Thank you for joining the world’s largest online audit, accounting, corporate finance and related learning platform. We at Illumeo, Inc. (“Illumeo”, “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection policies and describes your rights to access, correct, or restrict our use of your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Illumeo website (in any form, via any device) or related services (the “Services”).

By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

If any of our policies conflicts with applicable law or the policies of a corporate client we will change the policy as needed to conform.

Table of Contents

1. Why Do We Collect Data
2. What Data We Collect
3. How We Get Data About You
4. What We Use Your Data For
5. Who We Share Your Data With
6. Security
7. Your Rights
8. Jurisdiction-Specific Rules
9. Updates & Contact Info
10. Cookie Policy

1. Why Do We Collect Your Data

We collect your data primarily in order to provide you our Services. We simply can’t provide our Services without some fundamental data collection along the way. We also use your data to better understand how our users utilize our Services and to provide additional services. This helps us improve and add to our Services over time. For example, if you take an online assessment on our platform we will use the information to provide you with personalized course suggestions.


Some data is collected because it is needed by your company in a corporate subscriber mode. Illumeo is provided to many users by their companies who wish for them to gain professional development, continuing education credits, and other expertise through this platform. In that process, your manager and their leadership chain, along with any administrators assigned by your company, will have full view of your information and activity on Illumeo in order to better build and execute your professional development.


And yes, we use your data to more effectively communicate with you about our Services. For instance, if you have a job title that indicates you are in accounting we might send you information about accounting courses on our platform. You can always and easily opt out of these communications. We intend to educate, not annoy our users. What we don’t do is sell your data to third parties so that others can market to you. That is simply not our business model. Our intent and desire is that only Illumeo uses Illumeo-collected data for marketing purposes. Any third-party sharing of your data is for provision of Services on our platform. But do note that all of our service providers have their own data use policies which we do not and cannot control.

2. What Data We Collect

We collect certain data from you directly, like information you enter yourself about yourself (e.g. name, job title, company name, etc.), and data about your participation in courses or other elements of our platform, like assessments, your personal development plan and other platform features. We also collect some data automatically, like information about your device and what parts of our Services you interact with.

2.1 Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.

When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:

The data listed above is stored by us and associated with your account.

Illumeo keeps your data forever, unless you request that we destroy it, so that you can always access your learning history. We provide a convenient online storage capability for professional development and many of our users utilize our site as their primary record of their development activities.

Those who access Illumeo via company subscriptions can, should they ever part ways with their company, contact us via phone or email to request a change to their account access email. In this way you can maintain access to your learning history and records. Note that you will not be able to access additional courses unless you purchase a subscription yourself or though a new employer, but your learning and continuing education credit (e.g. CPE, CE, or RCH) history will remain accessible to you and your company will have no visibility to that history once it has been transferred to a new email. You will be required to positively identify yourself in order for us to transfer your account to a new email address.

2.2 Data We Collect through Automated Means

When you access the Services (including browsing courses), we collect certain data by automated means, including:

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.

3. How We Get Data About You

We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

3.1 Cookies and Data Collection Tools

As detailed in our Cookie Policy, Illumeo and service providers acting on our behalf (like Google Analytics and third party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, and web beacons (together, “Data Collection Tools”) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.

We use cookies (small files that websites send to your device to uniquely identify your browser or device or to store data in your browser) for things like analyzing your use of the Services, personalizing your experience, making it easier to log into the Services, and recognizing you when you return. We use web beacons (small objects that allow us to measure the actions of visitors and users using the Services) for things like identifying whether a page was visited, identifying whether an email was opened, and advertising more efficiently by excluding current users from certain promotional messages or identifying the source of a new mobile download.

Illumeo uses the following types of cookies:

• Preferences: cookies that remember data about your browser and preferred settings that affect the appearance and behavior of the Services (like your preferred language) and your login credentials.
• Security: cookies used to enable you to log in and access the Services; protect against fraudulent logins; and help detect and prevent abuse or unauthorized use of your account.
• Functional: cookies that store functional settings (like your preferred certification information).
• Session State: cookies that track your interactions with the Services to help us improve the Services and your browsing experience, remember your login details, and enable processing of your course purchases. These are strictly necessary for the Services to work properly, so if you disable them then certain functionalities will break or be unavailable.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional.

Some of the third-party partners who provide certain features on our site may also use Local Storage Objects (also known as flash cookies or LSOs) to collect and store data.

3.2 Analytics

We use third-party browser and mobile analytics services like Google Analytics and Facebook on the Services. These services provide Data Collection Tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application was accessed from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.

3.3 Online Advertising

We use third-party advertising services like Facebook, Google’s ad services, and other ad networks and ad servers to deliver advertising about our Services on other websites and applications you use. The ads may be based on things we know about you, like your Usage Data and System Data (as detailed above), and things that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services, and may be tailored to your interests.

Depending on the types of advertising services we use, they may place cookies or other tracking technologies on your computer, phone, or other device to collect data about your use of our Services, and may access those tracking technologies in order to serve these tailored advertisements to you. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.

When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.

4. What We Use Your Data For

We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising (for non-corporate clients only), and as required by law.

We use the data we collect through your use of the Services to:

• Provide and administer the Services, including to display customized content and facilitate communication with other users;
• Process your requests and orders for courses, products, specific services, information, or features;
• Communicate with you about your account by:
  
  • Responding to your questions and concerns;
  • Sending you administrative messages and information, including messages from instructors and teaching assistants, notifications about changes to our Service, and updates to our agreements;
  • Sending you information and in-app messages about your progress in courses, rewards programs, new services, new features, promotions, newsletters, and other available courses (which you can opt out of at any time);
• Manage your account preferences;
• Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
• Solicit feedback from users;
• Market and administer surveys and promotions administered or sponsored by Illumeo;
• Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers (for non-corporate clients only);
• Identify unique users across devices;
• Improve our Services and develop new products, services, and features;
• Analyze trends and traffic, track purchases, and track usage data;
• Advertise the Services on our and third-party websites and applications (for non-corporate clients only);
• As required or permitted by law; or
• As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.

5. Who We Share Your Data With

We share certain data about you with instructors, other employees at your company for reporting and management purposes but only if your company provides you your subscription access to the Services, companies performing services for us, our business partners, analytics and data enrichment providers, social media providers (for non-corporate clients only), companies helping us run promotions and surveys, and advertising companies who help us promote our Services (for non-corporate clients only). We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

• With Your Instructors: We share data that we have about you with instructors for courses you enroll in or request information about, so they can respond directly or improve their courses for you and other students. We will not share your email address with instructors unless it is necessary to facilitate requested direct response to you about a course.
• With Your Company If You Are A Corporate Subscriber: Many Illumeo users access Illumeo via a subscription provided by their company. In this case, your company will have visibility to multiple data elements including your name, title, user profile data, your Illumeo Development Plan, activity history including what courses you took and when, test scores and test attempts, "managed" (assigned by your manager - not personal) Competency Assessments, and more. Basically, if it's on this site and related to you, your manager and any assigned company administrators can see it.
• With Other Users and Instructors: Your shared content and profile data may be publicly viewable, including to other users and instructors in certain circumstances. For instance, if you ask a question to an instructor, your information (including your name, title, and company name) will be publicly viewable by other users unless you set your question 'ID' to "Anonymous".
• With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising (for non-corporate clients only)), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
• With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to Illumeo. Depending on your location, we may share your data with these partners.
• With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services, we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 1), aggregated data, or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
• To Power Social Media Features: The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.
• To Administer Promotions and Surveys: we may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.

• For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
  
  • Permitted or required by law;
  • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
  • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
  • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
  • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
  • Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Illumeo, our users, employees, members of the public, or our Services.
  • We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.
• During a Change in Control: If Illumeo undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
• After Aggregation/De-identification: we can disclose or use aggregate or de-identified data for any purpose.
• With Your Permission: with your consent, we may share data to third parties outside the scope of this Privacy Policy.

6. Security

We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.

Illumeo takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Illumeo, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact support@Illumeo.com with any concerns.

7. Your Rights

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and you can also contact us for individual rights requests about your personal data.

7.1 Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

• To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences on your account (In the upper-right select "My Info", then at the top select "Settings"). Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
• The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared.

If you have any questions about your data, our use of it, or your rights, contact us at privacy@Illumeo.com.

7.2 Accessing, Updating, and Deleting Your Personal Data

You can access and update your personal data that Illumeo collects and maintains as follows:

• To update data you provide directly, log into your account and update your account at any time.
• To terminate your account:
  
  • If you are a user, visit your profile settings page and at the bottom-right click on the delete link.
  • If you have any questions about terminating your account, email us at support@Illumeo.com or visit our FAQs.
  • Please note: even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users (including ‘in course’ comments or reviews); (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with continuing education credit management, legal obligations, resolving disputes, and enforcing our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.
• To request to access, correct, or delete your personal data, email privacy@Illumeo.com or write to us at Illumeo, Inc., 75 E Santa Clara St., STE 1215, San Jose, CA 95113. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

8. Jurisdiction-Specific Rules

If you live in California, you have certain rights to request information. Users outside of the United States should note that we transfer data to the US and other areas outside of the European Economic Area.

8.1 Users in California

If you are a California resident, you have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to privacy@Illumeo.com with the phrase “California Shine the Light” and include your mailing address, state of residence, and email address.

Since the internet industry is still working on Do Not Track standards, solutions, and implementations, we do not currently recognize or respond to browser-initiated Do Not Track signals.

8.2 Users Outside of the U.S.

Illumeo, Inc. is headquartered in California, and in order to provide the Services to you we must transfer your data to the United States and process it there. By visiting or using our Services, you consent to storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.

That data is also processed outside of Switzerland and the EEA by Illumeo, or our service providers, including to process transactions, facilitate payments, and provide support services as described above. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Illumeo and its processors.

9. Updates & Contact Info

When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email or postal mail with any questions, concerns, or disputes.

9.1 Modifications to This Privacy Policy

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

9.2 Questions

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team at privacy@Illumeo.com. You can also send postal mail to us at Illumeo Inc., 75 E Santa Clara St., STE 1215, San Jose, CA 95113.

10. Cookie Policy

This Cookie Policy was last updated on May 25, 2018

What are cookies?

Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your activities across websites, including on Illumeo. Cookies also allow us to remember things about your visits to Illumeo, like your preferred language, and to make the site easier to use.

We use both session cookies, which expire after a short time or when you close your browser, and persistent cookies, which remain stored in your browser for a set period of time. We use session cookies to identify you during a single browsing session, like when you log into Illumeo. We use persistent cookies where we need to identify you over a longer period, like to keep you signed in.

Why does Illumeo use cookies and similar technologies?

We use cookies and similar technologies like web beacons, pixel tags, or local shared objects (“flash cookies”), to deliver, measure, and improve our services in various ways. We use these cookies both when you visit our site and Services through a browser and through our mobile app. As we adopt additional technologies, we may also gather additional data through other methods.

We use cookies for the following purposes:

For example, cookies help authenticate your access to Illumeo and prevent unauthorized parties from accessing your accounts.

For example, cookies help us remember your preferred language or the country you’re in, so we can provide content in your preferred language without asking each time you visit.

For example, cookies help us test different versions of Illumeo to see which features or content users prefer, web beacons help us determine which email messages are opened, and cookies help us see how you interact with Illumeo, like the links you click on.

We also work with a number of analytics partners, including Google Analytics, who use cookies and similar technologies to help us analyze how users use the Services, including by noting the sites from which you arrive. Those service providers may either collect that data themselves or we may disclose it to them.

You can opt out of some of these services through tools like the Google Analytics Opt-out Browser Add-on.

For example, cookies help us show a personalized list of recommended courses on the homepage.

To learn more about targeting and advertising cookies and how you can opt out, visit www.allaboutcookies.org/manage-cookies/index.html, or if you’re located in the European Union, visit the Your Online Choices site.

Please note that where advertising technology is integrated into the Services, you may still receive advertising on other websites and applications, but it will not be tailored to your interests.

When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide its own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.

What are my privacy options?

You have a number of options to control or limit how we and our partners use cookies:

• Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by consulting your browser’s support articles. If you decide to decline cookies, please note that you may not be able to sign in, customize, or use some interactive features in the Services.
• To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Union, visit the Your Online Choices site. To opt out of Google Analytics’ display advertising or customize Google Display Network ads, visit the Google Ads Settings page.
• For general information about targeting cookies and how to disable them, visit www.allaboutcookies.org.

Updates & Contact Info

From time to time, we may update this Cookie Policy. If we do, we’ll notify you by posting the policy on our site with a new effective date. If we make any material changes, we’ll take reasonable steps to notify you in advance of the planned change.

If you have any questions about our use of cookies, please email us at privacy@Illumeo.com.