ion Privacy Policy
Effective Date: July 28, 2021
In this Privacy Policy (“Policy”), we describe how ion Global, Inc. (“ion” or “Company”) collects, uses, and discloses information that we obtain about visitors to our website www.ionlearning.com (the “Website”) and the services available through our platform, such as the online ion learning platform (the “ion Platform”) in which registered users (“Participants”) access course catalogs (collectively, the “Services”). ion provides the ion Platform to corporate enterprises (“Clients”) to implement small group learning for their employees. ion utilizes an algorithm to place these individuals into groups to facilitate accountability, group learning, and building trust across the enterprise. ion offers courses covering topics on professional development in the workplace, which are designed to enable Participants to become better teammates in today’s workplace. ion provides platform access to Clients who want to implement their own courses for their employees.
This Policy is designed to help you understand how ion collects, uses, and shares your personal information. For information about how to contact us, please see the Contact Us section below. This Policy does not apply to any of the personal information that our enterprise customers (e.g. your employer) may process using ion’s Services. The privacy policy of our enterprise customers governs the collection and use of any enterprise data.
By visiting the Website, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Website or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Company Terms of Service are incorporated by reference into this Policy.
The Information We Collect About You
The personal information we collect depends on how you interact with us and our Services. We collect information that you provide to us, as well as automatically when you use our Website and Services. We may also collect information about you from our enterprise customer (e.g. your employer).
Information We Collect Directly From You. We may collect the following personal information:
Through the ion Platform and Services.
- When you create an account to access the ion Platform, you must provide us with your full name, email address, job title and phone number.
- When using the ion Platform, we may also collect additional information from you that you provide to us, including (i) your photo and current job title, as well as any information you provide or post on our Website, such as your goals, other employment information, and job preferences, and (ii) any information that you provide to us through the “Help” chat feature.
- As part of our Services, we may collect demographic and other information about you. For example, when you complete a group matching survey or questionnaire, you may provide us with information about your gender, race, age, sexual identity, ethnicity, socioeconomic status, family status and size, as well as personality characteristics. Answers to placement surveys are anonymized and not shared with employers; and we do not sell this information to any third parties.
- When using the ion Platform, we also collect information regarding your quiz and assessment scores, the time you spent in training, completion progress, and any other information related to your training performance. The ion Platform also enables you to take notes as part of the Services; these notes are only available to you and not viewable by any other Participants or by your employer.
Through the Website.
- When you subscribe to receive our newsletters or updates or book a demo to learn more about our Services, you will provide us with your name, company or employer name, and email address, and phone number.
- To contact us through our Website, we maintain a chat feature to which you may us with your full name and email address. Participants may contact us through the email address we provide as part of the Services.
Information We Collect From Other Entities. For Participants using the ion Platform, we may collect the following information about you from your employer: full name, email address, phone number, job title, and related employment and contact information.
Information We Collect Automatically. Our Website may use cookies, web beacons, and other technologies, which may be provided by third parties, to collect information about users from their browser or device, including, without limitation, your browser type, platform-dependent information, requested document, referrer URL, data and time of your visit, clickstream data (e.g. about the pages you view, links you click and date and time stamps for your activities on our Websites) and the IP address associated with your interactions in the system. To the extent permitted by applicable law, we may combine this information with other information we collect about you, including your personal information. For more information, please see the section “Cookies and Other Tracking Mechanisms” section below.
How We Use Your Information
We may use your information, including your personal information, for the following purposes:
- Providing the ion Platform, our Services, and related support: including to help fulfill your requests for products and services; to communicate with you about your use of the ion Platform and our Services; to respond to your inquiries; to administer surveys and questionnaires that place you in participation groups and identify certain course curriculum; to provide troubleshooting and other technical support; and for other customer service and support purposes.
- Protecting the integrity of the ion Platform and Services: including to verify your identity; to detect and prevent fraud and unauthorized activities; to facilitate software; to preserve the integrity of the Services and our systems, and prevent unauthorized access and activities; to enforce our applicable terms; and to protect the rights and safety of others.
- Analyzing and improving the ion Platform, the Services, and our business: including to better understand how users access and use the ion Platform and our Services; to evaluate and improve the Services and our business operations; to develop new features, offerings and services; to conduct surveys and other evaluations; and for other research and analytic purposes.
- Personalizing the ion Platform and Services: including to tailor content we send or display on our Websites and Services (e.g., for your geographic area); to offer personalized help and instructions; and to otherwise personalize your experiences with the Services.
- Advertising, marketing and promotional purposes: including to send or display targeted marketing; to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to contact you about our Services, as well as other information we think may interest you. Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes.
- Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.
- Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with Participants or third parties.
- Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; to maintain appropriate business records; to enforce company policies and procedures; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
- Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.
How We Share Your Information
We may share your information, including personal information, as follows:
- Your Employer. We may share information we collect about you, including information relating to your participation and progress in our Services, with your employer. This information includes information relating to whether you have completed assessments, information about your and/or your group’s progression through curriculum or lessons, your group number, module/session, last login date and date of completion, as well as who was teaching or facilitating each group session.
- Experts. We may share your information with experts that assist us in providing the Services to you. Experts are individuals that teach or introduce the courses and curriculum to you. We require all such experts to agree to keep your information confidential.
- Service Providers. We may disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries.
- Other Participants. Your progress through the Services will be available to other users, as well as information you provide about yourself to other participants (such as information about your job, your professional goals, and your motivation for participating in the Services).
We also disclose information in the following circumstances:
- Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
- In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We may share aggregate, anonymized, or de-identified information with third parties for marketing, advertising, research or similar purposes.
Our Use of Cookies and Other Tracking Mechanisms
We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Website or Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Website and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Website and Services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity. Persistent cookies help Website remember your information and settings when you visit in the future, such as remembering your login information.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website and Services who disable cookies will be able to browse certain areas of the Website, but some features may not function.
Flash Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Website preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website and Services to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website usage.
Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Website. We also may use other analytic means to evaluate our Website. We use these tools to help us improve our Website’s performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
User Generated Content
If you post content, such as your photo and phone number, on the ion Platform, this content will be available to your employer and your participation group (e.g. the other individuals in your group that also complete the courses or curriculum available through the ion Platform).
Third-Party Links
Our Website may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of My Personal Information
We have implemented precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access To My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Website for a period of time.
What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at privacy@ionlearning.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Website. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website.
