Our Commitment to Your Privacy

Ethisphere has created this privacy policy in order to demonstrate our firm commitment to protecting your privacy. This Privacy Policy explains and summarizes how we collect, use and protect your personal information as you interact with us online and through our customer and technical supports services, if any. If you are visiting from outside the United States, there may be special rules or limitations on your use of this Web site.

If you have questions or concerns regarding this statement, you should contact Ethisphere Customer Support at (800) 369-7583.

This Privacy Policy is effective upon acceptance for new users and is otherwise effective on June 6th, 2007.

Information Collection and Use

Ethisphere contracts with client organizations to provide corporate ethics and compliance eLearning courseware, risk assessment and other related services. Personally identifiable information provided to us by our client organizations or information you (unique user) provide to us or that we learn from your use of this Web site is treated as confidential information. We are not in the business of selling or sharing your personal information to third parties for direct marketing purposes and we do not share your personal identifiable information with third parties for unknown or unrelated uses. However, we may share your personal information where it is necessary for us to complete a transaction initiated or consented to, by you, to do something you have asked us to do, or to comply with applicable legal requirements.

Ethisphere collects and uses personal information from you in several ways:

Registration

Our Web site registration form(s) may require customers to give us specific contact information (such as name and e-mail address), unique company information (such as employee ID, department name, business unit, etc) and demographic information (such as gender, ethnicity, zip code, etc). The extent of information collected depends on unique contractual agreements with our client organizations. We use this information to register client organization employees for online courseware programs, enable users to participate in online risk assessment surveys and/or contact customers about the services offered by Ethisphere.

In terms of demographic/profile data that is collected at our site, we use this data to tailor the visitor’s experience at our site, showing them content that we think they might be interested in, and displaying the content according to their preferences.

Web Site Usage

Ethisphere, or Ethisphere authorized service providers, may observe your activities, preferences, and transactional data (such as your IP address and browser type) relating to your use of this Web site. While we may collect or log this information, we do not identify you or match this information with your other personal information except as set forth herein or with your prior consent. We may use this collected or logged information to diagnose Web site technical problems, or to facilitate your use of the site. Ethisphere, or one of our authorized service providers, or we may use this information to track aggregate traffic patterns throughout this Web site.

Log Files

Like many Web sites, we collect certain information automatically and store it in log files. This includes information such as internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system and date/time stamp.

We use this information to help diagnose problems with our server and to administer our Web site. Your IP address is also used to help identify you and your shopping cart.

Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Our site uses cookies to keep track of your shopping cart and to deliver content specific to your interests. This cookie also allows us to track online courseware progress, which means whether or not an employee has completed a unique online course. We track this information based on your email address which also serves as your username. As such, we tie this personally identifiable information to the cookie.

We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close you browser.
We set a persistent cookie to store your username, so you don’t have to enter it more than once. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.

If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as surveys, will be limited.

Online Transactions

Our Web site uses an order form for customers to purchase products and services (online training). We collect contact information (such as name and billing address), financial information (credit card numbers), and demographic information (zip code). Contact information from the order form is used to fulfill orders and/or send information about our company to our customers. If we have trouble processing an order, we will use this information to contact the user.

Marketing Surveys

From time-to-time we may provide you the opportunity to participate in marketing surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code).

We use this information to create broad demographic profiles as well as to contact you when the survey is complete. For example, we may send the survey participant an email with the results of the survey.

We use a third party service provider to conduct these surveys; that company is prohibited from using our users’ personally identifiable information for any other purpose.

Testimonials

We post customer testimonials on our web site which may contain personally identifiable information such as the customer’s name. We do obtain the customer’s consent prior to posting the testimonial to post their name along with their testimonial.

Use of Collected Information

Ethisphere Partners/Suppliers

Ethisphere may work with some authorized service providers to provide technical and customer support, shipping, credit card processing, product fulfillment or other services. Ethisphere’s policy is to require these service providers to safeguard any personal information you provide to us. To the extent it is necessary for these service providers to complete their contractual obligations to Ethisphere; these third parties may have access to or process your personal information. Except as otherwise authorized by you, Ethisphere limits its use of your personal information to the purpose for which it was shared.

Mergers, Acquisitions and Bankruptcy

If Ethisphere should ever file for bankruptcy or merge with another company, or if Ethisphere should decide to buy, sell or reorganize some part or all of its business, Ethisphere may be required to disclose your personal information to prospective or actual purchasers or receive personal information from sellers. It is Ethisphere’s practice to seek appropriate protection for information disclosed or received in these types of transactions.

As Required by Law and Other Extraordinary Disclosures

Ethisphere may be required to disclose your personal information if it: (i) believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority; (ii) would potentially mitigate our liability in an actual or potential lawsuit; (iii) is otherwise necessary to protect our rights or property; or (iv) is necessary protect the interest of other users of our Web site.

Communications from the Website

Newsletters

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe. Please see the CHOICE-OPT OUT section presented later in this policy.

Service-related Announcements

Ethisphere may send service-related announcements on rare occasions when it is necessary to do so. For instance, if Ethisphere’s service is temporarily suspended for maintenance, a user would receive an email message from us.

Customer Service

Based on the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance to your wishes.

International Visitors and Customers

Ethisphere Worldwide

Ethisphere operates globally and privacy laws differ across the globe. To help visitors from countries outside the United States understand our privacy practices we provide special information on our privacy policies that may be applicable to these visitors. This Web site is hosted in the United States and is intended for United States visitors. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data to the United States and by providing your personal data you consent to that transfer.

EU Safe Harbor Adherence

Ethisphere adheres to the Safe Harbor principles agreed to by the United States and EU relating to data protection. For more information about Safe Harbor, please visit the U.S. Department of Commerce Web site.

Security

Your information is stored on our servers located in the United States. The security of your personal information is important to us. This site has security measures in place to protect the loss, misuse and alteration of the information under our control. When you enter sensitive information (such as credit card information) on our registration or order forms, we encrypt that information using either secure socket layer (SSL) technology or PGP technology.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and when we receive it. 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.

If you have any questions about security on our Web site, you can send Customer Support an email at support@Ethisphere.org.

Links to Other Websites

This Web site contains links to other Web sites that are not owned or controlled by Ethisphere. Please be aware that we, Ethisphere, are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information.

This privacy policy applies only to information collected by this Web site.

Changing Your Privacy Preferences

By using our Web site, you consent to the collection and use of your personal information by Ethisphere. If, in the future, we change the Privacy Policy, we will post the updated policy on this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

We reserve the right to change this policy in the future. Your continued use of this Web site following a change in the privacy policy represents consent to the new policy. We encourage you to periodically review this Privacy Policy.

Accessing/Updating Your Personal Information

If your personally identifiable information changes, you may update or delete this information by emailing our Customer Support at support@Ethisphere.org, or by contacting us by telephone toll-free at (800) 369-7583 or if you are a user of our eLearning courseware, you may log into the application and change your profile information.

A user may request access to his/her personal identifiable information at any time. If a user contacts Ethisphere either by email or telephone, they can expect to receive a response to their request for access to their personal identifiable information within 5 business days.

Choice/Opt-Out

Our site provides users the opportunity to opt-out of receiving communications from us and our partners at the point where we request information about the visitor.

This site gives users the following options for removing their information from our database to not receive future communications or to no longer receive our service.

Send an e-mail to info@ethisphere.com or call our toll-free number: (800) 369-7583.

Contacting Ethisphere

If you have any questions or suggestions regarding our privacy policy, please contact us at:

Ethisphere
info@ethisphere.com
(800) 369-7583
1185 Avenue of the Americas, Suite 1750
New York, NY 10036