You should read this Policy before you submit any personal information to us. By using our Sites or registering your interest in us online, you consent to the collection and use of your personal information as outlined in this Policy. If you do not agree with the content of this Policy, you should refrain from using our Sites.
1. WHO WE ARE
CEB, which owns and operates the Sites, has its principal place of business at 1919 North Lynn Street, Arlington, Virginia 22209, United States. More information about CEB and its network of Programs can be found at www.cebglobal.com.
CEB’s SHL Talent Measurement Solutions subsidiary (“SHL”) is a leader in talent measurement solutions that drive better business results for clients through superior people intelligence and decisions. SHL maintains its own membership in the U.S.-E.U. and U.S.-Swiss Safe Harbor Programs. More information about SHL can be found at www.shl.com.
2. PERSONAL INFORMATION WE COLLECT
In General. We may collect and store any personal information you enter on our website or provide to us in some other manner. Personal information is data that identifies you, or that can be combined with other information to identify or contact you, and includes (but is not limited to) your name, business or personal email address, job title, organization, organization’s physical address, direct telephone number, photograph, and biographical details. You are not obligated to provide us with any personal information, although you may need to provide some information to register as a member, submit a question, or engage in other transactions on our Site. We strive to limit the type of personal information that we collect to information that helps us accomplish our goal of providing first-class services.
You may use the send-to-colleague functionality on some of our Sites to send your colleagues information from CEB or its subsidiaries. In order to fulfill this request, we will ask you for your and your colleagues' names and email addresses. We do not retain this data after the email is sent.
Restricted Areas. If you access the Restricted areas of any of our Sites, we may collect additional information relating to your participation in Programs run by CEB or its subsidiaries. We also may obtain information about your access to and use of research materials, decision-support tools, and other online and offline resources we offer.
My Workspace. The My Workspace feature of the CEB website allows Members to save content available on the CEB website to the Member’s workspace; create folders for different types of content; add labels, tags, and notes to folders and saved content; and share content and notes with, and receive content and notes from, other members. CEB may review information about your use of My Workspace, including the content you save, folders you create, any tags, labels, or notes you add to your saved content or folders you have created, and any content that you share, and use such information to recommend content, tools, or other CEB services we think may be of interest to you. Information about your use of My Workspace, including the content you have saved and any tags, labels, or notes you have added to content you have saved or folders you have created, will only be accessible to CEB and will not be visible to or otherwise shared with other CEB Members unless you choose to share it.
Information from other sources. We also may periodically obtain both personal and non-personal information about you from other sources. Examples of information we may receive include updated contact information and additional demographic information. Please note that CEB or its subsidiaries may have previously collected personal information relating to you at the time you or your organization enrolled in a Program run by CEB or any of its subsidiaries, as well as in the course of allocating and issuing to you a unique ID and password to access the restricted areas of our Sites.
Information collected automatically. When you visit our website, we automatically collect and analyze certain information about your computer. This information includes but may not be limited to the IP address used to connect your computer to the Internet, information about your browser type and language, the date and time you are accessing our site, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address.
- Cookies. When you visit our Sites, we may assign your computer one or more "cookies." A cookie is a small text file that contains information that can later be read by us to facilitate your access to our Sites and personalize your online experience. For example, whenever you sign into our Sites, we will record your user ID in a cookie file on your computer. If applicable, we may also record your password in this cookie file, if you checked the box entitled "Save this password for automatic sign-in." Also, through the use of a cookie, we may automatically collect information about your online activity on our Sites, such as the web pages you visit, the links you click, and the searches you conduct. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our Sites.
- Other Technologies. We may use standard Internet technology, such as Web beacons (also called clear GIFs or pixel tags), locally stored objects (often referred to as “flash cookies”) and other similar technologies, to deliver or communicate with cookies and track your use of our Sites and content presented via the Sites. We also may include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer and measure the overall effectiveness of our online content, advertising campaigns, and the products and services we offer through the Sites.
3. HOW WE USE THE INFORMATION WE COLLECT
In General. We use the information we collect about you for the following purposes:
- to respond to inquiries that you submit to us via the online "contact us" feature and determine which Programs and services will help you achieve your business goals;
- to send you information about our programs and services that you have requested from us;
- to administer your membership in any of our Programs and facilitate your access to and provide you with resources, decision-support tools, and other materials available to you;
- to attribute content that you make available through the Sites;
- to communicate with you about surveys, marketing, promotions, executive-oriented events, educational forums, and other exclusive opportunities offered by CEB and its subsidiaries, partners, and affiliates, including information about other Programs in which you may be interested;
- for the purposes for which you provided the information;
- to customize the advertising and content you see, including the display of targeted advertisements;
- to engage in research and analysis in order to maintain, protect and improve our Programs and services, as well as develop new services;
- to generate anonymous and/or aggregated reporting;
- to enforce the legal terms that govern your use of the Sites;
- to enhance the our network and our products and services; and
- to ensure the technical functioning of the Sites.
Member Profiles and Peer Networking. On some of our Member Sites, you may be able to create an online profile, which may include information about your job title, employer, and your experience in different areas. This profile enables other Members participating in the Member program to determine whether the Member’s background and expertise might make him or her a useful contact on a particular issue. You can choose how much, if any, of your profile information is displayed in member listings or when you post discussion messages in the Peer Networking/Discussion areas, and whether to make your information searchable by other Members in your particular Member program. When you create an online profile and choose to (i) display any of your profile information in the Member listings or when you post discussion messages; or (ii) make your profile information searchable by other Members; you acknowledge and agree that you are making that information about you available to other Members, who might use that information to contact you via messages sent through the Member Site to obtain the benefit of your expertise.
Discussion Forums. In the event that you post personal information in discussion forums or other areas of the our Sites allowing users to upload or post content, that information can be viewed by any user with access to those areas. We discourage users from posting personal information in this fashion.
Utilization information. We may share information with our organizational Members about how their own employees use the Sites and the resources available to them through the Sites (e.g., how Member employees used certain features of the Sites, utilization trends, which features were most popular with the Member’s employees.)
4. CHOICES ABOUT THE USE OF YOUR INFORMATION
We believe that it is important to give you the opportunity to choose how your personal information is collected and used. We will not use your personal information for any purposes other than those described in this Policy or any service-specific privacy notices without first obtaining your explicit consent to do so.
Marketing Communications: We hope you find value in the communications we provide, and we will respect your wishes not to receive marketing communications. Please note that we will continue to send you member services emails and other service-related communications regardless of any such request. These service-related communications are an integral part of the Programs to which you subscribe. We will not share your information and personal details with third parties for their own promotional or marketing purposes without giving you a choice about such sharing.
5. DISCLOSURES OF PERSONAL INFORMATION
We may share your personal information with other companies or individuals in the following instances:
- When we engage service providers and third-party agents to process personal information on our behalf. When we do so, we contractually require these service providers to implement adequate technological and organizational security and privacy measures before they can receive any personal information from us to ensure that your personal information will be appropriately protected and only used for the purposes of performing the services for us.
- For legitimate business purposes connected with the provision of goods, services, and benefits for customers of CEB or its subsidiaries. Where information is shared with a third party for a legitimate business purpose, we will seek reasonable assurances from that third party that the personal information will be processed for legitimate reasons and appropriately protected.
- In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
- When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of CEB or its subsidiaries, our customers, or others; and in connection with our Terms of Service and other agreements.
- In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
We also may share aggregate or anonymous information with third parties, including advertisers, investors, and partners. Aggregate or anonymous information does not contain any personal information, and its use and disclosure is not subject to the terms of this Policy.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We operate the Sites in the United States and, depending on your country of residence; the submission of personal information to our Sites may involve some transfer of personal information to the United States. In addition, we may transfer personal information to our subsidiaries or affiliated companies in India, the United Kingdom, Germany, Singapore, and/or Australia for certain processing operations. You should be aware that privacy laws in the United States, India, Singapore, Australia, Germany, and the United Kingdom may not provide protections equivalent to those of your country of residence. We have taken steps to ensure that appropriate levels of protection necessary to maintain the security and quality of your personal information are in place and that any transferred data is processed only in accordance with this Policy.
7. ACCESS AND CORRECTION OF PERSONAL INFORMATION
In some cases, Members can directly access their online profiles and other personal details, enabling them to amend, update or add information by themselves at any time by logging into the relevant Program webpage.
You can also request access to any personal information that we hold about you and ask us to correct any personal information which may be inaccurate, except where the law requires otherwise. To access, correct or raise inquiries concerning your personal information in our possession, please email us at email@example.com or contact:
Privacy & Data Protection Officer
1919 North Lynn Street
Arlington, Virginia 22209, USA
8. INFORMATION SECURITY
We have implemented reasonable technical and organizational security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information. Unfortunately, no data transmission over the Internet can be guaranteed to be entirely secure, and we assume no liability for any damage suffered by you caused by the interception, alteration, or misuse of information during transmission.
We make reasonable efforts to restrict access to personal information to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Programs and services. We subject our third-party agents to contractual controls to ensure that they apply suitable protections to any personal information they access or receive from us.
Please note that the effective security with respect to our Sites depends, in part, on you ensuring that any IDs and passwords that you have been issued by us are kept confidential and secure and that you adhere to the restrictions on password and ID-sharing set forth in our Terms of Service.
9. OTHER WEBSITES
To provide increased value to users of our Sites, we may provide links to other websites or resources that are not part of the network of Programs run by CEB or its subsidiaries. We do not exercise control over these websites or their privacy practices, and any information you provide to those sites is subject to the Privacy Policies of those sites, and not this Policy.
10. SAFE HARBOR
Our Sites contain business-related content and are specifically aimed at and designed for use by adults. We do not knowingly solicit or collect personal information from or about individuals under the age of 18 years.
12. CHANGES TO THIS POLICY
This Policy may change from time to time. If we make material changes to this Policy, we will post any Policy changes on this page. If we feel it appropriate, we will provide a more prominent notice (including, for certain services, email notification). Your continued use of our Sites following such posts or notices will signal your acceptance of such changes.
Last Updated: February 24, 2014