PRIVACY POLICY

Proctor Gallagher Institute, L.P. (the “Company”) is dedicated to protecting privacy while using the services of proctorgallagherinstitute.com (the “Website”).  This privacy policy statement explains information collection and use practices for the Website. By accessing the Website, you are agreeing with and consenting to the data collection and use practices described in this privacy policy. This privacy policy statement expressly incorporates and is subject to the Terms of Use (“TOU”) for the Website, which may be separately accessed via a hypertext link located on its homepage. The provisions, terms and conditions set forth in the TOU shall supersede, govern and control in the event of any actual or potential inconsistency or conflict with the contents of this privacy policy statement.

PERSONAL DATA COLLECTION

You may be asked to provide the Company with information that personally identifies you or allows us to contact you (“Personal Data”), if necessary, to carry out a transaction or other service that you have requested in connection with use of the Website. The Personal Data the Company gathers, stores and uses may include the following information:

  1. Information about your computer including your IP address, geographical location, browser type and version, and operating system;
  2. Information about your visits to and use of this website including the referral source, length of visit, page views, and Website navigation paths;
  3. Information, such as your email address, that you enter when you register with the Website;
  4. Information that you enter when you create a profile on the Website—for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, and employment details;
  5. Information, such as your name and email address, that you enter in order to set up subscriptions to our emails and/or newsletters;
  6. Information that you enter while using the services on the Website;
  7. Information that is generated while using the Website, including when, how often, and under what circumstances you use it;
  8. Information relating to anything you purchase, services you use, or transactions you make through the Website, which includes your name, address, telephone number, email address, and credit card details;
  9. Information that you post to the Website with the intention of publishing it on the internet, which includes your username, profile pictures, and the content of your posts;
  10. Information contained in any communications that you send to us by email or through the Website, including its communication content and metadata; and
  11. Any other personal information that you send to the Company.

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this privacy policy.

PERSONAL DATA USE

The Personal Data collected on the Website will be used to operate the Website and to provide service(s) and/or carry out the transaction(s) you have requested or authorized in connection with the Website. More specifically, the Company may use your personal information for the following purposes:

  1. Administering the Website and the Company’s business;
  2. Personalizing the Website for you;
  3. Enabling your use of the services available on the Website;
  4. Sending you goods purchased through the Website;
  5. Supplying services purchased through the Website;
  6. Sending statements, invoices, and payment reminders to you, and collecting payments from you;
  7. Sending you non-marketing commercial communications;
  8. Sending you email notifications that you have specifically requested;
  9. Sending you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
  10. Sending you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
  11. Providing third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
  12. Dealing with inquiries and complaints made by or about you relating to the Website;
  13. Keeping the Website secure and prevent fraud;
  14. Verifying compliance with the terms and conditions governing the use of the Website (including monitoring private messages sent through our website private messaging service); and
  15. Other uses.

If you submit personal information for publication on the Website, the Company will publish and otherwise use that information in accordance with the license you grant to it.

The Company will not, without your express consent, supply your Personal Data to any third party for their or any other third party’s direct marketing.

When you sign up for or agree to receive promotional e-mail or other offers made in connection with or via use of the Website, the Company may use customized links or similar technologies to track e-mail links that you click. The Company may associate that information with your personal information or Personal Data in order to provide you more focused e-mail communications, use of the Website or other services and information related to, offered on or available through the Website. The Company will provide means to unsubscribe to e-mail communications that allows you to stop delivery of that type of communication.

DISCLOSURE OF YOUR PERSONAL DATA

The Company may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this privacy policy.

The Company may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.

The Company may also disclose your Personal Data as follows:

  1. To the extent required to do so by law;
  2. In connection with any ongoing or prospective legal proceedings;
  3. In order to establish, exercise, or defend the Company’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  4. To the purchaser (or prospective purchaser) of any business or asset that the Company is (or are contemplating) selling; and
  5. To any person the Company reasonably believes may apply to a court or other competent authority for disclosure of that Personal Data where, in the Company’s reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Data.

Except as provided in this policy, we will not provide your Personal Data to third parties.

INTERNATIONAL DATA TRANSFERS

Information and Personal Data that is collected may be stored, processed in, and transferred between any of the countries in which the Company operates, or in which our providers operate, in order to enable us to use the information in accordance with this policy.

Information and Personal Data that is collected may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: (1) the United States of America; (2) Russia; (3) Japan; (4) China; and (5) India.

Personal Data and formation that you publish on the Website or submit for publication on the Website may be available, via the internet, around the world. The Company cannot prevent the use or misuse of such information by others.
You expressly agree to the transfers of Personal Data and information as described in this section.

RETENTION OF YOUR PERSONAL DATA

This Section sets out the Company’s data retention policies and procedures, which are designed to help ensure compliance with our legal obligations regarding the retention and deletion of Personal Data.

Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. The Company does not delete Personal Data on any particular dates or times.

The Company will retain documents (including electronic documents) containing Personal Data:

  1. To the extent required to do so by law;
  2. If the Company believes that the documents may be relevant to any ongoing or prospective legal proceedings; and
  3. In order to establish, exercise, or defend the Company’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Except as otherwise described in this statement, personal information and Personal Data provided to the Company with regard to use of the Website will not be shared outside of this Website and its controlled subsidiaries and affiliates without your permission.

The Company may send out periodic e-mails informing you of certain services or products offered by it, its subsidiaries and affiliates, concerning technical services or security issues related to a product or service you requested or otherwise related to your use of the Website, or confirming a requested product or service related to the Website. Contact with the customer is an intrinsic part of the product or service being offered. You will not be able to unsubscribe to these e-mails as they are considered an essential part of the product(s) or service(s) you have chosen.

PERSONAL DATA SECURITY

The Company is committed to protecting the security of your Personal Data. The Company, through its selected service providers, uses a variety of security technologies and procedures to help protect your personal information and Personal Data from unauthorized access, use or disclosure. In this regard, the Company will:

1. Take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your Personal Data;

2. Will store all the Personal Data you provide on secure (password- and firewall-protected) servers; and

3. Will protect all electronic financial transactions entered into through the Website with encryption technology.

You acknowledge that the transmission of information over the internet is inherently insecure. The Company cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing the Website confidential. The Company will not ask you for your password (except when you log in to our website).

AMENDMENTS

The Company may update this privacy policy from time to time by publishing a new version on the Website. You should check this page occasionally to ensure you understand any changes to this privacy policy. The Company may notify you of changes to this privacy policy by email or through the private messaging system on the Website.

YOUR RIGHTS

You may instruct the Company to provide you with any Personal Data it holds about you. In order to obtain such information, you must provide the Company with the following:

  1. Payment in the amount of $100.00; and
  2. Supply appropriate evidence of your identity. For this purpose, the Company will usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address.

We may withhold Personal Data that you request to the extent permitted by law.

You may instruct us at any time not to process your Personal Data for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your Personal Data for marketing purposes, or we will provide you with an opportunity to opt out of the use of your Personal Data for marketing purposes.

THIRD PARTY WEBSITES

The Website may include hyperlinks to, and details of, third party websites. The Company has no control over, and is not responsible for, the privacy policies and practices of third parties.

UPDATING PERSONAL DATA

Please let the Company know if the Personal Data that it holds about you needs to be corrected or updated.

COOKIES

The Website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but Personal Data stored about you may be linked to the information stored in and obtained from cookies. The Company uses both session and persistent cookies on the Website.

The following cookies are used on the Website: (1) Google Analytics; (2) Adwords; (3) Infusionsoft; (4) Optin Monster; and (4) Ninja Pop-Ups. These cookies are used for the following purposes on the Website: (1) visits to the Website; (2) tracking users as they navigate the Website; (3) enabling the use of a shopping cart; (4) improve the Website’s usability; (5) Website use analytics; (6) Website administration; (7) fraud prevention and security improvements; (8) user personalization; and (9) advertisement targeting.

Most browsers allow you to refuse to accept cookies—for example:

  1. In Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools,” “Internet Options,” “Privacy,” and then “Advanced”;
  2. In Firefox (version 24) you can block all cookies by clicking “Tools,” “Options,” “Privacy,” selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
  3. In Chrome (version 29), you can block all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Content settings,” and then selecting “Block sites from setting any data” under the “Cookies” heading.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on the Website.

You can delete cookies already stored on your computer—for example:

  1. In Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835 );
  2. In Firefox (version 24), you can delete cookies by clicking “Tools,” “Options,” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies,” and then clicking “Remove All Cookies”; and
  3. In Chrome (version 29), you can delete all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Clear browsing data,” and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data.”

Deleting cookies will have a negative impact on the usability of many websites.

CONTACT INFORMATION

We welcome your comments regarding this privacy policy statement.  You may contact us via e-mail at customerservice@proctorgallagher.com or by U.S. Mail at Proctor Gallagher Institute – Privacy Policy Comments, 5010 E Shea Blvd, Suite 255, Scottsdale, AZ 85254.