Privacy and Cookies Policy

Industry Training LLC (d/b/a Julius Education) respects your privacy and has adopted this Privacy and Cookies Policy (hereinafter “Privacy Policy”) described below. This Privacy Policy is global in nature and describes our data protection practices and the types of Personal Data (as defined below) that we may receive or collect from you or from authorized third parties on your behalf; information we may collect automatically in the operation of our websites, web pages, and emails that provide a link to this Privacy Policy (collectively, the “Site”); from users of our products and services; and from individuals purchasing any of our other products and services available on Julius Education’s Site.

In addition, this Privacy Policy describes your rights and responsibilities, our rights and responsibilities, how we use the information we collect or receive, with whom we share the information with, the measures we take to protect the security of Personal Data from loss, misuse and unauthorized access, the choices you can make about providing your Personal Data to us as it relates to our products and services, and how you can contact us. All references to ‘our’, ‘us’, or ‘we’ as used in this Privacy Policy and within the opt-in notice are deemed to refer to Industry Training LLC, and websites within the Industry Training LLC family of companies as appropriate.

The rights and responsibilities described in our Privacy Policy do not cover third party websites that may be linked to our Site(s) or referred to on this Site. These third party websites have their own privacy policies and we encourage you to read and review them.

For purposes of this Privacy Policy “Personal Data” means any information that can be used to identify you or that when added with other Personal Data can identify you and includes, but is not limited to: personal contact details (name, street address, email address, phone number, fax number, credit/debit card information, company and title). We may also collect or receive the following additional Personal Data at registration, as necessary or appropriate, including, but not limited to: date of birth, employment data, education data and; residence and country of citizenship. In some cases, we may also collect ‘special categories of Personal Data’ about you, which may be considered sensitive. This would be the case, for example, if you are requested to provide your racial or ethnic origin. Before we collect sensitive Personal Data we will mark the question(s) as ‘optional’ or request and require your consent. Such consent may be withdrawn at any time.

This Privacy Policy describes:

Your Rights & Responsibilities

You agree that by visiting and/or providing, transmitting, or having another party who you have authorized on your behalf to provide or transmit your Personal Data to us on any of our Sites, you are accepting the practices described in this Privacy Policy and any updates made to this Privacy Policy. It is your responsibility to read this Privacy Policy and check for updates on a regular basis. By continuing to use our Site, products or services after such updates have been made you are agreeing to be bound by any updates to this Privacy Policy.

You are never required to provide us with your Personal Data. If you do not agree to this Privacy Policy, please do not provide, transmit or allow anyone else to provide or transmit on your behalf your Personal Data to us; however, if you decide to not provide to us your Personal Data it may affect our ability to allow you to register for our products and services, or for us to provide to you any other products or services we offer.

You agree that we may collect or receive, use, process, disclose, transfer and retain your Personal Data as described herein. This Privacy Policy governs your use of any and all of our Site(s) and in purchasing our products and services in general. We will use your Personal Data only for the purposes set forth herein.

As the data subject of the Personal Data collected, you may have rights related to the Personal Data that we hold about you.

At any time you may have the right to:

  • Request access to the information we hold about you.
  • Ask us how to correct any inaccurate or incomplete information we have about you or request us to make the corrections.
  • Request us to delete your information from our records, subject to our approval.
  • Withdraw consents you have given, where our collection and use is based upon your consent.
  • Ask us to send a copy of your Personal Data to a third party in a data portable format, subject to our approval.

You may make or submit a request listed above by contacting Industry Training LLC via email at [email protected] Upon receiving your request, we may need additional information from you to verify your identity and to better understand what it is you are requesting. In this case, we may ask you to provide additional information, including information you have previously disclosed to us. If you wish to designate an authorized agent under any applicable law, please contact us by any means described above and we will coordinate that designation. We will respond to requests within a reasonable amount of time in accordance with state and national laws and requirements. We recognize that you may have a right to not receive discriminatory treatment by exercising any of the rights listed above. We will not charge a fee to respond to a request, unless it is excessive, repetitive or unfounded.  If a fee will apply, we will advise the requester before completing the request, explain why a fee applies, and provide an estimate of the fee.

It is your responsibility to maintain the accuracy of your Personal Data at all times.

If you have concerns with these Rights and Responsibilities or our compliance with them, you may contact us at [email protected].

Our Rights & Responsibilities

We will provide you access to these Rights and Responsibilities and any subsequent updates.

We encourage you to periodically review this Privacy Policy to learn more about our information practices as they change over time. We reserve the right to update this Privacy Policy periodically, without notice. A change in the effective date will indicate that the Privacy Policy has been updated. Any updates to our Privacy Policy will become effective upon the posting of our revised Privacy Policy on our Site(s). Your use of our Site(s), and any of our products and services following such updates constitutes your acceptance of the revised Privacy Policy then in effect.

We rely on the following legal grounds to process your Personal Data:

  • Performance of a contract.We may need to collect and process your Personal Data as necessary to perform services subject to a contractual agreement with you. Examples of our legal grounds to process your Personal Data as being necessary for the performance of a contract include, but are not limited to: (i) when you make an online purchase for the purpose of allowing us to deliver the purchased product; and (ii) when you register to use our products or services.
  • Where we ask you for your consent, we will collect and use your Personal Data only to the extent you have consented.
  • Legitimate interests.We may use your Personal Data for our legitimate interests for the purposes of improving our products and services, the content of our Site(s), and improving our applications and systems.

Industry Training LLC and its authorized subcontractors will at all times protect your Personal Data with operational, administrative, technical, and physical security safeguards.

We do not disclose your Personal Data to third parties unless otherwise stated herein. We do not monetize Personal Data. We have not sold, within the last twelve (12) months, any Personal Data collected through this site, except to the extent that third party targeted advertising cookies are ultimately determined to involve a sale of personal information under California law. The following categories of personal information may have been collected and shared through such cookies and related technologies during the past 12 months within the digital advertising ecosystem:   Identifiers (limited to a numeric identifier, such as an IP address) Commercial Information, Internet or Similar Network Activity, Geolocation Data and Inferences draw from other Personal Information.

DESCRIPTION OF Industry Training LLC PRODUCTS and SERVICES

Industry Training LLC is the provider of assessments, learning, and analytics to individuals and organizations, including employers. These includes products and services that are proprietary to Industry Training LLC as well as ones that we license from third-parties.

Providing your Personal Data is voluntary, but may be necessary if you wish to receive our products and services. We will handle and treat all Personal Data collected and received by us in connection with you acquiring our products and services in the manner as described in this Privacy Policy.

We will retain your Personal Data for as long as needed to provide our services. To the extent that you request Industry Training LLC to delete your Personal Data, it may affect our ability to allow you to register for our products and services; or for us to provide to you any other products or services offered.

Data Categories

Depending on the Services requested, we may collect and/or disclose to third parties the following categories of data in order to manage day to day business needs including, but not limited to, providing you with our services, performing services on behalf of a business, payment processing and financial account management, business planning and forecasting, system improvements, security and fraud prevention, and compliance with legal and regulatory obligations:

(A) Identifiers such as a real name, address, unique personal identifiers, or email address

(B) Characteristics of protected classifications under California or federal law

(C) Commercial information, such as products or services purchased, obtained, or considered

(E) Internet or other electronic network activity information such as information regarding a consumer’s interaction with an Internet Web site, application, or advertisement

(D) Geolocation data

(E) Professional or employment-related information

(F) Education information

(G) Inferences about preferences, characteristics, preferences, predispositions, behavior, attitudes, abilities, and aptitudes

How We Use the Personal Data We Collect

We use Personal Data to (i) provide products, services and information; and (ii) for our legitimate purposes in operating our business. Examples of our use or disclosure of your Personal Data include, but is not limited to:

  • Providing assessment, learning, and analytics products and services
  • Our legitimate business purposes as needed to manage day to day business needs including, but not limited to, payment processing and financial account management, business planning and forecasting, security and fraud prevention, and compliance with legal and regulatory obligations.

Your Choices

Industry Training LLC endeavors to provide you with choices regarding our use of your Personal Data. For example, although we may occasionally use your Personal Data to contact you regarding products or services of Industry Training LLC that we think might interest you, you will be given instructions on how to opt out of receiving further communications of this nature by email. Should you elect to opt out of receiving further communications you will still receive program-related messages and similar transactional communications by email. In addition, as noted above, you will have the opportunity to choose not to receive marketing materials from our affiliates or third parties.

E-Commerce

Industry Training LLC’s E-commerce Sites provide you with the opportunity to purchase our products and/or services.

Personal Data Collected for E-commerce Services

We clearly identify what information must be provide by you in order for us to deliver the various products, services, and information that you may have requested. Depending on your choices, we will require different types of information for these various products, services, and information. You may also choose to provide additional or optional information to enhance the services we may provided to you. The Personal Data that we may collect includes:

  • Contact and shipping information, as well as purchase history, and payment information.
  • Information regarding your use of the Site (i.e., pages visited, files downloaded).

How we Use the Personal Data We Collect

We use the Personal Data you provide to Industry Training LLC to provide services and information you request, to process transactions, fulfill product delivery and for legitimate purposes in operating our business. Additionally, we use information collected about your use of our site for legitimate business interests to understand the habits of our Site users and to improve the products, services, and content we offer. In addition, you agree that Industry Training LLC, for its internal use only, may use your Personal Data for the purpose of further developing, upgrading, and improving our applications and systems.

Third Party Websites and Social Media

We may also collect information via third party websites such as Google, or via social media such as Twitter and Facebook. This information may include your name, address, username, email address, website visited, content posted, IP address, nationality, language, and other publicly available demographics. This information is used to improve the products and services that we offer, to identify and resolve customer service issues, and to provide the information and services you request.

Information Received from Internet Service Providers through this Website

This Site receives information that is automatically generated by a user’s Internet service provider (ISP), browser, or mobile device. This information may include the IP address (a number automatically assigned to a computer by the ISP), the associated URLs, domain types, the browser type used to access our Site, the country, state and telephone area code, the location of the ISP’s servers, the pages of our Site that the user views, any search terms entered on this Site, and the user’s website address and email address. This information may be collected for system administration purposes, to gather broad demographic information and to monitor the level of activity on the Site. We reserve the right to link this information to your Personal Data in order to protect the integrity of our system and for security purposes.

DISCLOSURE AND Transfer of Information

We will comply with the privacy and data collection laws of the jurisdiction of the individual from whom the information is being collected. Personal Data and information of test candidates located outside of the United States will be transferred to Industry Training LLC and our third party partners in the United States and elsewhere in the world only to facilitate the purpose for which it was collected. Our computer operations are currently based in the United States. By using this Site and sending information to us electronically, you consent to transborder and international transmission of any Personal Data that you may choose to provide to us to any country in the world, including countries without an adequate level of data protection. Information transmissions to this Site and emails sent to us may not be secure. Given the inherent operation and nature of the Internet, all Internet transmissions are done at the user’s own risk.

Disclosure and Transfer of Information to Jurisdictions
By registering for or purchasing our products and services, you give your consent for your Personal Data (with the exception of your debit/credit card information) to be transmitted by Industry Training LLC to the jurisdiction as necessary. For further information about how a specific jurisdiction may use your Personal Data we encourage you to contact the jurisdiction.

Other Disclosure and Transfer of Information

We may disclose Personal Data in the following situations: (a) in response to a subpoena, court order or legal process, to the extent permitted and required by law; (b) to protect your security, or the security of other persons, consistent with applicable law; (c) to address actual or suspected fraud or other illegal activities; (d) in connection with a sale, joint venture or other transfer of some or all of the assets of Industry Training LLC; and (e) to our contractors or agents who are committed or obliged to protect your privacy in a manner consistent with this Privacy Policy.

Industry Training LLC will have agreements in place with its relevant third party subcontractors and/or agents prior to the transfer of any Personal Data requiring that such subcontractors and/or agents (i) only use the Personal Data for purposes identified by Industry Training LLC; and (ii) protect the Personal Data in a manner that is consistent with this Privacy Policy.

In addition, your Personal Data and test scores may be provided to (a) parties approved by GED Testing Service LLC’s executive management to engage in research to inform and improve various educational practices. Such researchers must meet certain standards and are required to sign confidentiality agreements; and (b) parties providing support services to any of the organizations described in this Privacy Policy.

In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We do not provide your Personal Data to any third parties who at not connected with the services we provide or relate to such products or services unless you agree. Except as disclosed in this Privacy Policy, we will not provide your Personal Data to third parties.

Information from Children

We recognize the importance of protecting privacy where children are involved. We are committed to protecting children’s privacy and we comply fully with the Children’s Online Privacy Protection Act (COPPA) and similar laws and regulations. We do not knowingly collect Personal Data from children under the age of 13. If a child under the age of 16 has provided us with Personal Data, we ask that a parent or guardian contact us at [email protected]. If you are under 18, please be sure to read this Privacy Policy with your parent(s) or legal guardian(s), ask questions about things you do not understand, and consult with your jurisdiction regarding your eligibility to test.

Aggregation of Non-Person-Specific Data

We may statistically aggregate in non-person-specific form test responses and other information collected in the registration and delivery process of our products and services, and transfer this information to authorized third party vendors and to other authorized third parties such as the jurisdiction. Such aggregated non-person-specific information may be used for quality control, operations management, security and marketing purposes and to enhance, develop, or improve our products and services. By registering for our products and services, you give your consent to Industry Training LLC for this non-person-specific data aggregation and the use and transmission of this aggregated statistical data as outlined herein.

Email Newsletters

We may use your email address to send you email newsletters about Industry Training LLC and our products and services, and other related products and services. You may opt out of receiving the newsletter at any time by notifying us by email at [email protected] or following the opt-out instructions provided in the email newsletter.

PROTECTION OF CREDIT CARD INFORMATION

Individuals who make online purchases will be asked to provide credit/debit card information, which may include payment instrument number (e.g., credit card), name and billing address, the security code associated with the credit/debit card information, organizational tax ID, and other financial data (“Payment Data”). We use Payment Data to complete transactions, as well as to detect and prevent fraud. We will retain your Payment Data for as long as reasonably necessary to complete the transaction, to comply with our legal and reporting requirements, and to detect and prevent credit/debit card fraud. We provide a secured transmission method for the electronic transmission of credit/debit card information.

Marketing by Third Parties

Industry Training LLC honors your preferences with regard to sharing your Personal Data outside Industry Training LLC for marketing purposes. Prior to our sharing your Personal Data with our affiliates or other third parties for marketing purposes you will be given the opportunity to indicate whether you wish to not have your Personal Data shared with such parties.

Cookies and Web Beacons

We use browser cookies and similar technologies (collectively, “Cookies”) to collect and store certain information when you use, access, or interact with our Site(s). We may, for example, collect information about the type of device you use to access the Site(s), the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on the Site(s), the web pages you view immediately before and after you access the Sites(s), whether and how you interact with content available on the Site(s), and the search terms you enter on the Site(s). For information about how we use Cookies and the choices you may have, please see below.

By using our Site(s), you agree to our use of the cookies as described above and to our use of web beacons for the collection of information in order to provide the products or services you have requested and for improvements, as we deem appropriate for our legitimate purposes, related to our products and services.

Cookies. Cookies are small text files that a web server places on your computer or mobile device. Cookies contain information that can later be read by the web server that originally placed the cookie on your computer or mobile device.

Below is a list of the main types of cookies we use, and what we use them for.

  • Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
  • Performance Cookies: These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. Some of the performance cookies are analytics cookies, using third party web analytics software, which allow us to understand more about how our website is used. Performance cookies are not used to collect information that identifies a visitor. All information these performance cookies collect is aggregated and therefore anonymous. The aggregated data is only used by us to improve how our website works. We might also use performance cookies to highlight our products or services which we think will be of interest to you based on your use of our websites. By using this Site you agree we may place these types of cookies on your device.
  • Functionality Cookies: These cookies allow the website to remember choices you make (such as your user name, language or the region you are located in) and provide enhanced, more personal features. For instance, these cookies can be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect is not used to track your browsing activity on other websites. These cookies are known as “functionality cookies” and help to improve a user’s experience of a website by providing a more personalized service. By using this Site you agree we may place these types of cookies on your device.
  • Targeting or advertising cookies: These cookies are used to deliver advertising materials more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization. By using this Site you agree we may place these types of cookies on your device. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of targeted advertising by visiting common links, such as (note: these links and other links referred to herein may change):
  • 3rd Party Cookies and Social Networks. If you click on a hyperlink from this Site to any third party websites (for example, if you ‘share’ content from our Site with friends or colleagues through social networks, (such as Facebook or Twitter), or use third party services together with this Site, you may acquire cookies from these third party websites. Third party websites will have their own privacy and cookie policies which we do not and cannot control. Please check the third-party websites for more information about their cookies and how to manage them. You should always review these third party websites’ privacy policies.

How to Manage Cookies

If you block cookies or cookies are not enabled on your computer, it will mean that your browsing or shopping experience on our websites will be limited. Some active content, movies and online shopping baskets, for example, may not work correctly. To turn cookies on or off for all of our websites via your web browser, you can follow the instructions provided by the UK Information Commission Office at ico.org.uk/for-the-public/online/cookies.

Web Beacons. Web Beacons are small strings of code that provide a method for delivering a graphic image on a web page for the purpose of transferring data. For example, when you visit a page on this Site, the code for the page being visited may be transferred to us. The information transmitted to us is only used internally by us and is not shared with third parties, except as provided in this Privacy Policy. We use this information for the following purposes:

  • To allow us to better understand the traffic patterns within our websites and, subsequently, to adjust our content to better respond to our visitor’s interests; and
  • To use the information we obtain to suggest materials and resources that may be of interest to you based on your use of our Site.

Do Not Track Signals. This Site does not respond to web browser “do not track” signals or comparable signals or mechanisms.

By using www.juliusedu.com, unless otherwise specified by local law or regulation, you agree to the use of cookies and web beacons for the collections of information in order to provide to you the services you’ve requested and to improve our services.

Information Access and Corrections

To access and correct the Personal Data that we have collected under this Privacy Policy, please contact us or send us an email. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making alterations.

Resolution of Concerns

If you have questions or concerns about this Policy or how we handle Personal Data please contact us at www.juliusedu.com.

UPDATES to this Privacy Policy

We reserve the right to update the terms of this Privacy Policy from time to time. We encourage you to visit and review this Privacy Policy periodically to ensure you agree with  any changes or updates. We will post our revised Privacy Policy on our website and update the ‘Revision Date’ to reflect the date of the changes.

How to Contact Us

If you have any questions or concerns about this Privacy Policy or have a request regarding your rights as a data subject, please contact us at [email protected].

Effective Date of this Privacy Policy is December 1, 2020.

Copyright © 2020 Industry Training LLC. All Rights Reserved.