Privacy Statement

This Privacy Statement was updated on September 09, 2024.

 

About this policy

Protecting the individual’s privacy is crucial to the future of business. We have created this Privacy Statement to demonstrate our firm commitment to the individual’s right to data protection and privacy. This Privacy Statement outlines how we handle information that can be used to directly or indirectly identify an individual.

This is the Privacy Policy (“Policy”) for the websites operated by or on behalf of Litmos (“we” or “us”) and hosted at pages on the following domain: www.litmos.com (“Site”).

This Policy describes our general privacy policy and practices in relation to Litmos’s Site (navigating the Site, white paper downloads, event registrations, webinars, demo requests, pricing requests, or providing your personal information to us at our corporate events), including how we process personal information provided to us when you use our website, request our products or services, or otherwise contact us, such as via phone, email, mail, or chat. This policy does not cover information we process as a processor (e.g. personal information of employees of our customers).

This Policy describes how we collect information about you, what we do with that information, and also what controls you have over that information in relation to your use of our Site

A. General Information

Who is the Controller?

The controller for the Site is Litmos US, L.P., 548 Market St, Unit # 34398, San Francisco, CA 94104-5401 (“Litmos”), and its data protection officer can be reached at privacy@litmos.com.

What “Personal Data” does Litmos collect?

When using the Site, we may collect and process the following information about you:

Information provided directly by you

• Direct Identifiers and Contact Information (such as your name, company name, email address, postal address, state/province, country, and telephone number) that you provide by completing forms on the Site or social media channels we operate, including information about you if you register as a user of the Site, such as profile photographs, images or video content, information about you that you upload or submit to the Site, or information you provide to us when requesting information or material from us;
• Information and other details of any transactions made by you through the Site including financial and billing information, account numbers, billing name and address, birth year, credit card number (“Billing Information”) provided by you when making transactions through the Site;
• Internet Activity Information: We may collect your IP address, browser information, device information, your location, and which pages you visit on our website. When you visit our website, we automatically collect this information through “cookies” or related technologies like pixels. Information contained in communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site (or its content) or the services;
• Other additional information that you provide to us when attending our corporate events.

 

Information about you collected from third parties

We may process your personal information that we have obtained from third parties.

Why does Litmos need your Personal Data?

We will collect and use your information as described in this Policy and as permitted by applicable laws, including in circumstances where it is necessary: (i) to provide or fulfill services requested or consented to; (ii) for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract; (iii) for compliance with a legal obligation to which we are a subject; or (iv) to pursue our legitimate interests.

For example, we may collect and use your information for the following purposes:

• To perform the services you requested or consented to. For example, if you fill out a “Contact Me” web form, we will use the information provided to contact you about your interest in the services. This data processing is necessary to provide or fulfil a service requested by or for you.
• We also utilize social media to present ourselves on social media and to stay in contact and interact with you. In addition, we analyse how our company page is used on social media so that we can design and optimize it in line with requirements based on the insights gained.
• To plan and host events. For example, corporate events, host online forums and social networks in which event attendees may participate, and populate online profiles in relation to the services. This data processing is necessary to provide or fulfil a service requested by or for you.
• For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding Litmos and our group companies and our partners such as information about promotions, events, products, or services. We will only send you marketing communications and updates about our products, services, and events with your consent, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. As further described below, you can withdraw your consent at any time.
• In order to keep you up-to-date/request feedback. Within an existing business relationship between you and us, we may inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from us. Furthermore, where you have attended a webinar, seminar or event of Litmos or purchased products or services from us, we may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product, or service. You can object to further marketing at any time by checking and updating your contact details within your account, or/and selecting the “unsubscribe” link located on the bottom of Litmos’s marketing emails. Additionally, you may send a request to privacy@litmos.com.
  As described further below, you have the right to contact us at any time to object to the further processing of your information for the purposes of direct marketing to you, including any profiling related to such marketing.
• For operating and improving Litmos’s Site and your customer experience. For example, with your consent we may collect and analyze data on your use of our website and process it for the purpose of improving our online customer experience. Data collected could include data about your device, such as unique device identifiers, information about your mobile phone or other mobile device(s), browser types, browser language, operating system, and the state or country from which you accessed the Site. Data collected could also include information related to the ways in which you interact with the Site, such as referring and exit pages and URLs, platform type, the number of clicks and domain names. This data allows us to understand our customers, their interaction with our website and improve our website to better serve our customers. We may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information. Please see our Cookie Statement for more details. Data processing for analytical, operational improvement, and/or customer benchmarking purposes is a legitimate business interest.
• For customizing the Site with location-based information, advertising, and features. For example, with your consent, we may collect advertising cookies. As another example, if you enable location-tracking on your mobile device and it shows you are close to a Litmos corporate event, we may reach out to you and let you know you should visit our nearby event. If you access the Site through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. This data processing is necessary to provide or fulfil a service requested by or for you, and can be disabled by you.
• Maintaining your Litmos account
• Protection of Litmos and Others. For example, we may disclose your information to: (i) comply with legal obligations; (ii) enforce any agreements that you entered into with us; (iii) respond to claims that any content violates the rights of third parties; (iv) respond to your requests for customer service; and/or (v) for security (e.g. fraud prevention and the prevention of unauthorized access). We may also disclose information to law enforcement agencies in emergency circumstances, where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law. This is data processing for compliance with a legal obligation.
• Business Transfers. For example, we reserve the right to disclose and transfer all of your information, to a successor (or potential successor) company in connection with a merger, acquisition, or sale of all, or components, of our business, or in connection with due diligence associated with any such transaction. Data processing for this purpose is a legitimate business interest.

 

From What Types of Third Parties does Litmos obtain Personal Data?

In most cases Litmos collects Personal Data from you. Litmos might also obtain Personal Data from third parties, if the applicable national law allows Litmos to do so. Litmos will treat this Personal Data according to this Privacy Statement, plus any additional restrictions imposed by the third party that provided Litmos with it or the applicable national law. These third-party sources include:

• Litmos US, L.P. and its subsidiaries’ business dealings with your employer
• From third parties we work closely with (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers).
• From government authorities (e.g. law enforcement authorities for investigations)
• Other third parties, such as providers of publicly accessible sources (e.g. public websites, media, social media profiles, registers, records or databases), counterparties including their service providers (e.g. in litigation), or other companies or individuals at your direction.

 

How long will Litmos store my Personal Data?

The period for which Litmos retains your Personal Data depends on the purpose for which it is used. If you have an account with Litmos, Litmos will retain your data for as long as your customer account is active, unless otherwise specified. Litmos will only store your Personal Data for as long as reasonably necessary to accomplish Litmos’s legitimate business purposes, such as:

• for the performance of services between you and Litmos;
• to make the Site available to you;
• for Litmos to comply with its statutory or regulatory obligations resulting from applicable export laws or other laws/regulations that oblige Litmos to retain personal data;
• to allow you to participate in our corporate events;
• to the conclusion of activities described in this Privacy Statement as being based upon legitimate business interest or until you object against such use;
• to the conclusion of activities described in this Privacy Statement as being based upon consent or until you revoke your consent;
• to fulfill the purposes outlined in this Privacy Statement.

 

Litmos will also retain your Personal Data for additional periods if it is required by mandatory law to do so, or where your Personal Data is required for Litmos to assert or defend against legal claims. In such case, Litmos will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled. In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

 

Who are the recipients of your Personal Data and where will it be processed?

Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:

• Companies within the Litmos US, L.P. and its subsidiaries
• Third party service providers, including those providing consulting services and additional related services, e.g. third party servicers for consulting services and other additional related services
• Other service providers, e.g. for the provision of the website or newsletter dispatch
• State agencies and bodies, or regulatory authorities, e.g. based on entry requirements or police activities and investigations
• Our agents, partners or contractors who assist us in providing the services we offer through our Site. The assistance provided by our agents, partners or contractors may be related to our marketing activities such as: updating marketing lists, data analytics, advertising, market research, participation in a contest or sweepstakes, and receiving and sending communications. Transactional assistance may also be provided by our agents, partners or contractors, including: processing transactions, fulfilling requests for information, billing, sales execution, and fulfilment of orders. Other support services provided may include: data storage, transfer, analysis and processing, legal services, providing IT, and in other tasks as requested, from time to time. Our agents, partners and contractors will only use your information to the extent necessary to perform their functions under this Policy and are subject to contractual restrictions prohibiting them from using your information for any other purpose.
• Professional advisors, including lawyers, bankers, auditors, and insurers

We share your information with the above categories of third parties for the following purposes:

• To protect Litmos and others: We may disclose any of your information to:(i) comply with legal process; (ii) enforce any agreements that you entered into with us; (iii) respond to claims that any content violates the rights of third parties; (iv) respond to your requests for customer service; and/or (v) the extent necessary for the purposes of the legitimate interests pursued by us or by the third party or parties to whom the data are disclosed, except where such interests are overridden by the interests for fundamental rights and freedoms of the data subjects.
• We may also disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

International Data Transfers

As part of a global group of companies operating internationally, Litmos has affiliates and third-party service providers outside of the European Economic Area (the “EEA”) or from a region with a legal restriction on international data transfers and will transfer your Personal Data to countries outside of the EEA. If these transfers are to a country for which the EU Commission has not issued an adequacy decision, Litmos usually uses the EU standard contractual clauses to contractually require that your Personal Data receives a level of data protection consistent with the EEA. In the in the absence of standard contractual clauses, we particularly rely on the following derogations: (i) you have given your explicit consent; (ii) it is necessary for the conclusion or performance of a contract with you or in your interests (iii) it is necessary for important reasons of public interest (iv) it is necessary to establish, exercise, or defend legal claims, or (v) it is necessary for the purposes of our compelling legitimate interests. You can obtain more details about our third country transfers or a copy (redacted to remove commercial or irrelevant) of our safeguards such as standard contractual clauses by sending a request to privacy@litmos.com. You can also obtain more information from the European Commission on the international dimension of data protection here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_fr

 

EU-US, UK-US Data Privacy Framework (DPF)

In addition to having an intragroup data transfer agreement, and in addition to any applicable GDPR Article 49 derogations, Litmos complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Litmos is in the process of self-certifying to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and (once we have completed our certification) to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Litmos commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact Litmos at: privacy@Litmos.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Litmos commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services of TRUSTe are provided at no cost to you.

The Federal Trade Commission has jurisdiction over Litmos’s compliance with the DPF and the UK Extension.

Additionally, an individual has the possibility, under certain conditions, to invoke binding arbitration in the US for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms; for additional information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2

If Litmos receives personal information under the DPF Principles and then transfers that personal information to a third-party, Litmos shall remain liable under the DPF Principles to the extent the third party’s actions are inconsistent with the DPF Principles, unless Litmos provides information in support of Litmos not having responsibility for the event.

 

B. Processing based on a statutory permission

Why does Litmos need to use my Personal Data and on what legal basis is Litmos using it?

Consent

In specific cases we process your personal data only if you have given your consent, Art. 6(1), (a) GDPR. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. For example, personalized Newsletter. If you opt-in to receive marketing communications such as newsletters from Litmos, Litmos will collect and store details of how you interact with the newsletters to help create, develop, operate, deliver and improve our newsletter communications with you. This information is aggregated and used to help Litmos provide more useful information and to understand what is of most interest.

Processing to fulfill contractual obligation

Litmos requires your Personal Data to deliver goods or services you order under a contract Litmos has with you, to establish a contract for goods or services between you and Litmos, and to send you invoices for ordered goods or services.

Additionally, Litmos requires your Personal Data to provide you, at your request, with access to Litmos events or Litmos materials such as whitepapers. Litmos processes Personal Data to fulfill contractual obligations pursuant to Article 6(1), 1(b) GDPR, or the equivalent article under other national laws, when applicable.

Processing to ensure compliance

Litmos and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, Litmos is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through Litmos’s websites or other delivery channels controlled by Litmos. This could include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to Litmos’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match. Any such use of your Personal Data is based on the permission to process Personal Data in order to comply with statutory obligations (Article 6 (1), (c) GDPR or the equivalent articles under other national laws, when applicable) and Litmos’s legitimate interest (Article 6 (1), (f) GDPR or the equivalent articles under other national laws, when applicable).

Processing based on Litmos’s legitimate interest

Litmos can use your Personal Data based on its legitimate interest (Article 6 (1), (f) GDPR or the equivalent articles under other national laws, when applicable) as follows:

• Fraud and Legal Claims. If required, Litmos will use your Personal Data for the purposes of preventing or prosecuting criminal activities such as fraud and to assert or defend against legal claims.
• Questionnaires and survey. Litmos could invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any data that can be used to identify you. If you nonetheless enter such data in a questionnaire or survey, Litmos will use this personal data to improve its products and services.
• Contract Performance. If you purchase or intend to purchase goods or services from Litmos on behalf of a corporate customer or otherwise be the nominated contact person for the business relationship between a corporate customer (a “Customer Contact”) and Litmos, Litmos will use your Personal Data for this purpose. This includes, for the avoidance of doubt, such steps which are required for establishing the relevant business relationship. In case that an existing Customer Contact informs Litmos that you are his replacement, Litmos will, from the point in time of such notification, consider you to be the relevant Customer Contact for the respective customer until you object as further set out below.
• Creation of anonymized data sets. Litmos will anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates’ products and services.
• Recordings for quality improvement purposes. In case of telephone calls or chat sessions, Litmos will record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of Litmos’s services.
• To keep you up-to-date or request feedback. Within an existing business relationship between you and Litmos, Litmos might inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from Litmos. Furthermore, where you have attended a webinar, seminar or event of Litmos or purchased products or services from Litmos, Litmos might contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.
• If we rely on your consent to process your Personal Data, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

 

C. Cookies and Similar Tools

Information gathered by cookies or similar technologies, and any use of such information, is further described in Litmos’s Cookie Statement. You can exercise your cookie preferences as outlined in Litmos’s Cookie Statement by visiting the “Cookie Preferences” link in the bottom footer of the homepage.

D. Children Litmos does not knowingly collect the Personal Data of children under the age of 16. If you are a parent or guardian and believe Litmos collected information about a child, please contact Litmos as described in this Privacy Statement. Litmos will take steps to delete the information as soon as possible. Given that Litmos is not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, Litmos does not sell the Personal Data of any minors under 16 years of age.

 

E. Additional Information for U.S. Residents

Collection of Information

We have collected the categories of personal information set out below within the last 12 months for the purposes outlined above is Paragraph A. We may share your personal information with our business partners, service providers, contractors, sub-contractors, advertising networks, analytics providers, and search information providers as outlined above. Note that the categories listed below are defined by California state law. Inclusion of a category in the list below indicates only that we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all Site visitors.  As noted above, we may share the below categories of information with our third-party service providers.

 

Category of Personal Information Collected	Sources	Purpose of Collection, Processing, and Disclosure
Personal identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Directly from you, when you communicate with us, including through our forms on our website, when you register as a user of the Site or for the Customer Portal, when you use our website’s chat feature, when you request information or material from us, or when you register for and attend a Litmos corporate event.   We may also collect this information from our service providers.	To operate our business To perform our contractual requirements To provide customer service and respond to requests or inquiries To engage in marketing and sales activities To communicate with you
Information About You. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Directly from you, when you communicate with us, including through our forms on our website, when you register as a user of the Site or for the Customer Portal, when you use our website’s chat feature, when you request information or material from us, or when you register for and attend a Litmos corporate event.   We may also collect this information from our service providers.	To operate our business To perform our contractual requirements To provide customer service and respond to requests or inquiries To engage in marketing and sales activities To communicate with you
Commercial information: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Directly from you, when you communicate with us, including through our forms on our website, when you register as a user of the Site or for the Customer Portal, when you use our website’s chat feature, when you request information or material from us, or when you register for and attend a Litmos corporate event.   We may also collect this information from our service providers.	To operate our business To perform our contractual requirements To develop and deliver our products and services To provide customer service and respond to requests or inquiries
Internet or other electronic network activity information: browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	This information is collected directly from you, through the use of cookies, web beacons, clear gifs, social plug-ins, or other similar technology	To engage in marketing and sales activities To communicate with you

 

In addition to the categories of personal information above, we also collect the following categories of sensitive personal information:

 

Category of Personal Information Collected	Sources	Purpose of Collection, Processing, and Disclosure
Racial or ethnic origin	Directly from you, when you register as a user of the Site or for the Customer Portal and choose to upload a profile photo or video content.   We may also collect this information from our service providers.	To provide customer service and respond to requests or inquiries To communicate with you
Precise Geolocation	From you, when you access our Site through a mobile device that is configured to provide location information	To provide customer service and respond to requests or inquiries To engage in marketing and sales activities For security purposes

 

 

F. Consumer Rights

Depending on your jurisdiction, you may be entitled to the rights described below, subject to certain conditions and limitations. We may choose to offer these rights, even if we are not required to under applicable privacy law.

• Right to access/know. You have the right to know and request information about the categories and specific pieces of personal information we have collected about you (in some jurisdictions limited to the last 12 months), as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties, or specific third parties, depending on your jurisdiction, with whom we share such information.  You also have the right to know if we have sold or disclosed your personal information.
• Right to correct. You have the right to request correction of any inaccurate information we hold about you.  We may not be able to accommodate your request if we believe it would violate any law, any legal requirements, or cause the information to be incorrect. Information solely retained for data backup purposes is generally excluded.
• Right to delete. You have the right to request the deletion of your personal information, subject to certain exceptions.
• Right to limit use and disclosure of or opt-in to processing of sensitive personal information. Depending on your jurisdiction, you may have the right to limit our processing and use of your sensitive personal information. You may also have the right to opt-in to the processing of your sensitive information. The categories of sensitive personal information we collect are described above.
• Right to opt-out of the sale or sharing of personal information. We do not sell personal information, however, we do share personal information with third parties for cross-context behavioral advertising or targeted advertising. Depending on your jurisdiction, you may have the right to opt-out of the sharing of your personal information for cross-context behavioral advertising and targeted advertising.
• Right to know and question profiling decision. Depending on your jurisdiction, and whether your personal data is profiled in furtherance of decisions that produce legal or similarly significant effects concerning you, you may have the right to question the result of said profiling, the right to be informed of the reason that the profiling resulted in the decision, and, if feasible, the right to be informed of what actions you might have taken to secure a different decision and that you might take to secure a different decision in the future. You also have the right to review the personal data used in the profiling decision. We do not engage in profiling, therefore we do not offer this right.
• Right to correct data and reevaluate decision related to profiling decision. Depending on your jurisdiction, if a profiling decision was based upon inaccurate personal information, taking into account the nature of the personal data and purpose of processing, you may have the right to have the data corrected and the profiling decision reevaluated based upon the corrected data. We do not engage in profiling, therefore we do not offer this right.
• Right to portable data. You have the right to obtain personal information about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance.
• Right to Withdraw Consent and Object. You can withdraw your consent at any time and object to Litmos’s use of your Personal Data as set forth in this section by sending an email to privacy@litmos.com. In case of objection, Litmos will carefully review your objection and cease further use of the relevant information, subject to Litmos’s compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if Litmos requires the information for the establishment, exercise or defense of legal claims. Where personal data is processed for direct marketing purposes, the you have the right to object at any time.
• Right to lodge a complaint with a supervisory authority. If you have any concerns about how we process your personal data, we encourage you to let us know so we can try to resolve your concerns. Irrespective of this, if you think we have not complied with data protection laws, you have the right to lodge a complaint with the competent supervisory authority under Art. 77 GDPR.
• Right to non-discrimination. You have the right to not be discriminated against for exercising any of the above-listed rights.

 

In accordance with the disclosure requirements under the California Consumer Privacy Act (“CCPA”), Litmos does not and will not sell your Personal Data.

Litmos will require a more stringent verification process for deletion requests, or for Personal Data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your Personal Data. If Litmos must request additional information from you outside of information that is already maintained by Litmos, Litmos will only use it to verify your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes. 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 use the personal information you provide to us when submitting a consumer request only to verify the requestor’s identity or authority to make the request.

Data solely retained for data backup purposes is principally excluded from these rights until it is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose. These rights also do not apply to pseudonymous data if the information necessary to identify the individual is kept separately and is subject to controls that prevent access to the information. Pseudonymous data is personal data that can no longer be attributed to a specific individual without the use of additional information, if the additional information is kept separately and is subject measures to ensure that personal data is not attributed to the specific individual.

In addition to contacting Litmos at privacy@litmos.com or submitting a request via our webform https://www.litmos.com/data-removal-request, you may also exercise your rights as follows. You can designate an authorized agent to submit requests to exercise your data protection rights to Litmos. If you are submitting a request through an authorized agent, the authorized agent must provide us with your signed written permission stating that the agent is authorized to make the request on your behalf.  Alternatively, your authorized agent may provide evidence of having power of attorney or acting as a conservator for you. We may also request that any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.

Depending on your jurisdiction, we have between 30 and 90 days to respond to your request.

There may be circumstances where we will not be able to honor your request, in which case, we will notify you.  For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes. Depending on your jurisdiction, you may have the right to appeal this decision or to contact your Attorney General if you have concerns about the results of the appeal.

Please note that depending on your jurisdiction, we may only be obligated to respond, free of cost, to personal information requests from the same consumer up to two times in a 12-month period. Depending on your jurisdiction, after you have exceeded the applicable number of requests, we may have the right to charge a reasonable fee for fulfilling the request. In addition, under the applicable state privacy law, and for the protection of your personal information, we may be limited in what personal information we can disclose.

Depending on your jurisdiction, we may maintain your rights requests for at least 2 years. This information will not be used for any other purpose except to review compliance processes; it will not be shared except as necessary to comply with a legal obligation.

 

Do Not Track Signals

We partner with third parties to display advertising on our websites or to manage our advertising on other websites. Our third-party partners use cookies, web beacons, LSOs, tags, scripts, and similar technologies to gather information about you over time and across different websites or applications to help predict your preferences and show you ads on sites across the Internet. If you wish to manage your cookie preferences directly with us, please click [insert link] or make a request using one of the methods outlined in the Cookies Section of this policy.

We recognize your use of a universal opt-out mechanism for the purpose of targeted advertising or sale of your personal data. If there is a conflict between the opt-out request received via a universal opt-out mechanism and your existing privacy setting, we will comply with your opt-out preference and notify you of the conflict. The notification will provide you with the option to confirm either the privacy setting or participation in the program.

 

Third Party Content and Links

Our website may include links to third-party websites plug-ins, and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control third-party websites and are not responsible for their privacy statements.  If you submit personal information to any third-party websites or service providers, your information is governed by their privacy policies.  When you leave our website, we encourage you to read the privacy policy on every website you visit.

 

Changes to the Privacy Policy

From time to time, we may update this privacy policy.  We will post any revised version of this privacy policy on our website.  Any changes will be effective on the effective date stated in the revised policy.  This privacy policy was last updated as of the effective date listed above.  We will not use previously collected personal information for a new purpose without providing notice and/or obtaining your consent, as appropriate.  We may make minor changes to this policy without providing advanced notice and/or obtaining your consent.  We encourage you to periodically review this page for the latest information on our privacy practices.

 

Contact us

Have additional privacy questions or need further info?

If you have any questions, comments, or concerns regarding this Policy or Litmos’s privacy practices, they may be submitted via email to privacy@litmos.com, or in writing by addressing your inquiries to:

Litmos US, L.P.
548 Market St, Unit # 34398
San Francisco, CA 94104-5401
Attn: Legal