Last Updated: May 24, 2018


Grovo Learning, Inc. ("Grovo" or "we") provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of www.grovo.com (the “Website”) and our learning management platform and players used to view and interact with the courses (“Services”, and together with the Website, collectively, the "Site"). This Privacy Policy applies to visitors of our Website and individuals registering for our Services (“Users”), including Users who are provisioned an account by our clients (“Clients”) (collectively, “you” or “your”). Please read this Privacy Policy carefully to understand our practices.  By using the Site, you acknowledge that you have read and understood this Privacy Policy.


Information We Collect and Why

We collect and use the following information to provide, improve, promote, and protect the Site:

  • When you register with us through the Site to become a Grovo User, we will ask you for information that identifies you as an individual or relates to an identifiable person ("Personal Information"). We may request you to provide Personal Information such as your name, email address, job title, and other contact or employee information. We use your Personal Information to provide the Service and administer your inquiries.
  • We also collect Personal Information, particularly employee information, that: (a) that the Client has provided to the Services directly or (b) that the Client has provided to the Services indirectly through a third-party service. We may use this information to provide the Services to you or to provide the administrator (“Admin”) of our Client with this information.
  • When you view content and interact with our Site, we collect information about how you use the Site, including what courses you have viewed or completed.  We use this information to provide and improve the Site, and to protect the Site. We may also provide the Client’s Admin with this information.
  • If you have certain account access, you may create courses, including by uploading files, documents, photos, and other information.  We use this information to provide the Services to you and other Users of our Client’s account.
  • We may collect information from you in surveys that we may conduct in order to improve the Site.
  • When you use the Site, we may collect information about the devices you use to access the Site, including IP address, browser or device type, the website you visited before the Site, and identifiers of your devices.  We use this information to provide, improve, and protect the Site.
  • We may use information you submit to us on the Website, provide to us at a corporate event, or that we receive from a business partner to contact you with Grovo newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.
  • We may accept limited financial and billing information in order to process your payment for use of the Site.
  • We may aggregate or de-identify information collected by use of the Site so that the information does not identify you or Client.  This Privacy Policy does not restrict our use or disclosure of aggregated or de-identified information.


How We Use Information

We collect and use the Personal Information described above in order to provide, improve, promote, and protect the Site.  We also collect and use Personal Information for our legitimate business needs. To the extent we process your Personal Information for other purposes, we or our trusted third-party partners will ask for your consent.


Cookies

We use cookies, tracking pixels, and similar technologies by working with our partners, including Google Analytics, to provide, improve, protect, and promote our Site. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your username and password for future logins to the Site. Second, we utilize session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by visitors and Users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.  If you do not accept cookies, however, you may not be able to use all portions of the Site. A tracking pixel is a unique identifier embedded in a website, online advertisement, or email.  We use tracking pixels to understand how you interact with our websites and emails and helps us and our advertising service providers better promote our Site.  Our Site does not respond to Do Not Track signals.

To find out more about how Google uses information when you visit a website that uses Google Analytics, please visit: https://policies.google.com/technologies/partner-sites.  

For more information about cookies and how to disable them, please visit www.allaboutcookies.org.  You may also find more information about how to control cookies and opt out of receiving tailored advertising from the Network Advertising Initiative’s Consumer Opt-Out or the Digital Advertising Alliance’s Consumer Opt-Out.  You are responsible for choices you make regarding these mechanisms.


Information Sharing and Disclosure

We use your Personal Information as described below, but we don’t sell it to advertisers or other third parties.

  • If your User account was provisioned by a Client, your Admin may have access and control over the information associated with your account.  The Client may have its own policies governing access and use of information in your User account.
  • If you create course content with tools on the Site, we will share that content with other Users that are part of a Client account.
  • Grovo uses certain trusted third parties to help us provide, improve, protect, and promote our Site.  These third parties may have access to your information to perform services on our behalf and in compliance with this Privacy Policy.  We will be responsible for the third parties we use to perform services on our behalf.
  • You or your Admin may provide a third-party service with access to your information.  The use of such information by a third-party service will be governed by the third-party service’s privacy policy.
  • We may disclose your information to third parties if we determine such disclosure is reasonably necessary to: (a) comply with applicable law, regulation, legal process, or government request, (b) protect any person from death or serious bodily injury, (c) prevent fraud, abuse, or security issue of Grovo or other users, and (d) to protect Grovo’s or its licensors’ rights, property, safety, or interest.
  • We may also disclose or share your Personal Information with your consent.


Business Transfers

Grovo may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy.


Changing or Deleting Your Information

You may review, correct, amend, or delete the Personal Information provided to Grovo by contacting us or by accessing the "Settings" menu on the Site. If you would like us to delete your record in our system, please contact us at privacy@grovo.com with a request that we delete your Personal Information from our database. If your User account was provisioned by a Client, the Client is a “data controller” of your information, and if you seek to correct, amend, or delete data associated with your account, you should direct your requests to the Client. We may retain an archived copy of your records as required by law or for legitimate business purposes.


Security

Grovo is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.


International Transfer

Your Personal Information may be transferred to — and maintained on — computers located outside of your country.  Grovo may transfer your Personal Information to the U.S., to any Grovo affiliate worldwide, or to third-party subprocessors in any jurisdiction acting on our behalf for processing. Your acknowledgement of this Privacy Policy followed by your submission of such information represents your agreement to that transfer.  

Clients transferring Personal Information from the European Economic Area should contact Grovo at privacy@grovo.com for a copy of Grovo’s Data Processing Addendum.


Links to Other Websites

Our Site contains links to other third-party websites. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.


Our Policy Toward Children

This Site is not directed to individuals under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at privacy@grovo.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.


Changes

We may modify this Privacy Policy periodically.  The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised.  Any revisions will become effective when we post the revised Privacy Policy. If a revision meaningfully reduces your rights, we will notify you.  Your use of the Site following these revisions means that you consent to the revised Privacy Policy.


Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@grovo.com. 

Grovo Learning, Inc.

Attn: Legal Department

50 West 23rd Street

New York, NY 10010