1. COLLECTION OF INFORMATION
A. Purpose. The information we learn from customers allows us to personalize and continually improve the total experience at NCTI’s web sites. We may gather types of information like, but not limited to, those listed below.
a. Contact Information that allows us to communicate with you — including your name, address, telephone number, and e-mail addresses. This information was collected directly from consumers in order to identify and locate the consumers;
b. Billing information related to your financial relationship with us — including your payment data and service history. This information was collected directly from consumers and by us observing your activities and recording the information. It was collected to allow us to bill consumers;
c. Equipment, Performance, NCTI Web Site Usage, Viewing and other Technical Information about your use of our services, products, or web sites. This information was collected by us observing your activities and recording the information, and was collected to allow us to improve our service to meet consumer preferences; and
d. Professional information and educational information. This information was collected directly from consumers and is a by-product of our efforts to understand who our customers are and how to market our services to those customers.
C. Ways in which we collect information.
a. You give information to us when you create an account, purchase or interact with us about a product or service we offer or provide; and
b. We collect information automatically when you visit our web sites or use our products and services;
c. If you are using NCTI’s probation-related testing services, we collect information related to what you learned from the course materials, your name, and your case number;
d. If you are using the Real Colors Online Testing Instrument (a/k/a the Real Colors Personality Test or Real Colors Assessment), we collect your name, e-mail address, and your test answers and results.
2. INFORMATION USE
A. General. Information is collected from you when you perform the activities like those explained above.
B. Use of collected information. We may use the information we collect in a variety of ways, including to:
a. Provide you with the best customer experience possible;
b. Provide the services you purchase, and to respond to your questions;
c. Communicate with you regarding service updates, offers, and promotions;
d. Deliver customized content and advertising that may be of interest to you;
f. Provide online Activity Tracking and Advertising;
g. If you are using NCTI’s probation-related testing services, we provide access to government employees to review your testing results and input;
h. If you are using the Real Colors Online Testing Instrument (a/k/a the Real Colors Personality Test or Real Colors Assessment), we use the information we collect to score your test and make that information available to your facilitator for presentation to you at your class. After you complete the class, the information is stored by us for you to log in and access tools, print your certificate, and otherwise review the test results.
C. Past Disclosure to Affiliates. We and our non-NCTI partners (CRCB, Inc. and Real Colors Holding, Inc., as well as any other entities that are under common ownership with NCTI, or other entities that become part of that group (“Affiliates”)) have over the past twelve months used the personal information described in Section 1B above, as well as other non-personal information they have or we may have, to help draft emails to customers offering additional goods and services and to help us make other marketing decisions.
D. Prior Usage. The personal information described in Section 1B above has been collected for the previous twelve months to maintain and service accounts, provide customer service, process orders, verify customer information, process payments, provide advertising, and provide analytic services.
3. SHARING OF INFORMATION
A. General. The information that we collect about our customers is critical to our business. We respect and value this information, and do not want to jeopardize the flow of information between our customers and the site.
B. Between NCTI and Affiliated Entities. We have in the past twelve months, and may in the future share, the information we collect from you described in Section 1B above with our Affiliates. Affiliates may use information we collect to help provide, understand, and improve the services we provide, as well as improve and advertise their own services. If you do not wish for your personal information to be provided to our Affiliates, please click on the following link [DO NOT SELL MY PERSONAL INFORMATION] and opt out of having your personal information provided to the Affiliates. We will not discriminate against customers who choose to opt out of having their personal information shared with our Affiliates. The link [DO NOT SELL MY PERSONAL INFORMATION] may also be found on the footer of our website home page.
C. With Non-Affiliate Companies. We may share your personal information described in Section 1B above with non-Affiliate companies that perform services on our behalf that are necessary to allow us to provide our services to you. We may share your private personal information with such companies subject to confidentiality obligations consistent with this Privacy Notice. The services performed by the non-NCTI third parties are necessary to maintain and service accounts, provide customer service, process orders, verify customer information, process payments, provide advertising, and provide analytic services.
D. Special Note Re The Real Colors Online Testing Instrument (a/k/a the Real Colors Personality Test or Real Colors Assessment). If you take the Real Colors Online Testing Instrument you will have your name and test results reviewed by a third party certified facilitator. Moreover, your name and test results will be stored forever by NCTI or until NCTI decides to no longer store the information in its sole discretion. NCTI stores this information for a long time because it is useful to you for a long time. If you are a member of a company or organization that has contracted with NCTI to provide the Online Testing Instrument, that company or organization will also have access to your name and test results for as long as that information is stored by NCTI and may be used by the company or organization for any purpose. This will be true even if you choose not to obtain your test results or leave the company or organization.
E. In Other Circumstances. We may provide personal information to non-Affiliate companies or other third parties for purposes such as, but not limited to:
a. Complying with court orders and other legal process;
b. Enforcing our agreements and property rights; and
c. Obtaining payment for our products and services, including the transfer or sale of delinquent accounts to third parties for collection.
F. Aggregate or Anonymous Information. We may share aggregate or anonymous information in various formats with trusted non-Affiliate entities for purposes such as, but not limited to:
a. Retail, marketing and advertising companies that offer products and services that may be of interest to you;
b. Universities, laboratories and other entities that conduct scientific research; and
c. Media research companies and entities that may use the data for purposes such as municipal planning and coordinating disaster responses.
G. Our Use of Google Analytics. We use Google Analytics Advertising Features, including Google Analytics Demographics and Interest Reporting, and other services that collect data via Google advertising cookies and identifiers. Google Analytics sets cookies to identify unique users, identify unique sessions, throttle the request rate and store information about user sessions and campaigns. Google Analytics sets first-party cookies, which we use internally to view our site’s visitor demographics and to view the visitors’ journey. We also use Share This, which sets first-party cookies and allows visitors to share our content to social media if they wish.
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. You can opt out of the Google Analytics Advertising Features you use, including through Ads Settings, Ad Settings for mobile apps, or any other available means such as the NAI’s consumer opt-out. Google Analytics’ currently available opt-outs for the web are located at https://tools.google.com/dlpage/gaoptout/. Be advised, however, that some aspects of the site may not function properly if you elect to disable cookies.
4. INFORMATION SECURITY
A. Software Used. To protect the security of your information during transmission, we encrypt the personal information you input.
B. Order Confirmation. We reveal only the last four digits of your credit card numbers when confirming an order. Your credit card information is not stored on NCTI’s web sites, but is encrypted and transmitted in full to the appropriate credit card company.
C. Signing off. To prevent unauthorized access to sensitive information, it is important for you to monitor those who have access to your password and to your computer. Be sure to sign off when finished using a shared computer.
D. Business records. We maintain information about you in our business records while you are a customer, or until it is no longer needed for business, tax, or legal purposes.
5. AUTOMATIC INFORMATION
A. General. As discussed earlier, our systems collect information that is sent over the internet without your control.
B. Examples. Some examples of the information we may collect and analyze include the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information such as browser type and version, operating system, and platform; purchase history; the full Uniform Resource Locator (URL) click-stream to, through, and from our web site, including date and time; cookie number; products you viewed or searched for; and the phone number you used to call our toll-free number.
C. Software Used. During some visits we may use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
6. USER ACCESS TO INFORMATION
A. General. Some of the information that we collect and process related to you can be accessed by you.
B. Accessible Information. Examples of information you can access easily at our web sites include up-to-date information regarding recent orders and personally identifiable information (including name, e-mail, password, and address book). However, credit card information is not stored in customer profiles and must be entered with each purchase. If you are using the Real Colors Online Testing Instrument (a/k/a the Real Colors Personality Test or Real Colors Assessment), after you complete the class your information is stored by us for you to log in and access tools, print your certificate, and otherwise review and use the test results.
C. Changing Or Deleting Your Information. You have the right to change or delete the information and view the information that you entered previously. This information is sensitive, and it is necessary to both protect this information and keep it current in order to have the best experience at our site. You also have the right to restrict the processing or use of your information and you have the right to have your information moved (to the extent technically possible) to another party. To review, change or delete the information you entered previously, to request a processing restriction, or to move information, please send an e-mail to email@example.com, Attn: Privacy Compliance Officer. Please include your name, address, and e-mail address when you contact us. You may also call us at (800) 535-6366 or visit our account settings page at http://www.realcolors.org/account-information. You may only request your personal information twice in a 12-month period and we will need to collect information from you to verify your identity. We will respond within 45 days of receiving a personal information request.
7. USER CHOICES WITH REGARD TO ACCESS OF INFORMATION
A. General. You have the right to refrain from providing any information. However, this may have an impact on use of the site and on the ease of making purchases or taking advantage of certain unique features of the site.
C. Cookie Choices. The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, affecting the acceptance of cookies means that you will not be able to use certain web site features.
General. Our web sites and services are not directed to persons under 13. If you become aware that your child has provided us with personal information without your consent, please contact us at firstname.lastname@example.org. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child’s account.
9. CONDITIONS OF USE, NOTICES, AND REVISIONS
C. Applicability. Our current Privacy Notice applies to all information that we have about you and your account.
10. YOUR PRIVACY RIGHTS
Customers have the right to request information concerning whether NCTI has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Any customer who wishes to request further information about our compliance with applicable law concerning this Notice or have questions or concerns about our privacy practices and policies may contact us at email@example.com.