- Safe Harbor Compliance
- Information we collect about you
- Where we store data
- How we use your information
- Disclosure of your information
- Updating, correcting, or deleting your personally identifiable information
- Choices regarding control of your personally identifiable information
- Information related to data collected through the Gemba Academy platform service
- Data Security
- Links to third party web sites and advertisers
- Notice to California residents
- Communities, forums, chat rooms, and message boards
- Social Media features
- How do you contact us with questions?
1. SAFE HARBOR COMPLIANCE
We self-certify compliance with the following: the U.S. – E.U. Safe Harbor Framework and U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. Gemba Academy has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the Gemba Academy certification, please visit http://www.export.gov/safeharbor.
Our Safe Harbor Policy Statement is here.
2. INFORMATION WE COLLECT ABOUT YOU
We collect several types of information about visitors and/or users of our Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Websites.
(a) Personally Identifiable Information. ‘Personally Identifiable Information’ refers to information by which you may be personally identified, such as your name, email address, or company. We will collect and process such data about you when you register for a Service/create an account, subscribe to a newsletter, submit feedback, fill out a survey, or send us a communication. When ordering products or services on the Websites, you may also be asked to provide a credit card number and other payment-related information. You may also provide information to be published or displayed (“posted”) on public areas of the Websites (such as blogs, forums, message boards, and the like), or transmitted to other users of the Websites using ‘sharing’ features (collectively, “User Contributions”). Your User Contributions are posted and transmitted to others at your own risk. We cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
We may also collect your Internet Protocol (‘IP’) address. We use your IP address to diagnose problems with our servers, software, to administer our Services and to gather demographic information.
We do not collect more Personally Identifiable Information than is reasonably necessary to participate in an activity on the Websites. If you use a Gemba Academy service within the United States for children under the age of 13, you are responsible for obtaining consent from the parents/legal guardians of each child you wish to allow to participate in using any of our Services.
(b) Non-Personally Identifiable Information. We may collect, or our third party ad server and/or content server may collect, certain Non-Personally Identifiable Information, that does not by itself identify a specific individual. Such information tells us about your equipment, browsing actions, the resources that you access and use through the Services, your operating system and browser type. Our third party ad servers will provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon at our Websites. The information that we collect automatically is ‘statistical’ in nature. It helps us to deliver a better and more personalized service to users, by enabling us to estimate usage patterns, customize our Services according to your individual preferences, and speed up your searches.
(c) Device Information. When you use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best application version to provide you with. We do not ask you for, access or track any location based information from your mobile device at any time while using our Services.
3. WHERE WE STORE DATA
4. HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
- To ensure that content from our Services is presented in the most effective manner for you and for your computer or mobile device
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
- To carry out our obligations arising from any contracts entered into between you and us, including for billing and collection
- If you pay for Services using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company
- To allow you to participate in interactive features of our Services, when you choose to do so
- To notify you about changes to our Services
- In any other way we may describe when you provide the information
If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale to you.
If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
If you use the Contact Us form on our site, we will respond to your inquiry and delete the information provided after your request has been fulfilled.
5. DISCLOSURE OF YOUR INFORMATION
We do not sell, trade, rent or disclose your information to others, except as provided herein:
(a) We provide some of our Services through contractual arrangements with service providers and other third parties. We and our service partners use your Personally Identifiable Information to operate our Websites and to deliver Services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Websites; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us deliver the services.
(c) In the event that Gemba Academy decides to sell all or part of its stock or assets or enter into a merger, we reserve the right to include Personally Identifiable Information and Non-Personally Identifiable Information among the assets transferred to the acquiring or surviving company.
(d) We may provide Non-Personally Identifiable Information about our customers’ sales, traffic patterns, and related Website information to third party advertisers.
(e) Parents are able to consent to the use of their child’s Personally Identifiable Information without having to consent to the Website’s disclosure of the child’s Personally Identifiable Information to third parties, as we do not share Personally Identifiable Information of children under the age of 13 with any third parties (other than those service partners who help us provide the Gemba Academy service to you).
6. UPDATING, CORRECTING, OR DELETING YOUR PERSONALLY IDENTIFYING INFORMATION
You may change any of your Personally Identifiable Information online by contacting us.
You may also access, request deletion, and correct your personal information and privacy preferences by contacting us.
Please include your name, address, and e-mail address when you contact us. We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed and request that we no longer have contact with you; however, because we keep track of past transactions for as long as is reasonably necessary, you cannot delete information associated with past transactions on this Website. In addition, it may be impossible to completely delete your information without some residual information because of backups.
7. CHOICES REGARDING CONTROL OF YOUR PERSONALLY IDENTIFIABLE INFORMATION
You can access some of the information that we collect about you. For example, by logging in to your account, you can access information regarding recent orders from the Websites; Personally Identifiable Information; communication preferences; and payment settings.
With respect to your communications preferences, you can unsubscribe from newsletters by following the instructions included in the newsletter you receive. If your e-mail address has changed and you would like to continue to receive newsletters, you will need to access your account and update your e-mail address information in your account and sign-up again for the newsletter. Occasionally we may send out e-mails concerning website disruptions.
We do not send unsolicited commercial e-mails (“spam”). We offer commercial e-mail recipients the opportunity to opt-out of further communications in every e-mail. Please note that we may not include the opt-out information in non-commercial Service e-mails (i.e., e-mails concerning your order, , etc.).
You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Websites may not work properly in your case.
8. INFORMATION RELATED TO DATA COLLECTED THROUGH THE GEMBA ACADEMY ENTERPRISE SERVICES
For certain services Gemba Academy collects information under the direction of its clients (e.g., an entity that subscribes to the Services for use by the entity’s personnel). In this respect, Gemba Academy acts as a data processor and has no direct relationship with the individuals whose Personally Identifiable Information it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the relevant Gemba Academy client. If the client makes a request to us to remove the data, we will respond to their request within 30 days.
Gemba Academy will retain Personally Identifiable Information we process on behalf of our clients for as long as needed to provide our services to our client. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. DATA SECURITY
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology. To make online purchases you must use an SSL-enabled browser in order to protect the confidentiality of your personal and credit card information while it is transmitted over the Internet.
Access by you to your account is available through a password and/or unique user name selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone, that you change your password often using a combination of letters and numbers, and that you ensure you use a secure web browser. We cannot be held accountable for activity that results from your own neglect to safeguard the secrecy of your password and user name. If you share a computer with anyone, you should always log out of your account after you are finished, in order to prevent access to your information from subsequent users of that computer.
Please notify us as soon as possible if your user name or password is compromised.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.
In the unlikely event that we believe that the security of your Personally Identifiable Information in our control may have been compromised, we will notify you as promptly as possible under the circumstances. To the extent we have your e-mail address, we may notify you by e-mail and you consent to our use of e-mail as a means of such notification. If you prefer for us to use another method to notify you in this situation, please contact us.
10. COOKIES AND OTHER TECHNOLOGIES
You can disable and/or delete all types of cookies by using your browser settings. If you do disable cookies, our Websites will not recognize you and you may not have access to all portions of the Websites.
11. LINKS TO THIRD PARTY WEB SITES AND ADVERTISERS
12. NOTICE TO CALIFORNIA RESIDENTS - CALIFORNIA PRIVACY RIGHTS
If you are a California resident and have provided us with Personally Identifiable Information, California law gives you the right to request and receive from us, once per calendar year, information as to how we have shared your Personally Identifiable Information with third parties for their direct marketing purposes If applicable, such information would include a list of names and addresses of all third parties with whom such information was shared during the prior calendar year as well as a list of the categories of Personally Identifiable Information shared. To make such a request, please contact us. Your request must also include your name, physical mailing address and email address. We will respond to you within thirty days of receiving such a request.
Note, that we will not share your Personally Identifiable Information with third parties for their marketing purposes without obtaining your prior consent. Moreover, if you have granted us permission, such third parties’ use of your Personally Identifiable Information will be subject to their privacy policies. You should contact those entities directly regarding any communications you may receive from them, including, if you later decide that you no longer want that third party to use your personal information.
14. COMMUNITIES, FORUMS, CHAT ROOMS, AND MESSAGE BOARDS
If you choose to disclose Personally Identifiable Information on communities, message boards, forums, and the like, which may be accessible via the Websites, you should be aware that such information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. To request removal of your personal information from our blog or community forum, please contact us. You acknowledge and accept that any submissions to chat rooms or other public areas on the Websites are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for all activity conducted by you via communities, forums, message boards, chat rooms, etc. Please be careful and responsible whenever you are online.
15. SOCIAL MEDIA FEATURES
16. HOW DO YOU CONTACT US WITH QUESTIONS?
Gemba Academy LLC
PO Box 1403
Morro Bay, CA 93443
Phone: +1 (888) 439-8880
REVISED: 1 August 2015