Last updated: August 23, 2024
Changes: These updates reflect adding the UK Extension to the EU-U.S. Data Policy Framework and updating the frameworks associated with the JAMS dispute resolution.
Previous Versions:
We recommend that you read this Privacy Policy in full to ensure you are fully informed. However, to make it easier for you to review those parts of this Privacy Policy which apply or are relevant to you at any given moment in time, we have divided up the document into the following sections:
Aperian Global, Inc. and its subsidiaries and affiliated companies (collectively “Aperian,” “our,” “we,” or “us”) are committed to protecting the privacy of individuals who interact with us, such as our website visitors, customers, business partners, leads and prospects, recipients of marketing communications, end users and event attendees (“you” and “your”).
Aperian is an international consultancy that provides leading diversity & inclusion, cultural competence, and global mobility solutions. Aperian is headquartered in the United States with offices throughout North America, Europe and Asia Pacific. Aperian Global, Inc. is a Massachusetts corporation with a principal place of business at 414 Fayetteville Street, 4th Floor, Raleigh, NC 27601, USA.
The Aperian online learning platform that promotes global collaboration and inclusion. Aperian provides an analytics-driven solution that helps bridge work-style, communication, and cultural differences. We guide teams towards inclusive organizational culture, productive global projects, and stronger client relationships.
Aperian mostly sells its products and services to corporations and business customers. However, we also sell some services to consumers directly through our Aperian learning platform.
If you reside or are located in the European Economic Area (“EEA”), the United Kingdom or Switzerland, Aperian is the data controller of your personal information described in this Policy.
This privacy policy (“Policy”) explains how we collect, use and share your personal information when you:
When we refer to any combination of the above, we use the term “Services”.
When you access or use our Services, you acknowledge that you have read this Policy and understand its contents. If you do not understand any aspects of our Privacy Policy, or if you have questions or complaints, please feel free to contact us at privacy@aperian.com. Your use of our Site is governed by this Policy and our Terms of Service (https://aperian.com/terms-of-service).
The personal information we collect depends on the context of your interactions with Aperian and the choices you make, the Services and features you use, your location, and applicable laws, which in the preceding 12 months included:
We collect personal information that you provide to us including when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates or online courses, participate in our public forums, send us email messages, in-person conference registration by mail-in form or by telephone, and/or participate in online courses or other services on our Sites. This may include the following personal information:
We may also record or monitor our telephone or other communications with you, to the extent permitted by applicable law.
Providing your personal information is optional, but it may be necessary for certain services, such as for registration, or to access content. In such cases, if you do not provide your personal information, we may not be able to provide you with your request.
You are responsible for ensuring the accuracy of the personal information you submit to Aperian. Inaccurate information may affect your ability to use the Sites and our Services. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
We automatically collect certain device and usage information when you use or interact with our Sites, emails we send you, or as a part of your use of and interaction with our Services.
The information we collect includes:
Aperian does not intentionally collect any special categories of data in connection with the Services.
We collect this information through our Sites, Services and through other technologies, such as cookies, web beacons, and tags. For more information, review our Cookie Policy (https://www.aperian.com/cookie-policy/)
We may receive information about you from other sources (including third parties from whom we have purchased personal information) and combine that information with the information we collect. For example, we collect personal information from joint marketing partners, channel partners, our affiliated companies, recruitment agencies, credit check agencies, lead generation providers, public databases, data providers, and social media platforms.
This information may include:
We use personal information about you for a variety of purposes and on the legal bases described in this Policy or disclosed to you in our Services, which in the preceding 12 months included:
In carrying out these purposes, we combine information we collect from different contexts or that we obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.
Whenever we share your personal information with a third party provider we ensure that this is done so in accordance with applicable laws. The types of entities to whom we disclose and have disclosed information within the last 12 months, include:
We may also share aggregated or deidentified usage data with third parties to help us perform analysis and make improvements. Additionally, we may share anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends in the use of our Services.
Any personal information or other information you choose to submit in communities, forums, or blogs on our websites may be read, collected, and used by others who visit these forums, depending on your account settings.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
For further information on the recipients of your personal information, please contact us (see the “How to contact us” section below).
For your convenience we may provide links to sites operated by organizations other than Aperian (“Third Party Sites”) that we believe may be of interest to you. The privacy practices of these websites and services will be governed by their own policies. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the corresponding site to understand how that Third Party Site collects and uses your personal information. Please contact those third parties directly if you have any questions or concerns about their privacy policies and practices.
For example, it is possible that your payment information (such as credit card or debit card information) may be collected and stored by third party payment vendors.
We keep your personal information for no longer than necessary for the purposes it was collected outlined in this Privacy Policy, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.
Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. We determine the appropriate retention period for personal information based on the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your personal information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of that data.
For further information on applicable data retention periods, please contact us (see “How to contact us” below).
We consider the confidentiality and security of your personal information to be of the utmost importance. We use industry standard physical, technical and organizational security measures to keep your personal information confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment we cannot guarantee the security of your personal information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information, limiting access to your devices, and signing out of websites after your sessions.
In addition, our Site https://www.aperian.com is ISO 27001 and 27701 certified. For more information, please visit the ISO Certification site here (https://aperian.zendesk.com/hc/en-us/articles/360033772374-ISO-27001-2013-and-Data-Security).
If you contact us by email, please note that email communications are typically not encrypted and should not be considered secure.
If you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately (see “How to contact us” below).
Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We maintain primary data centers within the United States. Accordingly, if you reside or are located outside of the United States, your personal information will be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information.
We are committed to protecting the privacy and confidentiality of personal information when it is transferred. We take appropriate steps designed to ensure that the personal information we collect under this Policy is processed as described in this Policy and according to applicable law wherever the personal information is located. In particular, we use a variety of legal mechanisms to ensure that the recipient of your personal information offers an adequate level of protection, including entering into the standard contractual clauses for the transfer of European data approved by the European Commission, or where required, we will ask you for your prior consent.
EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (for Aperian Global, Inc. only)
Aperian Global, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Aperian Global, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Aperian Global, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit www.dataprivacyframework.gov.
Aperian Global, Inc. is responsible for the processing of personal information it receives, under each Data Privacy Framework, and subsequently transfers to a third party acting as an agent on its behalf. Aperian Global, Inc. complies with the Data Privacy Principles for all onward transfers of personal information from the EEA, UK, and Switzerland, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to the Data Privacy Frameworks, Aperian Global, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Aperian Global, Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, more fully described on the Data Privacy Framework website (https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf), you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
This section provides additional details about the personal information we collect only about California consumers and the rights afforded to them under the California Consumer Privacy Act (“CCPA”). Aperian Global, Inc. acts as a service provider for most of the personal information it receives or processes through the provision of its services and follows the instructions of its customers that engage Aperian Global, Inc. with respect to how it processes your personal information. If you would like more information about how your personal information is processed by other companies, including our customers, please contact those companies directly.
Please, also note that this section does not apply to information that is outside of the scope of the CCPA, including, without limitation, information collected (i) about our employees, contractors, or job applicants; and (ii) from non-California residents. Further, the privacy rights described in this section do not apply to information that is collected from individuals acting as representatives of another business in connection with business communications or transactions with us (e.g., our customers’ or vendors’ employees).
In particular, the categories of personal information we collect and the sources from which we collect it are described in detail in the section entitled “personal information collected” above. The business and commercial purposes for which we collect this information are described in the section entitled “how we use your personal information”). The categories of third parties to whom we “disclose” this personal information for a business purpose are described in the section entitled “how we share your personal information”).
Aperian does not “sell” your personal information to another business or third party for monetary or other valuable consideration.
California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Under California’s “Shine the Light” law (California Civil Code Section § 1798.83), California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To obtain this information, please send an email message to privacy@aperian.com with “Request for California Privacy Information” on the subject line and in the body of your message (see “How to Contact Us” below).
You have certain rights in relation to your personal information, and these rights will vary depending on your location. For instance, if you have an account with us, you can access your personal information and confirm that it remains correct and up-to-date.
In addition, if you no longer wish to receive marketing-related emails from us, you may opt-out by following the instructions in those emails (e.g. by clicking “Unsubscribe” or “Update my Preferences” at the bottom of any marketing email you receive from us). If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or other transactional, non-marketing purposes.
You can also send requests about changes to your information or your contact preferences, including requests to opt-out of sharing your personal information with third parties, by emailing: privacy@aperian.com.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
If you are located in the EEA, United Kingdom or Switzerland, you also have the following rights regarding the personal information we control about you:
If you would like further information in relation to your rights or would like to exercise any of them, you may contact us via privacy@aperian.com (see “How to contact us” below). We will review and process your request in accordance with our obligations under applicable law.
This section may apply only to California consumers. The CCPA provides California residents with the additional rights listed below. To exercise these rights, please reach out to us at privacy@aperian.com (see “How to contact us” below) with your request.
If you are a California resident seeking to exercise your CCPA rights, or if you are an authorized agent wishing to exercise CCPA rights on behalf of someone else, please contact us via email at privacy@aperian.com with “CCPA” in the Subject Line. Please include your full name and email address along with why you are writing so that we can process your request in a timely manner.
Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent (as applicable) have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your personal information.
Aperian strongly believes in protecting the privacy of children. Our Services are not intended for users under the age of 16 and we do not knowingly collect or maintain personal information from children under 16 years of age. No part of our Sites or Services are directed to children under 16 years of age. If you are under 16 years of age, then please do not use or access this Site at any time or in any manner. If you believe that we may have collected personal information from a minor without the requisite consent, please contact us as described in this Privacy Policy and we will investigate and promptly address the issue. We will take appropriate steps to delete any personal information of children less than 16 years of age that has been collected on our Sites without verified parental consent upon learning of the existence of such personal information. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.
Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Policy by posting a notice on our Site’s homepage prior to the change becoming effective, for a reasonable period of time following such update, and by changing the effective date (located at the bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.
If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via privacy@aperian.com or at Aperian Global, Inc., Attention: Privacy Department, 414 Fayetteville Street, 4th Floor, Raleigh, NC 27601, USA.
If you reside or are located in the EEA, the United Kingdom or Switzerland, our Privacy Team may assist with all queries regarding our processing of personal information at privacy@aperian.com or by registered mail at Aperian Global ApS., Bredgade 33, 2tv 6000 Kolding Denmark.
We are committed to ensuring this Policy is accessible to individuals with disabilities. If you wish to access this Policy in an alternative format, please contact us as described above.