Instructional Technologies, Inc. ("ITI," "we," "our," or "us"), respects your privacy and is committed to maintaining and using your information responsibly. Our clients entrust us with the personal information of their employees and their users. We take the obligation to protect that information very seriously. We recognize your need to properly protect and manage any personal information you share with us. We have established this Privacy Policy so that you can understand how we protect and maintain your personal information.

PLEASE READ this Privacy Policy before using our websites. By using our websites, you signify to us that you have read and understand the practices described in this Privacy Policy.

Our business model is different from that of companies that collect your personal information to monetize such data. We collect and use personal information to allow us to provide our services to our customers and their end-users. In other words, we are a service provider, and in most cases when we collect and process your personal information we do so at the direction and for the benefit of our customers. We do not and will not sell or rent your data to any third-parties.

This policy describes how we treat personal information we collect and receive during your use of our services, including how we use and share the personal information we collect and receive.

Personal information we collect or receive about you includes, but is not limited to, your name, address, email address, employer, and phone number. In general, you can visit ITI's website (instructiontech.net) without telling us who you are or revealing any personal information about yourself. This policy does not extend to third parties who may have their own privacy policies.

Information will be collected when you or your employer provide it to us, such as when you request a demo, sign up for email newsletters, request pricing, register for Pro-TREAD or Sentix access, enter your User ID and name through Pro-TREAD or Sentix, or through other communications with us.

Information you give us. For example, when you sign in to your user account we'll ask you for personal information. This is information which you provide to us which personally identifies you, such as your name, email address, phone number or billing information, or other data which can be reasonably linked to such information by us, including information we associate with your ITI account.

Information we generate from the use of our services. We collect information about the use of our courses and data related to their usage. The courses taken, the amount of time spent in the course, and bookmarking and completion information as users progress through the courses.

ITI handles personal information in accordance with applicable data privacy laws, and makes reasonable efforts, conformant with applicable industry standards, to protect any information collected from the Client and End-User.

Our websites collect statistics, such as Internet Protocol (IP) addresses, browser and operating system version, pages accessed, and the dates and times of access. This information is recorded in log files and via Google Analytics and HubSpot. This information is collected to help us better serve the needs and requirements of our clients and end-users.

ITI often requests personal information in order to provide service to end-users. This enables us to respond to user's questions efficiently. This information is usually limited to the email address, name, user ID, company name, and contact information.

If you received a mailing from us, (a) your email address is either listed with us as someone who has expressly shared this address for the purpose of receiving information in the future, or (b) you have registered or purchased or otherwise have an existing relationship with us. We respect your time and attention by controlling the frequency of our mailings.

Each email sent contains an easy, automated way for you to cease receiving email from us, or to change your expressed interests. If you wish to do this, simply follow the instructions at the end of any email.

ITI does not rent, sell, or share personal information about you with other people or nonaffiliated companies except to provide products or services you've requested, when we have your permission, or under the following circumstances:

As a service provider we provide information to your employer, including lesson information, at the direction and on behalf of your employer. Your employer is considered as a trusted recipient of personal information. ITI cannot guarantee the security of your personal information once it is delivered to your employer as it is the responsibility of your employer to maintain this security.

ITI may share your personal information as needed to satisfy any legal requirements or enforceable governmental requests; to investigate violations to our terms of use; detect and prevent fraud and security issues; and to protect the safety, health, and rights of ITI, its employees, its users, and the public, from harm.

ITI may share your personal information with a buyer or successor in interest if ITI is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings in which information of users is among the assets transferred. In this event, we will, if allowed, use reasonable efforts to notify you when your personal information is transferred to any third party under this paragraph by posting such notice on our websites or by contacting you via the personal information provided to us by you or your employer, if any. Any personal information you provide to a buyer or successor in interest after such transfer will likely be subject to a new privacy policy, which you should review.

If you are an end-user of our customer and we are providing our services to you on our customer's behalf, depending on applicable privacy laws we are considered either a 'service provider' or 'data processor.' In this case, your employer's privacy statement governs the use of personal information. Our Privacy Policy does not supersede the terms of any agreements between us and your employer (or any other customer or third-party), nor does it affect the terms of any agreement between you and your employer.

Cookies are small text files placed on your device to make sure our websites work efficiently and seamlessly and to perform certain functions. They are unique to your account or your browser. Our website sends information to your browser, which then creates this text file. Every time you go back to our site, your browser retrieves and sends this file to our server. Cookies cannot access, read, or modify any other data on your computer.

We use cookies and similar technologies on our sites, as almost all websites do. We also use cookies when you access our services and courses. Cookies allow us to store your preferences and settings, authenticate and log you in, provide you with a personalized experience, keep our site secure, and analyze how our site and services are performing.

The following provides information on the types of cookies we use for our sites and services:

Sign-in and authentication

These cookies help us authenticate you, keep you signed in, and personalize your experience. You'll see this when accessing your Sentix account.

Security

Security cookies support our security features and help us detect malicious activities.

Analytics

We use some third-party cookies such as Google Analytics to gather information about user activities and performance. This helps us analyze and improve the performance of our websites. It also lets us understand, improve, and research how our services are used and what type of devices are used to access them. The information we receive from these third-party providers is de-identified, meaning we cannot track it back to you.

When you access our websites, Google Analytics may automatically collect information from you through the use of Google's analytics IDs, and Google provides some of this information to us in aggregate and anonymized form. An analytics ID is a specific string of numbers and letters (often called a "character string") that is assigned to your computer or device but does not name you. The analytics ID allows Google to track usage data of a website or mobile app, such as date and time of visit, duration of visit, website traffic patterns, "clickstreams," other similar information about how visitors use a website, the type of web browser used, the operating system/platform a visitor uses, IP address, the websites that referred or linked a user to a website, and your CPU speed. Google Analytics provides information about the use of our websites to us in aggregate form (i.e., data about many users combined and not just about you). Some of this data might include the regional location or city of users, but again, this data will be in aggregate (and not individual) form. Google Analytics also provides data anonymization features which ITI enables for its use of Google Analytics across our websites. We might use information we receive from Google Analytics to learn how users are using our websites in general, and to improve our websites. We will not receive the analytics ID assigned to your computer or device that you use to access and use our websites.

Marketing and Advertising

We use cookies for re-marketing on Facebook, LinkedIn and Google. These cookies are used to advertise to you on those ad networks. Those cookies de-identify the data from us, and have large cohort requirements to further mask the identity of any single user. We also use cookies from Hubspot to collect information about how you interact with our website. We use these to provide a more personalized experience on the website. It only identifies you if you fill out a form on our website. These social media companies may recognize you and collect information about your visit to our websites, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of the social media companies. Please read their privacy statements and cookie policies to understand how they use your information.

We keep your personal information for as long as necessary to meet the relevant purposes for which we've collected it, including for the purpose of satisfying any legal, contractual, accounting, or reporting requirements. To determine the appropriate length of time for retaining your information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purpose for which we process your information and whether we can achieve those purposes through other means, along with the applicable legal requirements.

We use commercially reasonable security measures to reduce the risk of your personal information being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we use reasonable means to limit access to your personal information to those employees, agents, contractors and other third parties who have a legitimate need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Unfortunately, no data storage system, or system of transmitting data over the Internet or wireless network, can be guaranteed to be 100% secure, and no security system can prevent all security breaches. As a result, we do not and cannot guarantee the security of our servers or any personal information provided to us in connection with your use of our websites or when you interact with us.

California Civil Code Section 1798.83 permits California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for their direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. However, for the avoidance of doubt, and as indicated above, we do not disclose personal information to third parties for their direct marketing purposes.

ITI may update this Privacy Policy from time to time to account for changes in law, technology, or our operations. Any modifications to our Privacy Policy will be reflected first on this page and, where appropriate or otherwise required by law, we will notify you of any changes to this Privacy Policy via the contact information provided to us by you or your employer. You can determine if this Privacy Policy has been revised since last accessing our websites by referring to the last updated date at the bottom of this Privacy Policy. Please periodically review this Privacy Policy before using our websites, as your continued use of our websites indicates to us your acknowledgment and understanding of any changes. All personal information held by us will be governed by the most recent Privacy Policy posted across our websites. If we intend to use earlier-collected Personal Information in accordance with the terms of the revised Privacy Policy and doing so would result in a use for a different purpose than stated at the time of collection, where required by law we will notify you prior to such use.

If you have any questions or suggestions on our Privacy Policy, you can contact us. While we cannot guarantee privacy perfection, we will address any issue to the best of our abilities as soon as possible.