We will be updating the AchieveForum privacy policy due to the recent merger with Korn Ferry. The new terms will take effect automatically on June 29th 2020 and can be previewed here.

                                The policy update will:

                                • Give more detail on Korn Ferry’s business and services;
                                • Provide information on how your data is accessed by Korn Ferry;
                                • Confirm how to exercise your data rights; and
                                • Set out how cookies operate on Korn Ferry’s sites.

                                PRIVACY POLICY

                                AchieveForum, Inc., a member of the TwentyEighty, Inc. family of companies, is committed to protecting the privacy of those who visit our websites and those with whom we do business. As part of our normal operations, we collect different kinds of information about our website visitors. We have, however, structured our websites so that people have the option to visit without identifying themselves or revealing any personal information.

                                The following are things you can do while visiting our website if you prefer NOT to have information about your visit collected.

                                • Disable cookies within your browser before visiting our website (you may also click here to manage your cookie settings with respect to this website);

                                • Choose not to submit information via web forms located within our website;

                                • Choose not to purchase from our online store (if applicable);

                                • Choose not to “opt-in” to certain programs that are available on our websites;

                                • Choose not to complete any surveys available on our website.

                                • Choose not to complete any surveys available on our website.

                                The following describes the information we collect and how that information is used to provide our visitors with the optimal online experience.


                                COOKIES AND SPOTLIGHT IMAGES OR WEB BEACONS

                                We sometimes use session cookies to limit popup windows to a single browser instance. We also use Javascripting in cooperation with cookies and “spotlight images” or “web beacons” to track website traffic and email response. A “spotlight image” or “web beacon” is an electronic image, called a 1-by-1 pixel or clear GIF, that can recognize certain types of information on your computer, such as a cookie number, time and date of a page view and so on. These methods do not collect any personal information, but simply aggregate information that allows us to research patterns of behavior on our site to learn how to better meet our visitors’ needs. Our online store uses cookies to store order information. You may refuse cookies by turning off that feature on your web browser.

                                This website uses Marketo Munchkin cookies (“Marketo”). Marketo's cookie allows us to track repeated visits to the website, and link each visit to the information voluntarily provided by the visitor. For example, if the visitor is asked to provide us with name, company name and email address, we will know the identity of the visitor when they visit the site at a later date. We also use Munchkin to track email open rates and click through rates, allowing us to manage the email marketing experience. By using this website you are consenting to the above use of your data.

                                For more information on Marketo’s privacy and cookie policy, please visit Marketo privacy policy: http://www.marketo.com/trust/legal/privacy.

                                In addition, we may use or allow third parties to serve cookies on our site – specifically we use Google Analytics and Marketo to help us monitor our website traffic and understand visitor behavior.


                                INFORMATION WE COLLECT

                                You may be visiting our website for a variety of reasons. For the purpose of this privacy policy, we will classify these reasons as (i) browsing, (ii) submitting forms, (iii) purchasing products and services and (iv) completing surveys. Please note that not all activities may be available on our website at a given time. For each different type of activity, we collect and store different types of data for different reasons.

                                • Browsing – If you are simply browsing or navigating through our websites, we collect information about your computer and the pages you visit on our website in the aggregate (not individual or personal information). This data is often referred to as clickstream or navigation data. We use this information for research, analysis and reporting so that we can improve our navigation, page structure and page content to help visitors find information more quickly and provide more value when they find what they are looking for on our websites.

                                • Submitting Forms – Certain pages of our website contain forms that allow you to request information about our services and solutions, to register for events or to gain access to valuable resources (like white papers and research documents) in exchange for contact information. In completing one of these forms, you may be required to provide contact information, such as your name, phone number and/or email address.

                                • Purchasing – For purchasing in our online store or registering for events or courses, we will require you to create an account with us. We collect information in this account that enables us to complete your order and/or registration and streamline your purchasing process the next time you order from us. Furthermore, we will give you the ability to view and update this information if you so choose.

                                • Completing Surveys – For surveys, we collect responses to help us improve various aspects of our business based on aggregate and individual feedback provided. These surveys are sent via opt-in marketing programs or are made available on our website for you to participate if you so choose.


                                For purposes of the California Consumer Privacy Act of 2018 (“CCPA”), we collect and have collected within the preceding 12 months the following categories of personal information as listed in the CCPA:


                                Category A. Identifiers, such as name, contact information, IP address, and other online identifiers;

                                Category B. Personal information, as defined in the California customer records law, such as name, contact information, employment information;

                                Category C. Internet or network activity information, such as browsing history and interactions with our website;

                                Category D. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and abilities.


                                HOW WE USE AND SHARE YOUR INFORMATION

                                If you choose to provide us with your personal data, as contemplated above, in addition to using the data for the express purpose for which it was provided, we may, if permitted by applicable law, use your information to:

                                • Process a payment that you have made

                                • Process orders that you have submitted

                                • Carry out our obligations arising from any contracts entered into by you and us (or by your employer and us)

                                • Seek your views or comments on the services we provide through surveys or otherwise

                                • Notify you of changes to our services

                                • Send you communications that you have requested or that may be of interest to you, including activities or promotions of our products or services, or those of our affiliates

                                • Send you newsletters, event notices and announcements

                                • Process a job application

                                As a global organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, we have implemented global policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries worldwide and transfer it to countries in the world where we do business in accordance with this Privacy Notice.

                                Between our controlled subsidiaries we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, we use suppliers located in various countries to collect, use, analyze, and otherwise process personal information on our behalf.

                                Where appropriate, we may also share your personal information with selected partners to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes.

                                If we decide to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is our practice to require appropriate protection for personal information in these types of transactions.

                                If you do not wish for us to use your data in the ways described above, you may follow the instructions contained in the relevant communication, update your communication preferences in your online account (if applicable), or follow the instructions below, under the heading “YOUR RIGHTS”.

                                Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect our rights or property, or that of our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

                                We may place email links on this site to allow you to contact us directly via email. The information you provide is used to respond directly to your questions or comments. Those comments may be stored to improve the quality of our site and our services.

                                In addition, from time to time, we will purchase or rent relevant public mailing lists from reputable agencies that have obtained your prior approval to receive relevant information based on your personal preferences. Any promotional information sent to you by us will contain instructions on how to be removed from a mailing list source. We will also freely provide information about how and from whom your personal details were given to us when requested.


                                For purposes of the CCPA, we have disclosed the following categories of personal information as listed in the CCPA to third parties, as described in this Privacy Policy, for our operational business purposes within the preceding 12 months:


                                Category A. Identifiers, such as name, contact information, IP address, and other online identifiers;

                                Category B. Personal information, as defined in the California customer records law, such as name, contact information, employment information;

                                Category C. Internet or network activity information, such as browsing history and interactions with our website;

                                Category D. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and abilities.

                                We have not sold Personal Information, as “sale” is defined in the CCPA.


                                INTERNATIONAL TRANSFERS

                                Our international footprint may involve the transfer of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information. Where required, we implement Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties.


                                INFORMATION SECURITY AND ACCURACY

                                We intend to protect your personal information and to maintain its accuracy. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. We also require that our suppliers protect such information from unauthorized access, use and disclosure.


                                RETENTION PERIOD

                                We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.

                                Because the circumstances may vary depending on the context and the services, the information provided in Online Privacy Statement or provided in a specific notice may provide more detailed information on applicable retention terms.

                                In the event that we process your data for marketing purposes, we will delete your data if we have not received any responses to our marketing activities for a period of three years. The deletion will occur within six months of such three-year period elapsing.


                                HOW TO CONTACT US

                                If you have a question related to this Privacy Notice, please contact us by sending an email to Privacy@Kornferry.com. Your message should include our company name (so that we can identify which TwentyEighty company you are contacting us about) and will be forwarded to the appropriate member of our legal or compliance team.

                                For the purposes of the EU General Data Protection Regulation (GDPR), the controller of your personal information is AchieveForum ,Inc., Attn: Data Privacy Officer, 10901 W. Toller Drive, Suite 202, Littleton, Colorado 80127, United States of America.

                                AchieveForum, Inc. is not the controller in situations such as personal information processed in connection with a contractual relationship. In this case the controller of personal information is company with which we have contracted (such as your employer) unless otherwise agreed in that contract.


                                YOUR RIGHTS

                                You can request to access, update or correct your personal information. You also have the right to object to direct marketing. To make such a request or lodge such an objection, please send an email to Privacy@Kornferry.com. Please specify our company name (so that we know which company you are contacting us about) and provide details of your request. We will contact you if we need more information to process your request.

                                You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information. You can make these requests by sending an email to Privacy@Kornferry.com, providing the details of your request.


                                If you are a California resident, you may request that we:

                                • Disclose to you the following information covering the 12 months preceding your request:

                                  • The categories of personal information we collected about you and the categories of sources from which we collected such personal information;

                                  • The specific pieces of personal information we collected about you;

                                  • The business or commercial purpose for collecting (if applicable) personal information about you; and

                                  • The categories of personal information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such personal information (if applicable).

                                • Delete personal information we collected from you.

                                To make a request for the disclosures or deletion described above, please contact us at Privacy@Kornferry.com or toll-free at 888-508-CCPA (1-888-508-2272). We will respond to your request consistent with applicable law.

                                You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.


                                RIGHT TO LODGE A COMPLAINT

                                In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint directly with us by sending an email to Privacy@Kornferry.com and providing specific details of the complaint, including the name of the company to which it pertains. You may also be eligible to lodge a complaint with the competent data protection authority. The names and contact details of the Data Protection Authorities in the European Union can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm .



                                We are concerned about the privacy of young children and do not knowingly collect any personal information from a child under the age of 13. If we learn that we have personal information on a child under the age of 13, we will delete that information from our records and systems.


                                We employ procedural and technical measures that are designed to help protect your personal information from loss, unauthorized access, disclosure, alteration or destruction. However, we cannot guarantee that third parties will not overcome any such measures and gain access to your information for unauthorized purposes. By using the website, you accept the risk that compromise of and unauthorized access to your information is possible. To the fullest extent permitted by law, we disclaim any warranty or guarantee that your information will be protected from misuse, appropriation, alteration, or loss.

                                All data submitted in our online store (if any) is submitted using secure transport technologies to provide you with the utmost in protection for your private information.

                                OTHER INFORMATION


                                This website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.

                                Disclosure of Information

                                We may disclose or access customer information when we believe in good faith that the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation or civil or administrative authorities in connection with a pending civil case or administrative investigation.

                                Terms of Use

                                The content on this website is copyrighted material owned by us. It is provided for your general information and use only, and is subject to change without notice. We reserve all rights with respect to the website, including without limitation, copyright and intellectual property rights.

                                The website is provided on an “as is” basis. We make no representations or warranties of any kind, express or implied, with respect to the accuracy, completeness, suitability, timeliness, availability or reliability of the website or the information or materials found or offered on the site. We disclaim all implied warranties, including without limitation, warranties of merchantability, fitness for a particular purpose, accuracy of data and non-infringement.

                                Neither we nor any of our affiliated companies, directors, officers, employees, partners, or owners shall be liable for any loss or damage whatsoever related to the use of this website.

                                Any claim or cause of action arising out of or related to the use of the website shall be governed by the laws of the State of Delaware regardless of where the website was accessed or the country of origin of the claimant.


                                QUESTIONS ABOUT THE PRIVACY POLICY

                                If you have any questions or complaints about this privacy policy, the practices of this site or your interactions with this site, please contact:

                                Attn: Data Privacy Officer

                                370 Interlocken Boulevard, Suite 600

                                Broomfield, Colorado 80021


                                +1 303 945-8000


                                CHANGES TO THIS PRIVACY POLICY

                                We reserve the right to update or modify this policy at any time.


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