Privacy

Last updated: August 27, 2020

This Privacy Policy describes how Grace Hill (“Grace Hill” or “We”) collects and uses certain personal information as a result of the use of our platforms, including Vision, Validate, Visto, and PolicyPartner and the content and services that Grace Hill provides through other means (the products and services that Grace Hill offers are hereinafter, the “Services”) as well as through our website, www.gracehill.com (the “Website”).  This Privacy Policy is not applicable to services provided by Kingsley Associates, Inc., which is governed by the privacy policy available at https://kingsleyassociates.com/website-privacy-policy/.  In administering the Services and the Website, we are committed to protecting your Personal Information (described below). Subject to the terms of this Privacy Policy, we will not disclose your Personal Information to any third party without your consent. This Privacy Policy describes:

i. what Personal Information Grace Hill receives or collects from you or your device;

ii. how Grace Hill uses and shares your Personal Information with others; and

iii. your choices and obligations regarding your Personal Information.

By using or accessing the Services or the Website, you agree to Grace Hill’s use of your Personal Information as described herein and to be legally bound by this Privacy Policy as amended from time to time. If you do not agree with this Privacy Policy without limitation or qualification, you should not access or use the Services or the Website. Your continued use of the Services or the Website after we change this Privacy Policy will mean that you accept and agree to be bound by the changes. Because we reserve the right to modify the Agreement at any time, please check this Privacy Policy regularly for changes.

Our Services are provided under a contract with our clients. Grace Hill’s client may be you, your employer, an agent of your employer, an affiliate of your employer, or another person or legal entity who enters an agreement with Grace Hill for the Services that are provided to you (a “Client”). We are not responsible for the data practices of our Clients.

 

Application of this Privacy Policy

This Privacy Policy governs Grace Hill’s Services and Website and not any third party website, the Internet, or any other network. Grace Hill is not responsible for the privacy practices or the content of any third party websites or services with which Grace Hill communicates. By clicking on a link, logo or any item associated with a third party site, please note that you are exiting Grace Hill and the protections afforded by this Privacy Policy.

 

Contacting Us

If you have any questions or would like to make a verifiable consumer request about this Privacy Policy, our Services, or the Website, you may contact Grace Hill Customer Service at Grace Hill, 300 Executive Center Drive, Suite 201, Greenville, SC 29615, or toll-free by phone at (866)472-2344, or by email to notices@gracehill.com.

 

Personal Information

Grace Hill collects Personal Information from you to enable Grace Hill to provide the Services. We also collect Personal Information that you provide to us on our Website and when using the Services. The level of Personal Information depends on the Services used as well as the amount of information you provide to us on the Website. “Personal Information” includes:

Access Credentials When you or our client registers your account (the “Account”) for the Services, access credentials are provided to us for security purposes, such as to authenticate your identity each time you use the Services, including information that identifies one or more of the following: a user name, a password, a personal identification number (PIN) and/or responses to security questions (collectively, your “Access Credentials”). Your Access Credentials may be used when you access your Account for the Services.

Contact Information When you or our Client registers or updates your Account, your contact information is provided to us. Contact information includes, without limitation, your name, postal address, email address, telephone number, and facsimile number and other information you provide to us (collectively, your “Contact Information”). You may also provide us with Contact Information when you use our Website, such as through our chatterbot.

Device Information When you access the Services or the Website, we may obtain technical information that identifies your device and other technical parameters associated with your device, including your internet service provider, your IP Address, access point names (APNs), packet data networks, the make and model of your device; the type or version of your operating system; unique device identifier(s), a media access control (MAC) address, information associated with your service provider or mobile carrier, your internet browser type, specifications regarding your device hardware and/or software, etc. (collectively, your “Device Information”).

Location Information When you access the Services or the Website, we may collect and process information about your device’s actual location using global positioning system signals sent by your device, from a third-party location service, or from other sources that identify or describe the location from which your device is communicating with us.

Profile Information When your Account is created, you or our client may include additional information about you in a profile for your Account. Your profile may also include context information that identifies one or more of the following: your gender, primary or secondary languages, date of birth, profession or trade, employer, permission regarding your device location accuracy, permissions regarding your use of the Services, etc. (collectively, “Profile Information”).

Usage Information When you use the Website and/or the Services, we record your usage history (e.g., frequency of access, web pages accessed, Services accessed, duration of access, etc.), course history (e.g., classes taken, progress, courses completed, certifications earned, content accessed, etc.), performance history (answers to quizzes, communications with us, email messages, comments, etc.), reviews, messages, download history, etc. (collectively “Usage Information”).

 

Use of Your Personal Information

By using or accessing the Website or Services, you are voluntarily and unconditionally accepting the terms and conditions of the Grace Hill Terms of Use and this Privacy Policy and are freely accepting and agreeing to our use of your Personal Information in accordance with this Privacy Policy. You further acknowledge and agree that your access or use of the Website or the Services, or providing your Personal Information to us, including any information deemed “sensitive” by applicable law, is entirely voluntary on your part. Grace Hill may disclose and otherwise use your Personal Information for the following reasons:

Our Internal Use. We use your Personal Information for our own internal purposes, including to provide the Services and the Website to you, to verify your identity, to create your Account, to improve the Services and the Website, and to record and analyze the use of the Services and the Website (i.e. to determine your performance, your use of the Services and Website, the content you have viewed, etc.).

To Fulfill Our Obligations to Clients. You use the Services as a result of an agreement between Grace Hill and one or more of our Clients. The Client may be you, your employer, or another person as described herein. We provide your Personal Information to the Client(s) which has an agreement with Grace Hill under which the Services are provided to you. This allows the applicable Client to understand your use of the Services, including how you perform, what training content you have viewed, etc.

Creating De-Identified Personal Information. We encode or obfuscate your Personal Information to create de-identified Personal Information that removes any information that allows you to be identified. We use the de-identified Personal Information for our own internal purposes, for data aggregation, performance monitoring, statistical compilations and analytics, improving the Website and Services and when providing the Services to you.

Our Communications to You. We communicate with you through the Services, the Website (through our chatterbot) as well as email, text message, other messaging methods to market our Services and to provide notices to you to, for instance, inform you how to best use our Services, to recommend certain Services, to notify you of new features or functionality, planned disruptions, or other promotion or advertising content.

Identifying You to other Users.  We may identify you to other users of the Services using some of your personal information (when you get an award for performance, etc.).

Marketing the Services. We may use your Personal Information to market the Services to you and to the Client(s) associated with you.

Enforcing this Privacy Policy, Our Terms of Use, and Client Agreements. We may disclose your Personal Information to enforce or apply this Privacy Policy, our Terms of Use and/or our agreements with Clients.

Third Party Service Providers. To our contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep your Personal Information confidential and use it only for the purposes for which we disclose it to them.

Related Parties/Successors. We may disclose your Personal Information to our subsidiaries and affiliates, which will use your Personal Information only as described herein. Further, we may disclose your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Grace Hill’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which your Personal Information is among the assets transferred.

Harm; Compliance with Law; Other Uses. We may disclose your Personal Information to comply with a court order, law, subpoena, discovery request or legal process, including to respond to any government or regulatory request. Further, we may disclose your Personal Information if we believe that disclosure is necessary or appropriate to protect the rights, property or safety of Grace Hill, our Clients, or others. Finally, from time to time, we may use your Personal Information for new, unanticipated uses, such as notification of new services, announcements and general communications. If our information practices materially change at some time in the future, we will post such changes to this Privacy Policy before we use your Personal Information for these new purposes.

Except as stated above, Grace Hill will not sell or otherwise distribute your Personal Information, except that Grace Hill expressly reserves the right to sell or otherwise share de-identified Personal Information with others or to make it public.

 

How we Collect Your Personal Information

Information You Provide to Grace Hill. When you visit the Website, you may provide your Personal Information to us when, for instance, you engage in digital communications with our Website.  For example, the Website includes a chatterbot, which may ask you questions and allow you to respond. When you respond, we may use the Personal Information you provide to us. Further, when you access and use the Services, you may provide your Personal Information to us, such as when you populate your profile, select a course in Vision, view Grace Hill’s content, etc.

Information Provided to Grace Hill by Our Clients. If you use the Services subject to an agreement between Grace Hill and a third party (i.e. your employer, an affiliate or agent of your employer, etc.), your Personal Information may be provided to us by our Client.

Automated Collection of Personal Information. We use automatic data collection methods to collect and store information when you access the Website or the Services. This may include sending one or more cookies or anonymous identifiers to your device. We may also use cookies and anonymous identifiers when you interact with the Services. A cookie is a small file placed on the hard drive of your device. You may refuse to accept cookies by changing the settings of your device, but this may render you unable to access certain portions of the Website and/or Services. We may use flash cookies, which we store and which collect and store information about your use of the Website and/or Services. We may use web beacons (also known as web bugs, clear Graphics Interface Format pixel (or “clear GIFs”), 1 x 1 pixel, etc.) in combination with cookies or other functions to understand how you interact with the Website or the Services or to create analytics or other administrative functions. Beacons do not collect Personal Information. New approaches that offer alternatives to cookies and beacons to better protect your privacy and to improve the security of your Personal Information may be explored by Grace Hill or third parties from whom Grace Hill obtains hosting or other services. In the event that any of these approaches are used in addition, or as an alternative, to cookies or beacons, Grace Hill will update this Privacy Policy accordingly.

 

Data Security

We exercise great care in providing secure transmission of your Personal Information between your device and the servers on which the Website and Services are hosted. We also take great care to protect your Personal Information that we store for our use as described herein. We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use and disclosure.  The safety and security of your Personal Information also depends on you. For example, if a password is required for you to access the Services, you should not share your password with anyone. Unfortunately, no data transmission over the internet is completely secure, and, despite our efforts to protect your Personal Information, we cannot guarantee the security of your Personal Information. Any transfer of your Personal Information is at your own risk.

 

Your Choices and Obligations Regarding your Personal Information

Rights to Access, Change, or Delete Your Personal Information. When you access the Services, you may review or modify some of your Personal Information, including portions of your Access Credentials, Contact Information, and Profile Information. To ensure that we can continue providing the Services, performing security functions (for example, authenticating your identity), and maintaining your Account, you are not permitted to delete certain Personal Information including portions of your Contact Information, Access Credentials, device information and usage information.

Rights to Delete Your Personal Information. You may terminate your Account or request the deletion of your Personal Information at any time. When you request to terminate your Account, we will retain a copy of your Personal Information as needed to fulfill our obligations to our Clients (i.e. to including your usage history, etc.). Other than this copy, your Account and Personal Information will be deleted. Because of the way we maintain the Services and the Website, such deletion may not be immediate, and residual copies of your Personal Information may remain on backup media for up to ninety (90) days. Notwithstanding the foregoing, Grace Hill reserves the right to retain some or all of your Personal Information if, in our sole discretion, we determine that it is reasonably necessary to comply with applicable law, meet our legal obligations, comply with regulatory requirements, resolve disputes between users or Clients, prevent fraud and abuse, or enforce this Privacy Policy and the Grace Hill Terms of Use. Furthermore, Grace Hill reserves the right to retain a copy of a de-identified version of your Personal Information for any legal purpose.

Your Obligations. You agree not to upload, copy or otherwise use or disseminate any information that may violate the rights of others. You agree that you are authorized to upload any information that you provide to Grace Hill via the Website or the Services. You agree not to provide any information to Grace Hill that you are not authorized to provide. You further agree to keep your Access Credentials strictly confidential and to not share them with any unauthorized user or third party.

Any violation of this Privacy Policy may lead to the restriction, suspension, or termination of your Account at the sole discretion of Grace Hill.

 

Policy Toward Children

NEITHER THE WEBSITE NOR THE SERVICES ARE DIRECTED TOWARD CHILDREN UNDER THIRTEEN (13) YEARS OF AGE (the “Minimum Age”) WITHIN THE MEANING OF THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT OF 1998 (COPPA).

If you become aware that your child has provided us with Personal Information without your consent, please contact us at notices@gracehill.com. We do not knowingly collect Personal Information from children below the Minimum Age. If we become aware that a child under the Minimum Age has provided us with Personal Information, we will take steps to promptly remove such Personal Information and terminate the Account associated with the child.

 

California Privacy Rights

If you reside in the state of California, our Privacy Notice for California Residents is part of this Privacy Policy and applies to you. By providing this Privacy Notice, Grace Hill is not waiving the business-to-business exception to the California Consumer Privacy Act.

Click here to download the Grace Hill Privacy Policy.

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