Introduction (effective June 18, 2020)
Our principle guidelines are simple. We will be clear about the data we collect and why. We do not and will not sell your data to third parties. The prime purpose of collecting your data is to assist you in using our video role play solution. Whether you are practicing a scenario, coaching or mentoring a student, or collaborating with your team, our aim is to make practice fun and as beneficial as possible.
We will update this Policy when necessary to reflect legal changes, customer feedback, and changes in our Services. When we post changes to this Policy, we will revise the “effective” date at the top of the Policy and may describe the changes in a change history. If there are material changes to the Policy or in how ELB will use your personal information, we may notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Policy to learn how ELB is protecting your information. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.
IMPORTANT INFORMATION (EU AND CALIFORNIA USERS)
Who We Are
For the purpose of the GDPR, and depending on the specific Personal Information of interest, the data controller of your specific Personal Information of interest is either the subscriber company of the Rehearsal instance in which your data is entered and stored, or Rehearsal, a division of eLearning Brothers. of 5475 Reno Corporate Dr #400, Reno, NV 89511. You may contact our data protection officer at email@example.com.
Sale of Personal Data
You may opt out of all sales of your Personal Information. We never exchange Personal Information for money or any other consideration (e.g., trade it for free services). However, the CCPA’s definition of “sale” is very broad, and may include situations where, for example, browsing data is sent to a third party. We, along with millions of other sites, use these services. We limit the information sent to what is needed to properly fulfill our contractual obligations. Do Not Sell My Info
The Types of Personal Information We Collect
Information you provide to us
We collect information from you directly that you voluntarily provide to us, such as your name and email address; for instance, when you want to update your profile or when you contact our Customer Care department for assistance.
Information we collect automatically
We automatically collect information about you, such as data about your use of Our services. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our websites, and whether and how you interact with content available on our websites.
Information obtained from other sources
We may receive information about you from other sources, including third parties, such as ELB partners and partners with whom we offer co-branded services or engage in joint marketing activities. We may also receive information about you from ELB partner websites, for instance, when you interact with us on those sites. We protect data obtained from third parties according to the practices described in this Policy and we also apply any additional restrictions imposed by the source of data.
Information of children
ELB does not target and is not intended to attract children under sixteen. Although visitors of all ages may navigate through our websites or use our app, we do not knowingly collect or request personal information from those under the age of sixteen without parental consent. If, following a notification by a parent or guardian or discovery by other means, a child under sixteen has improperly accessed or used our Services by using false information, we will delete the child’s personal information from our records.
Customer Interactions with ELB
To make the information in this Policy easy to understand, we have highlighted different occasions when ELB could potentially collect personal information from customers. The customer interactions with ELB are broken down into the following segments:
Learning about ELB
As you gather more information about ELB, you may virtually or physically visit or interact with a site that we own or operate. Examples include browsing our website, calling our in-house sales representatives, or attending ELB-sponsored events. To learn more about ELB Services, you may voluntarily provide personal information, such as your name and email address during these interactions. We may also collect information about you online when you visit our websites.
We collect: name, email address, phone number, company, and IP address.
Why: We use this information to share news about events, and Services offered by ELB. Additionally, the IP address helps us to understand geographic information about our websites’ visitors better so that we can improve our websites for everyone. It is our legitimate interest to process your personal data for these purposes.
Updating your profile
When you update your profile, we allow you to enter or modify certain information. You may voluntarily provide personal information such as your first name, last name, and email.
We collect: first name, last name, email address, sales territory, image, and preferred language.
Why: We use this information to notify you of activities and events within Our Services depending on your notification preferences, identify your associated assets, such as practice videos, identify you to other authorized collaborators in Our system, properly display content in Our Services, and authenticate access to content based on associated roles and privileges. Processing your personal data for these purposes is necessary for the performance of the agreement we have with you.
Submitting a video
The ELB Service is a video role-play solution, and the submission of videos by trainers, mentors, and students is the core function of the technology. We use the videos to facilitate training by example, by practice, by evaluation, and by screen capture.
We collect: Video data, audio data, screen-capture data.
Why: We use this information to to facilitate practice, training, and collaboration between coaches, mentors, and students. Processing your personal data for these purposes is necessary for the performance of the agreement we have with you.
Getting Help from ELB
From time to time, you may decide to contact our Customer Care department for assistance with the ELB Services, such as if you are having issues with the operation of your camera or your microphone. To be able to offer you the best service possible, we may collect certain data from you.
We collect: This may include contact information, such as your name, email address, phone number, and the content of your chats and other communications with ELB Customer Care.
Why: We collect this information to give you the best and most efficient customer support possible. For instance, for Customer inquiries and technical questions, we use contact information to respond to the Customer in their preferred channel (e.g., phone or email). Processing your personal data for this purpose is necessary for the performance of the agreement we have with you.
How We Use Personal Information
ELB uses the data we collect to provide you with the Services we offer, which includes using data to improve your experiences. We also use the data to communicate with you, for example, informing you about, new Services available, security, and other types of updates.
ELB uses the data for the following purposes:
Providing our Product Experience
We use data to provide, operate, support and improve the Services we offer to ensure our customers can practice, coach, and collaborate as efficiently as possible. This processing is necessary for the performance of our agreement we have with you.
We use data to respond to customer inquiries, diagnose problems using the Services, address technical issues, and provide other Customer Care and support services. This processing is necessary for the performance of our agreement we have with you, as well as to serve our legitimate interest.
We continually use data for research purposes and to develop and improve Our Services, including maintaining and improving the performance of Our Services, developing and adding new features or capabilities, such as using verification to improve security, and using usage data to determine what new features to prioritize. This processing is necessary to serve our legitimate interest.
Security, Safety and Dispute Resolution
We use data to protect the security and safety of Our Services and our customers, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.
We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.
Communication, Marketing, and Advertising
How We May Share Personal Information
ELB does not and will not sell personal information about our customers. We only disclose your data as described in this Policy. We may share information with the following types of third parties.
Entity or Company provisioning your account
All accounts in the ELB platform are provisioned by a ELB customer. ELB does not control the creation or deletion of these accounts, and the creators of these accounts may have access to some or all of your personal information based upon agreements you may have executed. Sharing information with our ELB customer companies for this purpose is necessary for the performance of our agreement we have with you and with the associated customer company.
When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, investigative organizations, our affiliates or in legal proceedings.
Sale or Merger
We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. We will also share information with that company, including at the negotiation stage.
The Legal Bases for Using Personal Information
There are different legal bases that we rely on to use your personal information, namely:
Performance of a contract
The use of your personal information may be necessary to perform the agreement you have with us. For example, to process your submission of a video response, to search for assignments, to post to the leaderboard, to help with technical issues, and to respond to your requests.
We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyze and improve ELB Services, to send you notifications about ELB Services, or to use your personal information for administrative, fraud detection or legal purposes.
Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you on our website, you may exercise your right to object by sending an email to firstname.lastname@example.org.
Security, Storage and Retention of Personal Information We Collect
ELB is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.
We use a variety of appropriate technical and organizational measures and industry standards to protect your personal information and help prevent information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. We ensure that our data center has adequate security measures. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transmission over the Internet. You can only access your information and our service through the use of an individual user login and password. To protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person. Please alert us immediately if you believe your password has been misused. Additionally, always log out and close your browser when you finish using the Services. Please note, we will never ask you to disclose your password.
If you have any questions about the security of your personal information, you can contact us at email@example.com.
Personal data collected by ELB may be stored and processed in your region, in the United States (for instance in our data centers), or in any other country where ELB is located or maintains facilities. ELB has put in place adequate mechanisms to protect personal information when it is transferred internationally, for example by using the Standard Contractual Clauses as approved by the European Commission.
ELB will retain your personal information for as long as we deem it necessary to enable you to use the website and ELB Services, to provide services to you, to comply with applicable laws (including those regarding document retention), and resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Policy and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to firstname.lastname@example.org.
Your Rights and Choices
We want you to be in control of how your personal information is used by us. Subject to local law, you can do this in the following ways:
- you can ask us for a copy of the personal information we hold about you;
- you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you;
- in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
- in certain situations, you can also ask us to send the personal information you have given us to a third party.
Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.
We rely on you to ensure that your personal information is complete, accurate and current. Please inform us promptly of any changes to, or inaccuracies of, your personal information by contacting email@example.com.
We will respond to your request as soon as possible but certainly within 30 days.
We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.
Rights for EU and California Users Only
The GDPR and CCPA grant EU and California residents certain rights regarding their Personal Information, including the right to access and modify Personal Information held by providers (like us), and to have providers “forget” Personal Information that is no longer relevant. You may always contact us for assistance in exercising these rights. Please include information about which rights you are seeking to exercise if you contact us. We may need to verify your identity before fulfilling your request. It should not need to be said, but we will never provide worse services to, or in any way punish anyone who chooses to exercise these rights.
You have the following rights with respect to your Personal Information that we process. Except where indicated, these rights apply equally to EU and California users:
- Withdraw Consent: You may withdraw your consent to our processing of your Personal Information, in whole or in part (i.e., for marketing purposes). Certain Services may be ineffective upon opt out.
- Access / Request Information: You may access the Personal Information we hold about you at any time by contacting us directly.
- Modification: You may modify the Personal Information we hold about you at any time via by contacting us directly.
- Erase and Forget. In certain situations, for example when the Personal Information we hold about you is no longer relevant or accurate, you can request that we erase your Personal Information. If you delete your account, all Personal Information will be erased within thirty days of the date of deletion.
- Portability: you may request a copy of your Personal Information and may always move it to other entities as you desire.
- No Sale of Personal Data (California Users only): Go to the Do Not Sell My Personal Information page to stop all “sale” of your Personal Data.
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have the right to request that ELB disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
DELETION REQUEST RIGHTS
You have the right to request that ELB delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us at:
ELB Training, LLC or firstname.lastname@example.org
5475 Reno Corporate Dr #400
Reno, NV 89511
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
If you wish to exercise any of these rights, please contact us at email@example.com, or write us at the address below. In your request, please make clear: (i) what Personal Information is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only fulfil requests with respect to the Personal Information associated with the email address you send your request from, and we will need to verify your identity before doing so (which is typically done by having you make the request from within the Services). We will comply with your request promptly, but in any event within thirty (30) days of your request (forty-five (45) days for requests under the CCPA). We may need to retain certain information for recordkeeping purposes or to complete transactions that you began prior to requesting such change or deletion.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write or email to us at:
ELB Training, LLC or firstname.lastname@example.org
5475 Reno Corporate Dr #400
Reno, NV 89511
Service data submissions
If you wish to access, edit or remove video or content, change your password, or request deletion of your personal data, you can do it by sending an email to email@example.com. We will respond to any request to access or delete your personal data as soon as possible but certainly within 30 days. Note that some data requests will require authorization from the customer company that provisioned your account, as it is typically the case they have an ownership interest in the data.
Your Communication, Marketing and Advertising Preferences
You can opt out of receiving direct marketing communications from ELB by following the instructions included in every email sent to you via the “Unsubscribe” link. We respect your choice, and we will stop sending you promotional emails once you unsubscribe.
Please note we will continue to communicate with you regarding changes to terms and conditions, policy updates, ELB Service updates, routine customer service messages such as information about service interruptions, data breaches, or other significant information about your use of the Services.
A ‘cookie’ is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. ELB uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted. We use the following types of cookies on our website.
- Strictly necessary cookies. These cookies are essential for you to browse our website and use its features. Without these cookies, services like shopping baskets cannot be provided.
- Performance cookies. These cookies collect information about how you use our websites. This data may be used to help optimize our website and make it easier for you to navigate.
- Functional cookies. These cookies allow our websites to remember choices you make and personalize your experience. We may store your geographic location in a cookie, for instance, to ensure that we show you the websites relevant to your area.
- Third Party cookies. Third-party cookies are those placed by websites and/or parties other than ELB. These cookies may be used on our websites to improve our products or services or to help us provide more relevant advertising. These cookies are subject to the respective privacy policies for these external services.
- Analytics cookies. We use analytics cookies, like those offered by Google Analytics, to help us understand things like how long a visitor stays on our websites, what pages they find most useful and how they arrived at rehearsal.com. To learn more about Google Analytics and your data, visit this Google webpage.
How to control cookie settings
Advertising and Modern Marketing Tools
To help more people achieve increased expertise on the ELB platform, we use several modern marketing tools in support of our advertising efforts.
If you have opted out of receiving communications from us, we will not use your email for interest-based advertising.
How to Contact Us
If you have any questions about the use of your personal information, please send an email to firstname.lastname@example.org.
In many cases, the ELB customer provisioning your account may be a data controller subjecting you to different privacy policies. You can contact the provisioning ELB customer or ELB directly for more information.
Our address is 5475 Reno Corporate Drive #400, Reno, Nevada 89511, USA.
The following are basic questions you may have about our Policy. We encourage you to read the detailed statement above for additional details.
What is the GDPR?
The GDPR is a regulation intended to strengthen and unify data protection for everyone within the European Union (EU). And because we believe that all our customers can benefit from its mandates, we’re implementing it globally. The GDPR requires greater openness and transparency from companies on how they collect, store and use personal data, while also imposing tighter limits on the use of personal data. You can learn more here.
What is the CCPA?
The CCPA was created to protect the privacy and data of consumers. The CCPA initiative states that the act is intended to “give Californians the ‘who, what, where, and when’ of how businesses handle consumers’ personal information.” The act requires businesses tell consumers what data its collecting and gives consumers the right to say no to the sale of their personal information.
We will update our Policy as necessary to ensure that our policies are in line with international regulations, our product and business practices.
What information does ELB collect about me?
ELB collects your first name, last name, street address, city, state, postal code, country, phone number, email address, territory, image, video content, audio content, and the content of your chats and other communications with ELB Customer Care.
Why does ELB need my information?
ELB uses the data we collect to provide you the best experience within the Services we offer, which includes using data to improve your experiences. We also use the data to communicate with you, for example, informing you about your assignments and assignment deadlines, new services available, security, and other types of updates.
How is my information used?
ELB uses the data we collect for the following purposes:
- Service Improvement
- Future Service Development
- Customer Support
- Security, Safety, and Dispute Resolution
- Business Operations
- Communications and Marketing
How does collecting my information help ELB improve its Services?
We use the information to make sure that we are efficiently and accurately capturing your video submissions, displaying submitted videos, and facilitating coaching and collaboration interactions. We also collect service error information, so we can make improvements to eliminate potential bugs and problems. And finally, understanding how and when our customers collectively use our service helps us design new ways to improve the video role play practice process.
Does ELB sell information to third parties?
No. We never have.
Can I opt out of sharing my information to ELB?
Yes, you can opt out of submitting certain types of personal information to ELB, but because ELB collects mostly data related to practice, coaching, and collaboration, the decision not to submit some information may impact ELB’s ability to provide efficient and effective services.
How do I delete my personal data from ELB and what are the consequences?
You can always send us an email to email@example.com or contact our Customer Care team and request that your data be deleted. Please note, however, that by deleting your personal data, submitted content may no longer be available, and we will be unable to provide further practice or historical training records.
How long does ELB keep my information?
ELB retains personal data for as long as necessary to provide the Services, and fulfill the transactions you have requested, 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.
How is information stored and secured on ELB’s servers?
ELB is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. Any data we transmit over the internet is protected using encryption.
Is ELB using cookies to gather information?
Does ELB use interest-based advertising?
Yes. We work with third-party advertisers that utilize cookies and similar technologies to provide more relevant advertising about ELB on our website and across the internet. To provide interest-based advertising, the advertisers combine non-personal data learned about your online activities over time to customize the advertising delivered to you. We do not share your personal information to do this.
What safeguards are in place for children who have access to ELB services?
ELB does not target and is not intended to attract children. ELB does not knowingly solicit personal information from children or send them requests for personal information. Although visitors of all ages may navigate through our website, we do not intentionally collect personal information from persons under the age of sixteen. If following a notification by a parent or guardian, or discovery by other means, that a child under sixteen has improperly accessed or used the site or Services, we will delete the child’s personal information from our records.
If you have any questions about the use of your personal information, please send us an email to firstname.lastname@example.org.