providing services for us.

For more information about Cornerstone OnDemand’s collection practices, please log into the Services, and visit its policy here: https://commonsense.csod.com/phnx/driver.aspx?routename=Home/Privacy. Cornerstone OnDemand’s Terms of Service is available here: https://commonsense-pilot.csod.com/phnx/driver.aspx?routename=Home/Terms....

V. CHILDREN'S PRIVACY

Our Services are not intended for, marketed to, or knowingly made available to students or individuals younger than the age of 18, and individuals younger than the age of 18 should not submit Personal Information to the Services.

VI. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

Links. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third party, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply our endorsement of the linked site or service. In addition, we are not responsible for the information collection, use, disclosure or security policies and practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer.

Security. We seek to use reasonable administrative, organizational, technical, and physical measures to help protect the Personal Information you provide to us. When users enter any information on the Services, CSOD encrypts the transmission of that information using secure socket layer technology (SSL), and ensure passwords and data are stored securely using encryption.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, you should immediately notify us in accordance with the section below entitled "Contacting Us." Please note that if you notify us by physical mail, this will delay the time it takes for us to respond to the problem.

Changes to the Privacy Policy. We reserve the right to change this Policy, and any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Services following such changes constitutes your acceptance of the revised Policy then in effect. If we make material changes to this Policy, we will take reasonable steps to alert users of the Services that the Policy has been updated.

VII. CONTACTING US

If you have any questions about this Policy, or the Services, please contact us at [email protected]. Or write to us at:

Privacy Department
Common Sense Media
650 Townsend Street, Ste. 435
San Francisco, CA 94103

Appendix

Cornerstone Client Portal Privacy Policy

Last updated: August 10, 2017

Our Privacy Policy is designed to assist you in understanding how we collect and use personally identifiable information ("Personal Information") that you provide to us and to assist you in making informed decisions when using our website and services (collectively, "Cornerstone" or "Website").

Cornerstone OnDemand Inc. complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Cornerstone OnDemand Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit: www.privacyshield.gov.

By visiting or using any part of this Website, you agree to the terms of this Privacy Policy as they may be amended from time to time. As we update and expand our Website, this Privacy Policy may change, so please check this web page for updates to our Privacy Policy. Further, this Privacy Policy is incorporated into, and is a part of, this Website"s Terms of Use agreement, which also governs your use of this Website.

Collection of Information

When you visit our Website, we may collect information regarding your visit from your computer. Such information helps us to determine information about how you found our Website, the date you visited our Website and search engines that may have led you to our Website. We collect this information to continually improve and enhance the functionality of Cornerstone.

Generally, you may provide us with two types of information (User-Provided Information and Website Usage Information), both of which are discussed in greater detail below.

Personal Information you choose to provide

In order to make your visits to our Website as enjoyable as possible, we may ask you for Personal Information. Personal Information includes, for example, your name and e-mail address, both of which you may be asked to provide when registering with Cornerstone. A description of some of the ways that you may provide Personal Information to us, as well as further details on how we may use such Personal Information, is given below.

1. Contact us/feedback

If you email us through a "Contact us" link on our Website, we may ask you for information such as your name and e-mail address so we can respond to your questions and comments. If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages, your e-mail address and our response to you. In certain cases, and with your permission, we may post content from your e-mails to us on the Website.

2. Questionnaires and surveys

We may occasionally ask viewers of our Website to complete online surveys and opinion polls about their activities, attitudes and interests. These surveys help us serve you better and improve the usefulness of Cornerstone. In requesting your participation in these surveys, we may ask you to provide your name and e-mail address to us.

3. Bulletin Boards

Our Website may offer its users the opportunity to use bulletin board blogs and chat rooms, and engage in discussions with other users. If you choose to use these features, you should be aware that any Personal Information you submit through these features can be read, collected or used by other viewers of these forums and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums.

Website usage information

1. Cookies

When visiting Cornerstone, we may use "cookies" on or in connection with our Website to maintain information about you. A cookie is a very small text document, which often includes an anonymous unique identifier and additional information necessary to support the sites intended functionality. Cornerstone employs the use of "session" cookies. A session cookie is temporary and disappears after you close your browser.

When you visit our Website it will then send a session cookie to your browser if your browser"s preferences allow it, but (to protect your privacy) your browser only permits our Website to access the cookies it has already sent to you and not the cookies sent to you by other websites. Except as otherwise set forth herein, all of our cookies are necessary for the provision of our services. We do not employ any third-party advertising cookies on our site. Some of the cookies we use and their functionality are included in the table below:

Analytics Cookies

Name Purpose Description
c-c-n Session Provides our 24x7 global performance monitoring system with regional statistics to ensure our pages load quickly and consistently. Contains the name of the portal logged into and the numeric system identifier of the logged in user. Does not contain any Personal Information.
_utma Persistent Used to distinguish users and sessions. The cookie is created when the JavaScript library executes and no existing _utma cookies exist. The cookie is updated every time data is sent to Google Analytics.
_utmb Persistent Used to determine new sessions/visits. The cookie is created when the JavaScript library executes and no existing _utmb cookies exist. The cookie is updated every time data is sent to Google Analytics.
_utmt Persistent Used to throttle request rate.
_utmz Persistent Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the JavaScript library executes and is updated every time data is sent to Google Analytics.
_ga Persistent Used to distinguish users.

Functional Cookies

Name Purpose Description
_accss Session This cookie is used for automated course launch functionality in the Curriculum Player. The cookie keeps track of the Curriculum ID if launched in the Curriculum Player and the next Learning Object to be launched. Contains Curriculum and Learning Object GUIDs. Does not contain any Personal Information.
anon_users_cart_cookie Session This cookie is used to temporarily hold items placed in the shopping cart by an anonymous user. The items are transferred to the user's shopping cart once they log in with their individual account. Selected items would be lost without this cookie. Contains Learning Object GUID. Does not contain any Personal Information.
ASP.NET_SessionId Session This is a default cookie that is required for ASP based pages to load. Without this cookie, our website will not function. Contains the unique session identifier. Does not contain any Personal Information.
c-n-s Session This cookie is required to support content file encryption and Java applets when client launches http content. Contains the name of the portal logged into.
c-s Session This cookie is required to support content file encryption and Java applets. Contains the name of the portal logged into. Not httpOnly as it is used for Flash requests.
CYBERU Session This cookie is used to support session timeout due to inactivity. Contains the unique session key and the URL.
CYBERU_lastculture Session This cookie is used to ensure our login and maintenance pages load in the local language of origin. Contains the Region (e.g., U.S.) of the incoming machine.
CyberUErrorMessage Session Carries over error message from the originating page to the actual page that displays the error. Contains error message GUID. Does not contain any Personal Information.
loginCyberU_
LogoutRedirectUrl
Persistent This cookie holds the redirect URL used after a user's session times out.
QS_COOKIE_ENC Session This cookie is required for query string encryption when the user is logged out of their session so that the user's ReturnUrl link can navigate back to the same page and be successfully decoded. Contains first eight characters of the session ID. Does not contain any Personal Information.
SessionGuid Session Contains a unique session identifier. Protects against Session Fixation vulnerability. Does not contain any Personal Information.

Most web browsers can be adjusted to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Refusing a cookie may, in some cases, preclude you from using, or negatively impact, the display or function of, our Website or certain areas or features of our Website. There are many resources on the internet that can provide more information about how cookies work and how you can manage them. One very informative non-profit site is www.allaboutcookies.org.

2. Clear GIFs

When visiting Cornerstone, we may also use "Clear GIFs" (a.k.a. "web beacons" or "pixel tags") or similar technologies in our Website and/or in our communications with you. A Clear GIF is typically a one-pixel, transparent image located on a web page or in an e-mail or other type of message, which helps us to verify an individual"s viewing or receipt of a web page or message. Clear GIFs allow us to know whether you have viewed a web page prior to visiting our Website and may enable us to relate such information to other information, including your personal information. We use information provided from Clear GIFs to allow more accurate reporting, improve the effectiveness of our marketing and make Cornerstone better for our users.

3. IP address and Clickstream data

Our servers automatically collect data about your Internet Protocol Address when you visit us. When you request pages from our Website, our servers may log your IP address and sometimes your domain name. Our servers may also record the referring page that linked you to us (e.g. another website or a search engine); the pages you visit on this Website; the website you visit after this Website; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Website or a referral website; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our servers and to administer our Website. Such information may also be used to gather broad demographic information, such as country of origin and Internet service provider. Personal Information including IP addresses are not used to facilitate contact with users who have not provided their contact details to CSOD. Personal Information is not shared with any third party marketers.

Rights to opt in/opt out

You have the right to "opt in" and/or "opt out" of certain of our uses of your Personal Information. For example, you may have the opportunity to elect whether you would like to receive correspondence from us. You will have the opportunity to opt out of Cornerstone"s promotional e-mails by clicking the "opt out" or "unsubscribe" link in the e-mail you receive. You can also request this by sending an e-mail to [email protected], specifying whether: (i) you would like to opt out of receiving promotional correspondence from Cornerstone in general, or just via e-mail, postal mail and/or by phone, and/or whether (ii) you would only like to opt out of certain of Cornerstone"s e-newsletters or correspondence.

Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.

Use, Disclosure, and Sharing of Personal Information

1. Service providers

We may use third-party partners to help us operate and maintain our Website and deliver our products and services. We may also share your information with our service providers and other third parties ("Affiliated Parties") that provide products or services for or through this Website or for our business (such as website or database hosting companies, address list hosting companies, communications providers, e-mail service providers, analytics companies, distribution companies, fulfillment companies, credit card processing companies and other similar service providers that use such information on our behalf).

Third-party service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. Data can be processed in the United States, India or Israel depending upon contractual requirements and in accordance with legal jurisdictions for the region(s) to which Cornerstone is subject.

2. Aggregated statistics

We may disclose non-personally identifiable aggregated statistics regarding user behavior as a measure of interest in, and use of, our Website and e-mails to third parties in the form of aggregated data such as overall patterns or demographic reports that do not describe or identify any individual user. Information relating to aggregated statistics will be collected through the use of third-party cookies and other third-party tracking devices.

3. Legally compelled disclosures

We may disclose your Personal Information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to law applicable to us, our group or out partners, comply with a judicial or court order or comply with legal processes served on us or Affiliated Parties; (b) protect and defend our rights and property, the Website, the users of the Website and/or our Affiliated Parties; or (c) act under circumstances to protect the safety of users of our Website, ourselves, or third parties.

Consent to worldwide transfer and processing of Personal Information (applies unless otherwise agreed in writing between you or your organization and Cornerstone)

By providing Personal Information to us through this Website, you agree that it may be used by us and our Affiliated Parties for the purposes described herein and you further understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, which may have different privacy laws from your country of residence and which may afford varying levels of protection for your Personal Information. Regardless of the laws in place in these countries, we will treat the privacy of your information in accordance with this Privacy Policy. By providing your Personal Information to this Website, you consent to our transmission to and processing of your information in any jurisdiction in accordance with this Privacy Policy.

Your access and correction rights

You retain the right to submit and correct your Personal Information by contacting your organization.

Privacy Shield

Cornerstone OnDemand Inc. complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Cornerstone OnDemand Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit: www.privacyshield.gov.

In compliance with the Privacy Shield Principles, Cornerstone OnDemand Inc. commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union and in Switzerland with inquiries or complaints regarding our Private Shield policy should first contact their employer, as Cornerstone OnDemand Inc. data processing is on behalf of their clients. Cornerstone OnDemand Inc. can be contacted at:

Attn: Cornerstone Privacy Address: 1601 Cloverfield Blvd., Suite 600 South, Santa Monica, California 90404, USA E-mail: [email protected]

Cornerstone OnDemand Inc. has further committed to cooperate with EU data protection authorities (DPAs) and with the Swiss Federal Data Protection and Information Commissioner with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs or the Swiss Federal Data Protection and Information Commissioner for more information or to file a complaint. The services of EU DPAs and the Swiss Federal Data Protection and Information Commissioner are provided at no cost to you.

Cornerstone OnDemand Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

It is also possible, under certain conditions, to invoke binding arbitration. Please visit the Privacy Shield website for additional information.

In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Cornerstone OnDemand Inc. shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

Third-party websites

When you are on this Website you may have the opportunity to visit or link to other websites, including other websites operated by us or by unaffiliated third parties. These websites may collect Personal Information about you, and because this Privacy Policy does not address the information practices of those other websites, you should review the privacy policies of such other websites to see how they treat your Personal Information.

Privacy of minors

This Website is not directed at children under the age of thirteen. We do not knowingly collect Personal Information from children under the age of thirteen on our Website. If we become aware that we have inadvertently received Personal Information from a visitor under the age of thirteen on our Website, we will delete the information from our records.

Security

We use commercially reasonable and industry-standard physical, managerial and technical safeguards to preserve the integrity and security of your Personal Information. We also use Secure Sockets Layer (SSL) encryption when transmitting sensitive information. Whilst we endeavor to protect the security and integrity of sensitive Personal Information provided to this Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you contact us by e-mail or a "contact us" or similar feature on the Website, you should be aware that your transmission might not be secure. An unaffiliated third party could view information you send by these methods in transit. We accept no liability for disclosure of your information due to errors or unauthorized acts by third parties during or after transmission.

In the unlikely event we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we shall endeavor to do so as promptly as possible under the circumstances, and (insofar as we have your e-mail address) we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you would prefer us to use another method to notify you in this situation, please e-mail us at [email protected] with the alternative and/or additional contact information you would like us to use.

Updates to our privacy statement

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our online information practices. We will post a prominent notice on this Website to notify you of any significant changes to our Privacy Statement and indicate at the top of the statement when it was most recently updated.

Conditions of use

If you choose to visit csod.com, your visit and any dispute over privacy are subject to this Privacy Policy and our Terms of Use Agreement (incorporated by reference herein, as amended from time to time), including limitations on damages, arbitration of disputes and application of the law of the State of California.

Language

The governing language of this Privacy Policy is English, which shall prevail over any other language used in any translated document.

Contact us

If you have any questions or comments about this Privacy Policy, or if you would like to review, delete or update information we have about you or your preferences, please contact us as follows:

Attn: Cornerstone Privacy Address: 1601 Cloverfield Blvd., Suite 600 South, Santa Monica, California 90404, USA

E-mail: [email protected]