Privacy Policy
Updated and effective: May 2, 2018
This Privacy Policy applies to ullearn.com, ondemand.puresafety.com and all other websites, applications, online services and other interactive features owned or operated by EduNeering Holdings, Inc. or UL Verification Services Inc. (collectively, “UL,” “we,” “us” or “our”) that posts a link to this Privacy Policy (collectively, the “Site”). This Privacy Policy describes our information and privacy practices with regard to the Site, such as the types of information we may gather from you and other visitors to the Site. Except where specifically stated otherwise, this Privacy Policy applies only to information collected on the Site and does not apply to information collected by UL offline or otherwise outside of the Site, unless specific reference is made to this Privacy Policy.
Please take a moment to review this Privacy Policy. Please note that certain features or services discussed in this Privacy Policy may not be offered on the Site at any particular time. By using the Site, you agree to this Privacy Policy.
TABLE OF CONTENTS
SUMMARY
THIS SUMMARY PROVIDES AN OVERVIEW OF SOME IMPORTANT INFORMATION REGARDING OUR USE AND SHARING OF INFORMATION AND THIRD PARTIES WHO MAY SERVE ADVERTISEMENTS AND WHO OTHERWISE MAY SET COOKIES OR SIMILAR TRACKING TECHNOLOGIES WHEN YOU INTERACT WITH THE SITE. PLEASE REVIEW OUR FULL PRIVACY POLICY BEFORE USING OUR SITE.
We may collect Personal Information from you, which we primarily use in connection with your relationship with UL, your use of the Site, and for sending you information from us or on behalf of certain third parties. Please review the INFORMATION WE MAY COLLECT ON THE SITE and HOW WE MAY USE THE INFORMATION COLLECTED sections of this Privacy Policy for a full description of the information we collect, including without limitation Personal Information, and how we use that information. Remember that if you participate in community forums and similar features on the Site, your information may be public. Note that we do not share your Personal Information with third parties for marketing purposes; however, we may share your Personal Information under certain limited circumstances. For more details, please review the section below titled HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES.
In addition, UL works with network advertisers, ad agencies, analytics providers and other vendors to provide us with information regarding traffic on the Site, including without limitation the pages viewed and the actions users take when visiting the Site; and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. These third parties may set and access their own tracking devices (including without limitation cookies and web beacons) and they may otherwise collect or have access to information about you and your visits to this or other websites or applications, and may use that information to serve you targeted ads on this and other websites and applications. Please review THIRD-PARTY ADVERTISING COMPANIES AND ANALYTICS SERVICES for additional information. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit www.networkadvertising.org/managing/opt_out.asp for the NAI and http://www.aboutads.info/choices/ for the DAA, which provide information regarding targeted advertising and offer an “opt out” for participating companies.
INFORMATION WE MAY COLLECT THROUGH THE SITE
Information You Provide to the Site
UL may ask you to provide “Personal Information” (which is information that identifies or can be used to identify you as a specific individual, such as your name or email address) and other information about you, such as demographic information (ZIP code, gender or age, for example) and information about your interests and preferences. If we combine this other information with Personal Information, then we will treat the combined information as Personal Information under this Privacy Policy. In addition, we may collect work-related information about you (such as your work email address, job title, industry, and employee identification number) which may include Personal Information. Some services on the Site allow you to pay online, and therefore require that you supply us with information associated with your credit card or other accepted form of payment; some of this information may be Personal Information.
The Site is directed to a general audience. We do not knowingly collect personal information from children younger than the age of thirteen (13), and we will delete any personal information later determined to be collected from a user younger than age thirteen (13).
Information We Collect Automatically As You Access and Use the Site
In addition to any Personal Information or other information you choose to submit to the Site, we, and our third-party service providers (including without limitation any third-party advertisers and content or analytics providers), may use a variety of technologies that automatically or passively collect certain website usage information whenever you visit or interact with the Site (“Site Usage Information”). This Site Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, the search terms you entered into a search engine that led you to our Site (if applicable), all of the areas within our Site that you visit and the time of day, among other information. We may use this Site Usage Information for a variety of purposes, including without limitation enhancing or otherwise improving the Site. Site Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for your computer, mobile phone, or other device (any, a “Device”) used to access the Site. We may be able to collect or infer your approximate location through information we collect, such as an IP address. A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our servers identify your Device by its Device Identifier.
We may directly collect specific location information from your Device if you have opted-in to such collection through one of our mobile applications. You may be able to turn off the collection of location information through your Device settings. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. In addition, some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the Site.
The methods used to collect Site Usage Information may include, without limitation, the following:
Cookies & Local Storage. A cookie is a data file placed on a Device when it is used to visit the Site or otherwise access our online content. Certain web browsers and certain browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Site may make use of this local storage. For example, a Flash cookie is a data file placed on a Device via the Adobe Flash plugin that may be built-in to or downloaded by you to your Device. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Cookies, Flash cookies, and other local storage devices may be used for a variety of purposes (e.g., to identify your Device when you revisit our Site, to recall your authentication information, to store information related to your navigation throughout our Site, or to enable certain features on our Site).
Some cookies are essential to the functioning of the Site, and, without them, some features and services you have requested cannot be provided. Other cookies help us to understand and improve how the Site works or allow us to personalize it for you. You may be able to refuse or remove some or all of these cookie and local storage technologies, such as through your browser settings. If you choose to do so, some features of the Site may not function properly.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
HOW WE MAY USE THE INFORMATION COLLECTED
UL may use information collected through the Site, including without limitation your Personal Information and Site Usage Information, in order to: (1) allow you to participate in the Site and features offered through the Site and to provide customer service, including without limitation to resolve any billing or payment processing inquiries; (2) tailor content, recommendations, and offers we display to you, both on the Site and elsewhere online; (3) process your registration with the Site, including without limitation verifying that your email address is active and valid; (4) provide you with services or information or fulfill transactions that you have requested or otherwise agreed to receive, including without limitation authorizing and processing your payments and orders, and to process information you provide via the Site; (5) send you special offers from us, our advertisers, or third-party business partners; (6) allow you to participate in the public areas and other features of the Site (including without limitation keeping track of how and which content you watch); (7) contact you with regard to your use of the Site or similar administrative communications, including, without limitation and in our discretion, changes to the Site's policies; (8) use for internal business purposes such as to improve the Site or our products and services and to comply with regulatory and legal obligations; or (9) use for purposes as disclosed at the time you provide your information or otherwise with your consent, and as further described in this Privacy Policy.
We may use information that does not identify you or relate to an identifiable individual for any purpose, except where we are required to do otherwise under applicable law. If we combine such information with Personal Information, then we will treat the combined information as Personal Information under this Privacy Policy.
HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
UL may share non-Personal Information, such as Site Usage Information, aggregated user statistics and de-identified information, with third parties in our discretion. We do not share your Personal Information with third parties for those third parties’ marketing purposes. In addition, UL may share the information we have collected about you, including without limitation Personal Information, as disclosed at the time you provide your information or otherwise with your consent, as described in this Privacy Policy and in the following circumstances:
Third Parties Providing Services on Our Behalf. We sometimes use other businesses to perform services for us, such as website hosting, conducting website usage analysis, sending email or other communications, fulfilling orders, providing marketing assistance and data analysis, processing payments (including without limitation clearing and processing credit card payments), or performing other services. We may provide access to your Personal Information to such service providers in order for them to complete a requested transaction or otherwise to perform these services.
When You Agree to Receive Information from Third Parties or Request That We Share Your Information. You may be presented with an opportunity to receive information or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an interactive feature or third-party application, that we share information about you with a third party, and we will typically do so under those circumstances.
Administrative and Legal Reasons. UL may transfer and disclose information, including without limitation your Personal Information, Site Usage Information and Device Identifier (e.g., IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Conditions of Use or other applicable Site policies; to respond to an emergency; or otherwise to protect our rights, property, safety, or security or that of other Site visitors or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion. Such disclosures may be carried out without notice to you.
Business Transfers. In the event that UL goes through a transition such as being sold, has all or a portion of its assets acquired or transferred, whether voluntary or involuntary (such as through bankruptcy), or merges or becomes affiliated with any other division, individual or entity (including, without limitation, during the course of any due diligence process), any customer information owned or under the control of UL (including without limitation your Personal Information) will likely be one of the transferred assets. We reserve the right, as part of this type of transaction, to assign or otherwise transfer your information (including without limitation Personal Information) and other information we have collected from users of the Site. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.
THIRD-PARTY ADVERTISING COMPANIES AND ANALYTICS SERVICES
UL may work with network advertisers, ad agencies, analytics service providers, and other vendors to serve third-party advertisements on the Site; to serve our advertisements elsewhere online; and to provide us with information regarding use of and traffic on the Site (including without limitation the pages viewed and the actions users take when visiting the Site) and the effectiveness of our advertisements. For example, if you click on an advertisement for the Site, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement; likewise, if you click on an advertisement you see on our Site, our service provider(s) may be able to tell which page you were visiting on our Site and pass that information to the advertiser. The advertisements you see may be served by one or more third parties, who may use information about your activities on the Site, and other websites and services you visit, across the various devices you use, to provide you targeted advertising based upon your interests. Our service providers may collect certain information about your visits to and activity on the Site and other websites and services and may use this information to target advertising to you.
These service providers may set and access their own tracking technologies on your Device (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as your Site Usage Information and Device Identifier). Some of these parties may collect Personal Information over time when you visit the Site or other online websites and services. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information such as Device Identifiers, Site Usage Information and de-identified information with third-party advertising companies, analytics providers and other vendors for advertising and analytics purposes.
We use a variety of service providers to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). You may wish to visit http://optout.networkadvertising.org/#/, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit http://optout.aboutads.info/#/, which provides information regarding targeted advertising and offers an opt-out for participating companies.
We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site 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.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive non-targeted ads while online or on your Device.
HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Site does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
CHANGING YOUR PREFERENCES AND ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION
The Site may contain web pages or features through which you can correct or update some of the Personal Information you have provided to us through registration through the Site. In addition, if you would like to review, correct, update, suppress, restrict or delete Personal Information that you have provided to us, you may contact us as set forth under “Contacting Us,” below. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. UL will make good faith efforts to respond to your request as soon as reasonably practicable, consistent with applicable law. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or within our other records. Also, please note that we may need to retain certain information for our administrative purposes. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information, either through any online account feature offered or by contacting us as set forth under “Contacting Us,” below.
The Site may contain web pages or features through which you may be able to unsubscribe or modify the email newsletters or similar communications we send to you. Also, users who receive a newsletter or other marketing emails from us and who wish to remove themselves from the mailing list (i.e., opt out) can do so by following the link provided in each such email received. However, please note that we reserve the right to send you certain communications relating to your use of our Site, service announcements, notices of changes to this Privacy Policy or our Conditions of Use or similar administrative or transactional messages, and these messages may be unaffected if you choose to opt-out from marketing communications. If you sign up to receive SMS or MMS messages that may be offered on the Site, you may unsubscribe from any text messages received by replying “STOP.”
If you have made any public postings on the Site, such as in Community Forums, these communications cannot generally be removed.
THIRD-PARTY CONTENT, LINKS TO OTHER SITES, AND UL CONTENT FOUND OUTSIDE OF THE SITE
Certain content on the Site may be hosted and served by third parties, and the Site may contain links to third-party websites that UL does not control. For example, our Site may provide links to third-party sites through which you can purchase merchandise, products or services or which link to a product or service offered by a third party. The Site may also contain certain third-party applications, such as email, web browser toolbars, wallpapers or other downloads or software applications. These links and applications may include, without limitation, those that use an UL logo as part of a co-branding agreement. In addition, UL widgets or other UL content may be included, among other places, on web pages and websites that are not associated with UL and over which we have no control. These third parties may collect Site Usage Information through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services. UL is not responsible for the privacy or other practices employed by any third party.
SECURITY
While UL takes commercially reasonable steps designed to secure your Personal Information with technical and organizational measures appropriate to the risk, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. UL cannot ensure or warrant the security of any information we collect. You use our Site and provide us information at your own risk.
JURISDICTION AND CROSS-BORDER TRANSFER
The Site is controlled and operated by UL from the United States and is not intended to subject UL consensually to the laws or jurisdiction of any state, country or territory other than that of the United States. Visitors who use the Site and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Site, you consent to the transfer of information to countries outside of your country of residence, including without limitation the United States, which may have data protection rules that are different from those of your country.
If you reside in Europe, please see the section below for additional information for European Residents.
RETENTION PERIOD
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless we are required to retain records for a longer period in connection with legal claims or regulatory proceedings. We retain your contact details, attempted and completed courses, and transaction records until you ask us to delete your account.
SENSITIVE INFORMATION
We ask that you not send us and not disclose any sensitive Personal Information (e.g., social security numbers and other official identifiers, information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life or sexual orientation, biometric identification or genetic data, criminal background, or trade union membership, children under 16) on or through the Site or otherwise to us.
REVISIONS TO THIS PRIVACY POLICY
UL reserves the right to make changes to this Privacy Policy and will notify you of material changes by posting the revised Privacy Policy on our Site. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified.
CONTACTING US
If you have any questions about this Privacy Policy, please contact our Data Privacy Director at GDPR@ul.com or contact us by mail at:
UL PureLearning
202 Carnegie Center, Suite 301
Princeton, NJ 08540
United States
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
CALIFORNIA RESIDENTS - YOUR CALIFORNIA PRIVACY RIGHTS
Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information relating to third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. Alternatively, the law provides that a company may comply, as UL does, by disclosing in its privacy policy that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties’ direct marketing purposes, and information on how to exercise that choice. As stated above in this Privacy Policy, UL does not share your personal information with third parties for their direct marketing purposes.
EUROPEAN RESIDENTS
For Site users who are residents of the United Kingdom, European Union, and other European Economic Area nations, please be advised that while there is some uncertainty as to the scope of the EU General Data Protection Regulation (GDPR) as applied to US-hosted Sites such as ours, our practices in handling personal information collected through the Sites relating to residents of your jurisdictions are designed to conform to the GDPR.
When you request information or training through the Sites, we will inform you what personal details are necessary to receive materials or training and if any such details are optional. You may withdraw consent for future processing or communications from us at any time, and you may lodge a complaint with the data protection supervisory authority in your country of residence if you believe that our processing has violated the law. Our Data Privacy Director may be contacted at GDPR@ul.com or 33 Westland Square, Pearse Street, Dublin 2, Ireland.