Effective Date: 3/5/2018
The CMMI Institute LLC
, located at 11 Stanwix St, Ste 1150, Pittsburgh, Pensylvania, 15222, USA, (“CMMI Institute”, “CMMI”, “we”, “our”, or “us”) operates the site and subsites located at www.cmmiinstitute.com
and its subdomains (collectively “Site”) and provides the content (including email and electronic communications) and services (collectively “Services”) offered on or through the Site. “Platform” means the “Site” and/ or “Service”.
This Privacy Notice explains how we collect, use, share, protect and process information about visitors or registered users on, from or through the Platform and the choices that visitors and registered users have about the collection and use of certain information about them.
This Privacy Notice applies solely to information that we collect from visitors and registered users through the Platform or through electronic communications that we receive at the address indicated in the section “Contact Us”.
A “visitor” is an individual who visits the Platform, without having registered. We do not know the identity of the individual. A “registered user” is an individual who has registered with the Platform, and whose identity can be determined directly or indirectly from the information provided. For the purpose of this Privacy Notice “you” means a visitor or a registered user; and a “visitor” includes a “registered user”.
This Privacy Notice does not apply to the websites of third parties to which the Platform may link. CMMI does not endorse, and is not responsible for the content of these websites, their policies or practices, or any product or service that they may offer. Any activity you perform on these third-party websites will be subject to the privacy policies and other terms and conditions of these third parties. We recommend that you review these third-party terms before providing any personal information to them.
By using the Platform, you signify your agreement to the terms of this Privacy Notice. Please ensure that you read this Privacy Notice carefully.
We may modify this Privacy Notice from time to time. We will notify you of material changes to this Privacy Notice by posting the amended terms in accordance with applicable laws. If you do not agree with the proposed changes, you should discontinue your use of the Platform before the new Privacy Notice takes effect. If you continue using our Platform after the new terms take effect, you will be bound by the modified Privacy Notice.
How We Collect Information
We (and our service providers) collect information in a variety of ways, such as through the methods identified below:
Information We Collect
- From the visitor’s browser, such as the screen resolution, operating system name and version, device manufacturer and model, language, or browser type and version.
- Through a visitor’s activities offline, for example when a visitor responds to a newsletter or interacts with us by telephone.
- Through the visitor’s activities online when using the Service – for example, taking a course filling out an online form or responding to quiz.
- Through a visitor’s social media account if it is connected to the visitor’s account on our Platform.
- Through cookies and other technologies that help analyze how our Platform is used, measure and track general visitor activities, and on third party websites and compile statistical reports.
We collect information from visitors when they interact with the Platform. This includes, for example, the following:
Information We Collect Automatically
When a visitor uses, or interacts with our Platform the visitor’s browser automatically provides, and we automatically collect and store, certain information about the visitor’s device (computer, tablet, smart phone,) and the visitor’s activities. This includes, for example:
Communications and Interaction
- Preferences and settings: time zone, language, and character size;
- Identifiers: IP address; mobile device advertising identifier, Media Access Control (MAC) address;
- Technical information: type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution;
- Connection: Internet service provider or mobile carrier’s name, connection speed and connection type;
- Information about use of the Platform: date stamp, URL of the last webpage visited before visiting our Platform, and URL of the first page visited after leaving our Platform, pages viewed, time spent on a page, click through, clickstream data, queries made, search results selected, comments made, search history, type of service requested, purchases made;
- Information collected through cookies, pixel tags, and other technologies; and
- General geographic location.
When a visitor registers to have access to the Platform (thereby becoming a “registered user”), when we send a communication to a visitor, or when the visitor accesses, responds to, or declines to open a communication from us, completes a form to communicate with us, or contacts us, we collect and store certain information about the visitor, the visitor’s device (computer, tablet, smart phone,) and the visitor’s activities, such as:
Conference Registrations, Certifications, Content Downloads and Training Courses
- The visitor’s name, login ID or pseudonym and contact information (if provided);
- If the visitor logs in using social media authentication, we will collect the information provided by the applicable social media services, for example, Facebook, Twitter or LinkedIn, as applicable.
- Information that the visitor provides or comments that the visitor makes;
- The nature of the communication;
- The purpose of the interaction, and the action we took in response to the visitor’s inquiry or request;
- Whether the visitor opened our communication or ignored it; Any action the visitor takes upon receipt of such communication.
When a visitor registers for a course, conference, or certification or download content, we collect information about the visitor through our sign-up form. When a visitor provides his/her information during a transaction, we keep track of that information, and may contact the visitor about next steps in the visitor‘s interaction with CMMI. In this case, we may collect: first and last name, title, street address, email address, telephone number, job title, Facebook ID, Twitter handle, LinkedIn ID, and company name, address, and phone number. In some cases, we may collect additional information, for example: password, security questions and answers, date of birth, birthplace, gender, residence status, college/higher education transcripts, passport or national id number.
Information We Obtain from Third Parties
We may obtain information from third parties, such as third parties with whom we do business, such as strategic business partners, service providers, public databases, or social media services to which CMMI Institute might be linked.
Use of Information
In addition to some of the specific uses of information that are described in this Privacy Notice, we may use the information that we have collected or received to:
Sharing of Information
- Send administrative information to the visitor;
- Remember the visitor’s preference, such as language, font size, when using our Platform;
- Remember the visitor’s interests;
- Administer our Platform, diagnose technical problems, and otherwise manage our business;
- Facilitate the visitor’s use of the Platform;
- Allow the visitor to navigate or browse through our Platform quickly and efficiently;
- Personalize the visitor’s experience by presenting content that is tailored to that specific visitor based on what we know about that visitor;
- Keep records of contact information and correspondence;
- Send marketing information;
- Communicate with the visitor about our activities;
- Send invitations to events that may be of interest to the visitor in accordance with the visitor’s preferences or apparent interests;
- Facilitate social sharing functionality, such as sharing content, through social media networks;
- Allow the visitor to share content with a friend through the Platform; by using this feature, you guarantee that you have the right to use and provide us the names and email addresses you submit.
- Improve, test, and monitor the effectiveness of the Platform;
- Develop features for the Platform that may be of interest to our visitors;
- Optimize our marketing efforts, for example by compiling statistics regarding the use of the Platform, identifying usage trends, or measuring the effectiveness of our promotional campaigns;
- Perform data analysis, audits, security and fraud monitoring and prevention;
- Enhance, improve, or modify our Platform; identify usage trends;
- Help diagnose server problems, and detect spam behavior, denial of service attacks or similar incidents.
Some of the technologies used on our Platform are managed by third parties. The practices of some of these third parties are subject to the third parties’ privacy policies over which we may have no control. We encourage visitors to read their privacy policies. Third parties who may have access to information may include:
We share information with our suppliers, subcontractors, and other third parties who provide services to us (collectively “service providers”) in connection with advertising, hosting, data analytics, information technology and infrastructure, email delivery, auditing, and other related activities. Our service providers are given only the information they need to perform their designated functions and are prohibited from using information provided by CMMI for their own purposes.
Affiliates, Partners and Sponsors
Some of our content is offered or promoted in conjunction with an affiliate, partner or sponsor. For this purpose, we may share visitor information with these parties. These affiliates, partners and sponsors will use the shared information in accordance with their own privacy policies.
The Platform may include links to third party websites and social media services where a visitor is able to post comments, reviews or other information. Please note that any information that is posted or disclosed through these social media services may be available to us, or to other visitors of that service or the public. We recommend caution when using these features.
Responding to legal requests and preventing harm
We may disclose information about a visitor in response to a facially valid request from a government agency or a private litigant in the form of a subpoena, court order or search warrant, or where we believe, in good faith, that it is necessary to do so for the purposes of a civil action, criminal investigation, and other legal matter.
Change of Control
We may disclose and provide information about our visitors to a third-party in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of any of our business, assets, or stock, including in connection with bankruptcy or similar proceedings.
Aggregated, Anonymized, or Statistical Information
We generate and use aggregated, anonymized, or statistical information about the use of our Platform. We may provide this information to third parties such as advisers or consultants for research, analytical or strategic purposes. This information is not intended to allow the identification of any specific visitor of our Platform.
Cookies and other Tracking Technologies
We may retain the services of third party service providers who may link personal information about a visitor - such name or email address - to other information they may have – for example, past purchases. This information may allow us to identify assumed interests or preferences of that visitor, so that we can provide a visitor with more useful and relevant ads.
We use these technologies to:
- Display information more effectively;
- Gather statistical information about the use of the Platform to understand how our Platform is used, and improve design and functionality;
- Store, on a visitor’s device, information about that visitor’s preferences and settings;
- Recognize a visitor when the visitor moves from page to page, or returns to use the Platform;
- Collect information such as browser type, time spent on the Platform, pages visited, and traffic data;
- Track responses to our marketing and advertising campaigns; and for security purposes.
We also use these technologies to understand the activities and interests of our visitors, including to:
How to block Cookies
- Measure traffic and usage of our Platform
- Monitor the effectiveness of our Platform
- Better understand the interests of visitors
- Recognize new or past visitors to our Sites
- Present more personalized content and advertisements
- Optimize a visitor’s shopping experience
- Identify visitors across devices, and third party websites.
- Identify improvements or enhancements to our Platform that might be of interest to our visitors
for information on commonly used browsers.
To control flash cookies, you can visit: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Please note that blocking or disabling certain cookies may interfere with certain functionalities of some parts of our Platform. Choices you make about cookies are also browser and device specific. Further, while disabling a cookie may prevent the collection of information in the future, it does not prevent the use of information collected before the cookie was disabled. If you block or delete cookies, not all of the tracking described in this notice will stop.
Information collected by Google Analytics is transmitted to, and stored by, Google in accordance with its privacy practices. To see an overview of privacy at Google and how this applies to Google Analytics, please click here: https://support.google.com/analytics/answer/6004245
To opt out of Google Analytics, please go to https://tools.google.com/dlpage/gaoptout
We may – or may have third parties, on our behalf - display to a visitor interest-based advertising and other custom content regarding our capabilities, products or services that may be of interest to visitors. This advertising may be served to a visitor on our Platform, or in our emails or on third-party sites or may be placed on other websites. It may be based on assumed interests attributed to a specific visitor, based on the use of our Platform by that visitor, or use information gathered about that visitor over time across multiple sites. They may be based on other interactions you have with us or our Platform. They may be based on other activities and behaviors that you demonstrate online.
The information collected about a user’s use of our Platform, or across the Internet, the products in which the user appears to be interested, etc., may be used to build an assumed profile of a particular person. To do so, our service provider may place or recognize a unique cookie on the user’s browser and use other techniques, such as pixel tags. If you are using one of our mobile applications, our ad network partners may use and store your mobile device ID or Advertising ID to show ads that they consider relevant to you.
How to Opt-out of Interest Based Advertising
You may opt-out of receiving interest based advertising as explained below. The opt-out may be provided through specific tracking opt-out cookies. Please note that if you get a new computer, install a new browser, or erase or alter your browser’s cookie file (including upgrading certain browsers), this may also clear any opt-out cookie.
Each visitor may opt out of receiving interest based advertising from advertising networks that may be delivered to them on other websites by visiting the following websites, please visit http://www.aboutads.info
Mobile device visitors may also download the AppChoices app at www.aboutads.info/appchoices
to opt out from interested based advertising served in mobile apps.
The features above will allow a visitor to opt out of many –but not all - of the interest-based advertising activities in which we or third parties engage.
Do Not Track
Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Consequently, due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law.
Links to Third-Party Sites or Applications
The Platform may allow you to directly access applications or services operated by third parties. These links are provided for your convenience only and should be used at your discretion. These links do not constitute sponsorship, endorsement, or approval of the content, policies or practices of such third-parties’ applications.
This Privacy Notice does not apply to information provided to or gathered by the third parties that operate them. We are not responsible for any information these third-parties’ services may obtain or how they may use it. You should review their privacy notices to understand how they may use your information.
Legal Basis For The Processing of Personal Information
If you are located in the European Economic Area (“EEA”), our processing of your personal information will be based on the following: To the extent that we obtain your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). If the processing of your personal information is necessary for the performance of a contract between you and us or for taking pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for us to comply with a legal obligation, we will process your personal information on basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).
Please note that where you have given your consent to the processing of your personal information you may withdraw your consent at any time which withdrawal will not affect the lawfulness of any processing previously made on basis of your consent.
We will retain your personal information for as long as it is necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
We take reasonable measures to protect any personal information we may hold in order to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction. In some areas of our Platforms, we may use Secure Socket Layer (“SSL”) or Transport Layer Security (“TLS”) encryption technology to enhance data privacy and help prevent loss, misuse, or alteration of the information under ISACA control.
We cannot guarantee, however, that all information will remain secure. The Internet by its nature is a public forum. We encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your login ID and password from third party access, and for selecting passwords that are secure.
Consent to Transfer of Personal Information
If you are located outside the United States, please be aware that information we collect about you will be transferred for processing to the United States or other countries or jurisdictions that may not have the same data protection laws as your jurisdiction. If you are located within the EEA, we will only transfer personal information that we collect about you to another country outside the EEA if appropriate safeguards are in place which ensure an adequate level of protection of your information, unless applicable laws or regulatory requirements allow us to transfer the information without such safeguards being in place. By registering for, and using the Platform, you consent to the transfer and storage of your personal information to the U.S. or to any other country in which we or our service providers maintain facilities.
We may use aggregated and non-identifying information to deliver tailored advertisements targeted to a specific audience. Based upon the aggregated information we have collected about visitors, we display the advertisement to the intended audience based on these general criteria. Some advertisement methodology may be directed to a specific individual, and may be based on the specific apparent interest of the visitor of a specific device.
If you receive commercial electronic communications from us, you can unsubscribe from the receipt of future commercial electronic communications from us by clicking on the “unsubscribe link” provided in such communications. Please also note that if you do opt out of receiving emails from us, we may still send you important administrative messages (such as updates about your account or service changes), and you cannot opt out from receiving these messages. Please note that even though you have opt-out of receiving marketing-related Communications from us, we may still send you important administrative messages.
We may need to retain certain information for record keeping purposes and/or to complete any transaction that you began before requesting a change or deletion. In addition, it is likely that residual information might remain within our databases, back-ups or other records and might not be removed.
Shine the Light
If you have an established relationship with us you may request from us a list of the categories of personal information we have disclosed to third parties for those third parties’ direct marketing purposes, and a list of all third parties to whom we have shared that information. We will include in that list the names and addresses of the third parties who received the information and used it (or who we believe may have used it) for their own marketing purposes.
To exercise your rights, you may make one request each year by emailing us as set forth in the “How to Contact Us” section below. Indicate in your letter that you are making a “Shine the Light” inquiry. Responses to requests that meet these requirements will be provided within the time frame required by law.
California Right of Erasure
If you are a California resident under the age of 18, and you are registered visitor of the Platforms, you may request that we remove content or information that you posted on the Platform or stored on our servers, by submitting a request in writing as indicated in the “How to Contact Us” section below, and clearly identifying the content or information that you wish to have removed, and providing sufficient information to allow us to locate the content or information to be removed.
Your Privacy Choices
Each visitor has the right to access, correct, or in the EU/EEA, delete personal information that we have collected from that visitor as well as to restrict or object, at any time, to the further processing of such information. For your protection, we may need to verify your identity before implementing your request. We will try to implement your request without undue delay. To submit a Data Subject Access Request click here
There are instances where applicable laws or regulatory requirements allow us to refuse to provide or delete some or all of the personal information that we maintain. In this case, we reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or to charge a fee that takes into account the administrative costs for providing the information or taking the action requested.
In your request, please make clear what information you would like to have access to or have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information.
The Service is a general audience service. Our content is neither directed towards minors nor children who are under the age of 13. We do not knowingly collect personal information from children under the age of 13. If we become aware that a minor or a child under the age of 13 has provided us with personal information without parental consent, that information will be deleted. Parents who have questions about personal information that may have been submitted by a child under the age of 13 should email us at the address provided in the “How to Contact Us” section.
By using the Platform, you represent that you are at least 13 years old.
How to Contact Us
If you have any questions about this Privacy Notice, please contact us by email at info@CMMIInstitute.com