Privacy Statement
February 8, 2011 (no older versions at this time)
Translational Education LLC (the “Company”) is a thought-leader in education and health products and services. This Privacy Statement applies to all of the products, services, and websites offered by Translational Education LLC or its subsidiaries or affiliated companies (hereinafter collectively referred to as “Translational Education,” the “Company,” “we,” “us,” or “our”). Sometimes, we may post product specific privacy notices or materials to explain our products, services, and websites in more detail.
By using or accesssing our products, services, and websites, you agree to our privacy statement outlined here.
If you have any questions about this Privacy Statement, please feel free to contact us through our website at compliance@translationaleducation.com. If you have a complaint, please contact us thorugh our website AND write to us at:
Compliance
c/o Beth Ann Wright
Translational Education LLC
1166 A Bonhomme Lake Dr.
St. Louis, MO 63132
USA
Information we collect and how we use it
We may collect the following types of information:
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•Information you provide – When you visit or use our products, services and websites, you may share content (provide information) with others. Some of our products, services, and websites allow you to provide information without signing up for an account, while other products, services, and websites require you to sign up for an account to provide information. No opt-in is provided for information you provide that is manifestly made public by you. When you sign up for a Translational Education account, we ask you for personal information. When you purchase products or services, you provide information to process the payment and details of the transaction. We may combine the information you submit under your account with information from other Translational Education products, services, or websites, or third parties in order to provide you with a better experience and to improve the quality of our products, services, and websites. For certain services, we may give you the opportunity to opt out of combining such information. If you are using Translational Education products, services, and websites in conjunction with your Translational Education Data Registry Account, we provide such products, services, and websites in conjunction with or on behalf of your Translational Education Data Registry administrator. Your administrator will have access to your account information including your email. The Translational Education Data Registry administrator adheres this privacy statement.
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•Information you provide related to journalistic material – When you visit or use our products, services and websites, personal information that is gathered for publication, broadcast, or other forms of public communication of journalistic material, whether used or not, as well as information found in previously published material disseminated from media archives, is not subject to the requirements of the Safe Harbor Principles or this Privacy Statement.
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•Information other users provide about you – When you use a Translational Education Account, you may consent to allowing other Translational Education Account holders to provide information about you.
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•Information you provide about others – When you use a Translational Education Account, you may consent to providing information about other Translational Education Account holders.
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•Cookies – When you visit us, we send one or more cookies to your computer or other device. We use cookies to improve the quality of our products, services, and websites, including for storing user preferences, improving product and service offerings, and product and service selection, and tracking user trends, such as how people choose and use our products, services, and websites. The Company also uses cookies in its advertising services to help advertisers and publishers serve and manage ads across the web and on the Company’s products, services, and websites.
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•Log information – When you access our products, services, and websites via a browser, application or other client, our servers automatically record certain information. We may use a technology known as web beacons - sometimes called single-pixel gifs - that allow this site to collect web log information. A web beacon is a graphic on a web page or in an e-mail message designed to track pages viewed or messages opened. These server logs may include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account. We may also include web beacons in promotional e-mail messages in order to determine whether messages have been opened.
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•User communications – When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our products, services, and websites. When you send and receive SMS messages to or from one of our products, services or websites that provides SMS functionality, we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction. We may use your email address to communicate with you about our products, services, and websites.
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•Third Party Applications – The Company may make available third party applications, such as gadgets, extensions, and web apps, through its services. The information collected by us when you enable a third party application is processed under this Privacy Statement. Information collected by the third party application provider is governed by their privacy policies.
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•Location data – The Company may offer location-enabled services. If you use those services, we may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location (such as a cell ID). Information collected by the third party application provider is governed by their privacy policies.
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•Unique application number – Certain services, such as Web Apps include a unique application number that is not associated with your account or you. This number and information about your installation (e.g., operating system type, version number) may be sent to us when you install or uninstall that service or when that service periodically contacts our servers (for example, to request automatic updates to the software or to administer digital rights management features).
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•Other sites – This Privacy Statement applies to our products, services, and websites only. We do not exercise control over the sites displayed as search results, sites that include Translational Education applications, products or services, or links from within our various services or websites. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.
In addition to the above, we may use the information we collect to:
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•Provide, maintain, protect, and improve our products, services, and websites (including advertising services) and develop new services; and
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•Protect the rights or property of the Company or our users.
If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.
The Company processes personal information on servers in the United States of America and may in other countries. In some cases, we process personal information outside your own country.
Choices
You can use your Translational Education Account to review and control the information stored in your Translational Education Account. You understand that even after you edit, amend, or delete information from your Account, copies of that information may remain viewable elsewhere to the extent that it has been shared with others, was otherwise distributed, or was copied or stored by others.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our features and services may not function properly if your cookies are disabled.
Information sharing
We only shares personal information with other companies or individuals outside of the Company in the following limited circumstances:
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•We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
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•We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. The Company shall ensure that any third party for which personal information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
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•We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
If the Company becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions, and the transfer of your information to the new owner so that the products, services and websites may continue to operate. We will provide notice before personal information is transferred if it becomes subject to a different privacy statement.
Information security
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.
We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
You understand the risks inherent in sharing information. We cannot control the actions of others with whom you provide information. We cannot guarantee the security of information on or transmitted via the Internet.
Accessing and updating personal information
When you use our products, services, and websites, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. Access may be denied for personal information processed solely for research or statistical purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. In such cases, we may charge a reasonable fee for access to individual information. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from active servers and may remain in backup systems.
Enforcement
The Company adheres to the US Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement, and is registered with the U.S. Department of Commerce Safe Harbor Program.
The Company uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies that the Statement is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we will cooperate and comply with appropriate legal and regulatory supervisory authorities that provide for handling of individual complaints to resolve any complaints regarding the transfer of personal data that cannot be resolved between us and an individual.
Changes to this Privacy Statement
Please note that this Privacy Statement may change from time to time. We will not reduce your rights under this Privacy Statement without your explicit consent. We will post any Privacy Statement changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Statement changes). We will also keep prior versions of this Privacy Statement in an archive for your review.
To be removed from our contact lists, please write to us at the following address:
Translational Education LLC
1166 A Bonhomme Lake Dr.
St. Louis, MO 63132
USA
Please note that you may continue to receive materials while we are updating our lists.
We may update this website Privacy Statement from time to time. When we do update it, for your convenience, we will make the updated statement available on this page.
Last Updated: February 8, 2011
