Deque University Privacy Policy

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Privacy Policy for California Residents

Effective Date: July 17, 2020

1. Introduction

Deque University (“DequeU” “we” or “us”) is an online training platform that focuses on digital accessibility. We work predominantly with companies that want to provide our training services and offerings to their employees. However, there are some cases where consumers enroll in our courses in their private capacity.

Deque University adopts this privacy policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA that have the same meaning when used in this policy.

This CCPA Privacy Policy provides information that applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). In particular, this Policy applies to your use of our Services and Site (www.dequeuniversity.com), and covers information collected in connection with your access to and use of our services and Site.

2. Categories of Personal Information Collected

We collect information that identifies or is reasonably capable of being associated with you or your device (“personal information” or “PI”).

Note that Personal information does not include publicly available information from government records, or deidentified or aggregated consumer information.

In the table below we provide the list of categories of PI that DequeU has collected within the last twelve (12) months and some examples for a better understanding.

Categories of Personal	Examples
A. Personal Identifiers.	This may include a real name, online identifier, Internet Protocol address, email address, account name, username, or other similar identifiers
B. Personal Records	This may include name, telephone number (optional), address (optional), employment. Note that Deque University does not store information such as bank account number, credit card number or financial information. The information is directly processed and stored on the servers of a third-party payment provider.
C. Protected classification characteristics under California or federal law.	In some instances, Deque provides free access courses for people with disabilities. For this reason, in exceptional circumstances we may receive information related to these types of protected characteristics. However, we minimize the PI collected and stored in this context.
D. Commercial information.	This may include products or services purchased, obtained, or considered, or other purchasing histories or tendencies, affiliation with company and courses completed.
E. Internet usage or another similar network activity	This may include information on a consumer's interaction with our website, page views, quiz responses, interaction with advertisements or course completion.
F. Geolocation data	Deque only collects IP addresses and high-level information on location based on Google analytics (country level). This information is only used for security purposes and statistics, it is not used for direct marketing.
G. Professional or employment related information.	This may include employment related information such job title and role.
H. Inferences drawn from other personal information.	This may include profile reflecting a person's preferences, behaviour, characteristics, or predisposition.

3. Sources of Personal Information

Directly from you. When you visit our Site, log-in as a registered user, as well as through correspondence, emails, telephone inquiries, web forms, and other means of communication.

When your employer enrolls you into our courses, they will provide us with your business email address and contact information to facilitate access to the platform.

Indirectly from you. When you navigate and interact with our Site, some information is automatically collected by cookies and similar technologies. For more information about the cookies we use, see our Cookie Policy.

4. How We Use Your Personal Information

DequeU use the Personal Information collected for the following purposes:

Performing Customer Service, Processing and Managing Interactions:

Providing you with the Deque products and features you choose to use
Processing or recording payment transactions
Displaying your historical transaction information
Delivering the information and support you request
Fulfilling any other purpose disclosed to you in connection with our Services

Security and Debugging:

Creating, maintaining, and securing your account with us
Maintaining the security, and integrity of our Website, products and services
Verifying your identity

Quality Assurance, Improving and Developing Our Services:

Improving our services and developing new products and Services
Conducting surveys and collecting feedback about our industry and services

Analytics

Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services
Reviewing and analyzing user browser and wireless device technical information
Tracking course progress and completion rates

Advertising and Marketing

Marketing of our Services, events, research and products;
If we send you marketing emails, each email will contain instructions permitting you to “opt-out” or unsubscribe of receiving future marketing or other communications; and
If we obtain any personal information from you we will not sell it to third-parties.

Compliance With Regulatory Requirements:

Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process
Evaluating the information as part of a merger, restructuring operation or as part of bankruptcy or similar proceeding, according to applicable law
Enforcing our Terms of Service or other applicable agreements or policies

5. Disclosures to third parties

DequeU does not sell Personal Information from California consumers.

At times, DequeU engages service providers, and other qualified vendors for the same business purposes for which we collect such Personal Information as described in the previous section, to that end a contractual agreement is signed with each vendor to restrict the use of your Personal Information.

In the description below we provide categories of Personal Information that DequeU has disclosed to our service providers within the last 12 months for business purposes.

Categories of Personal Information Collected	Categories of service providers with whom PI has been shared for business purposes
A. Personal Identifiers.	Internet Service Providers (ISP) Information security and audit Software and IT providers Sales/marketing Analytics and advertising providers
B. Personal Records	Internet Service Providers (ISP) Information security and audit Software and IT providers Sales/marketing Analytics and advertising providers
C. Protected classification characteristics under California or federal law	N/A, internal only
D. Commercial information.	Software and IT providers Sales/marketing Analytics and advertising providers
E. Internet or another similar network activity	Analytics and advertising providers
F. Geolocation data	Analytics and advertising providers
G. Professional or employment related information.	Software and IT providers Internal marketing teams
H. Inferences drawn from other personal information.	Analytics and advertising providers

In certain circumstances, DequeU may disclose your Personal Information when authorized by law, public authorities, courts or law enforcement, or when required to protect our legal rights. For example, as part of a merger, acquisition, bankruptcy, or other transaction in which a third party takes control of all or some parts of our business.

6. Our Policy Towards Children

DequeU does not knowingly collect Personal Information directly from minors and does not sell Personal Information from minors. Any information we collect from minors is always with the consent of a parent or guardian. If you are under 16 years old, do not use or provide any information on our Website or on or through our services.

7. Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. Note that DequeU does not sell Personal Information from California consumers.

This section describes the CCPA rights to know and to delete and explains how to exercise those rights. We will not discriminate against you for exercising your CCPA rights.

A. Right to Know

You may have the right to send us a request, no more than twice in a 12-month period, for any of the following:

The categories of personal information (PI) we collect about you
The categories of sources for the PI we collect about you
Our business or commercial purposes for collecting that PI
The categories of third parties with whom we share that PI, and categories of PI that each recipient received
The specific pieces of PI we collect about you

B. Right to Delete

You have the right to request that a company delete any of your Personal Information that it has collected from you and retained, subject to certain exceptions.

For example, we may deny your deletion request if retaining the information is necessary for us to complete the transaction or service that you requested, detect security incidents or enable internal uses that are reasonable aligned with your expectations.

C. How to Exercise your California Privacy Rights

Mechanisms to submit Requests to Know and to Delete: To exercise the right to know and the right to delete, please submit a verifiable consumer request to us by either:

Completing an Online form on our website, at https://accessibility.deque.com/data-request-form
Sending us an email at: privacyinquiry@deque.co m
Calling us at 1-703-225-0380

Please, describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Process: Once the initial identification and verification process is complete, we will send you an acknowledgement of receipt within 10 days from receiving your request and a reference number.

Any request that you submit to us is subject to an identification process to verify your identity or authority to make the request.

Time period: We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you in writing.

Designating an authorized agent: To exercise any of these privacy rights you can also designate another person to act on your behalf. In this case, we will need this person to provide us with a written authorization (such as a Power of Attorney).

Fees: We will typically not charge a fee to fully respond to your requests. However, if we determine that the request warrants a fee according to the CCPA, we will tell you why and a cost estimate before completing your request.

To obtain this information in an alternative format: If you require this notice to be provided in a different format, please contact us at: privacyinquiry@deque.com

8. Changes to Our Privacy Policy

This International Policy may be revised from time to time as we add new features and Services, as laws change and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change.

9. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which DequeU collects and uses your PI, please feel free to contact us at: privacyinquiry@deque.com.

Privacy Notice for EEA/UK Residents

Effective Date: July 17, 2020

1. Introduction

Deque University (“DequeU” “we” or “us”) is an online training platform that focuses on digital accessibility. We work predominantly with companies that want to provide our training services and offerings to their employees. However, there are some cases where individuals enroll in our courses in their private capacity.

Deque University adopts this notice to comply with the General Data Protection Regulation (“GDPR”) and any terms defined in the GDPR that have the same meaning when used in this notice.

This Notice applies solely to all visitors, users, and others who reside in the European territory, including the European Economic Area, Switzerland and the United Kingdom (“you”). In particular, the Notice applies to your use of our Services and Site (www.dequeuniversity.com).

You can find our contact details in the last section of this notice.

2. Categories of Personal Data Collected

We recognize personal data or personal information as any information related to an identified or identifiable individual.

In the table below we provide the list of categories of personal data that DequeU collects from you, as well as some examples for a better understanding.

Categories of Personal Data	Examples
Personal Identifiers	This may include a real name, online identifier, Internet Protocol address, unique personal identifier, email address, postal address, account name, username, or other similar identifiers.
Personal Records	This may include name, telephone number (optional), address (optional). Note that Deque University does not store information such as bank account number, credit card number or financial information. The information is directly processed and stored on the servers of a third-party payment provider.
Protected classification characteristics	Our scholarship application form allows free access for people with disabilities and therefore, we may capture information about disabilities in this context.
Commercial information	This may include products or services purchased, obtained, or considered, or other purchasing histories or tendencies, affiliation with company and courses completed.
Internet usage or another similar network activity	This may include information on a consumer's interaction with an advertisement, our website or course completion.
Geolocation data	Deque only collects IP addresses and high-level information on location data (country level). This information is only used for security purposes, to track course completion and analytics.
Professional or employment related information	This may include employment related information such as company affiliation and role.
Inferences drawn from other personal information	This may include information reflecting a person's preferences, for example, language (English vs other languages), visual layout and other related things that could enhance the user experience.

3. Sources of Personal Information

Directly from you

When you establish a commercial relationship with us
When you visit our Site, log-in as a registered user
Through correspondence, emails, telephone inquiries, web forms, and other means of communication.

Indirectly from you

When you navigate and interact with our Site, some information is automatically collected by cookies and similar technologies. For more information about the cookies we use, see our Cookie Policy.

Corporate clients

From corporate clients, when they set up an account on behalf of their employees

4. How We Use Your Personal Information and legal basis

DequeU uses Personal data collected for the following purposes:

Purpose	Description of purpose	Legal basis
Performing Customer Service, Processing and Managing Interactions	Enforcing our Terms of Service or other applicable agreements or policies Providing you with the Deque products and features you choose to use Processing or recording payment transactions Performing customer service	Performance of a contract
Responding to your requests	Delivering the information and support you request	Legitimate interest in providing you with the support and information requested
Security and Debugging	Creating, maintaining, and securing your account with us Maintaining the security, and integrity of our Website, products and services Verifying your identity	Legitimate interest in ensuring the security of our platform and users’ information
Quality Assurance, Improving and Developing Our Services	Improving our services and developing new products and Services Displaying your historical transaction information	Legitimate interest in improving our services and developing new products
Marketing	Conducting surveys and collecting feedback about our industry and services Marketing of our Services, events, and products;	Consent
Analytics	Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services Tracking course progress and completion rates	Legitimate interest
Compliance With Regulatory Requirements	Complying with any applicable laws or regulations Responding to lawful requests for information from the government or through legal process Evaluating the information as part of a merger, restructuring operation or as part of bankruptcy or similar proceeding	Compliance with laws and legitimate interest in defending DequeU’s rights
Provide free access to people with disabilities	Deque provides free access to their courses for people with disabilities. For this reason, we may receive information related to these types of requests	Explicit consent

5. Disclosures to third parties

At times, DequeU engages third party contractors, and vendors to help us accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.

Our service providers are mainly based in the United States, and include:

Internet Service Providers (ISP)
Information security and audit
Software application organizations, email and hosting services
System development and maintenance organizations
Sales/marketing
Analytics and advertising providers
Customer services and support
Payment service provider
Order fulfillment organizations

If the engagement involves the transmission of personal data, we require the service provider to treat that data consistent with this Policy. A contract to protect the personal data should be executed before any data is disclosed.

In certain circumstances, DequeU may disclose your personal data when authorized by law, public authorities, courts or law enforcement, or when required to protect our legal rights. For example, as part of a merger, acquisition, bankruptcy, or other transaction in which a third party takes control of all or some parts of our business.

We also may partner with another organization to host an event or webinar together. In this case, we will provide you with a separate privacy notice explaining how we will collect and use your information.

6. International Transfers of Personal Data

If you are located outside the United States and you interact with our website or provide us personal data, then your personal data may be transferred to the United States or to other countries.

If you are located outside the United States and you interact with our website or provide us personal data, then your personal data may be transferred to the United States. In addition, some of our customer support services are provided from our office in India. If you are based in the EU, please be informed that these countries are not in the list of territories that the European Commission considers adequate to the protection of personal data. However, we provide appropriate safeguards for your data in the US and other countries which may include mechanisms such as Standard Contractual Clauses and other contractual assurances related to the privacy, security and individual rights related to personal data.

7. Our Policy Towards Children

DequeU does not knowingly collect Personal Information directly from minors. Any information we collect from minors is always with the consent of a parent or guardian. If you are under 16 years old, do not use or provide any information on our Website or on or through our services.

8. Your EU Rights and Choices

If you reside or otherwise find yourself in the territory of Europe, DequeU is committed to facilitate the exercise of your rights granted by the European data protection law. Otherwise you can contact us at any time to discuss your privacy concerns.

Privacy Rights under the European Regulation:

Transparency and the right to information: we provide notice to our clients, users, vendors and others of how we use personal data in our day-to-day operations at the time of collecting personal data, or as soon thereafter as possible. We also publish this privacy notice for a greater transparency.
Right to access, rectification, restriction of processing, and erasure: we provide you with access to your own personal data where required by applicable law. In addition, we will rectify their personal data when it is incorrect and inaccurate, and we will ensure the right to erasure and to restriction of processing when these rights are not compatible with local regulations.
Right to object: for all marketing materials, you can opt-out anytime, and free of charge. The right to object for other processing activities will be balanced in order to ensure that it is not incompatible with local regulations or the legitimate interests of DequeU.
Right to withdraw consent: when we obtain information based on consent, you can withdraw it at any time, and free of charge.
Right to data portability: based on your specific situation, we provide data subjects with the right to obtain and reuse your data across different services and includes transferring of your data to you, another controller or a trusted third party.
Right to lodge a complaint with a supervisory authority

How to Exercise Your EU Privacy Rights:

You should send a communication in writing to privacyinquiry@deque.com and provide the following information in order to verify your identity: email associated with your account or at which we have contacted you, name, and information about your interaction with our products or teams such as recent courses completed or date when we last contacted you. We may ask for additional information in order to verify your identify. We will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.

If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority of your habitual residence, place of work or place of the alleged

9. Data Retention

We may keep a record of your personal data, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. When personal data is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies. We store information related to course progress and completion indefinitely because our former customers may require access to their records in order to provide proof of continuing education credits. Former customers may request deletion of this data by sending a request to privacyinquiry@deque.com.

10. Security

DequeU is committed to the security, confidentiality and integrity principle. We take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorized access and use and we periodically review our security measures

We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. We leverage industry standards such as those provided by the National Institute of Standards and Technology (NIST). These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances, and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of encryption.

11. Changes to Our Privacy Policy

We reserve the right to modify this Privacy Statement and related business practices at any time. We will duly inform you of any changes.

12. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which DequeU collects and uses your PI, please feel free to contact us at:

Deque Systems, Inc.
381 Elden Street Ste 2000
Herndon, VA 20170

privacyinquiry@deque.com

Cookies Policy

I.Introduction

This cookies policy describes the information that Deque University (“DequeU”, “we”) collect automatically when you visit our Web Site, applications, or receive e-mails for marketing purposes, how we use it, and what are your choices. This policy complements our Privacy Policy

II.Information Collected Automatically and Purposes

When you visit our Web Site, applications or receive e-mails from DequeU, we automatically collect certain information about your activities or interactions ("Online Usage Information"), for example, the number and frequency of visitors to each website, the length of their stays, the URL of the website that the visitor came from, the type of browser and operating system each visitor is using, or what was clicked on our Website, applications or e-mails.

In the table below, we provide the list of cookies and similar technologies that we use to collect online usage information via our website, applications, or e-mails.

Cookie name	Service	Purpose	Expiration date
__cfduid	Hubspot	This cookie ensures that all HubSpot features and functionality are added to the site correctly.	1 year and 1 day
_ga	Google Analytics	This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.	2 years
_gat	Google Analytics	This cookie is used to throttle the request rate – limiting the collection of data on high traffic sites.	10 minutes
_gid	Google Analytics	Like _ga, this cookie is used to site users.	24 hours
__hstc	Hubspot	This cookie is used for website analytics.	2 years
__hssc	Hubspot	This cookie is used for website analytics.	2 days
__hssrc	Hubspot	This cookie is used for website analytics.	2 days
hubspotutk	Hubspot	This cookie is used for user authentication.	9 years and 363 days
SID	YouTube/Google	This cookie is used by Google in combination with HSID to verify a Google user account and most recent login time.	Expiry date varies for these, from end of session up to two years.
HSID	YouTube/Google	This cookie is used by Google in combination with SID to verify Google user account and most recent login time	Expiry date varies for these, from end of session up to two years.
demographics	YouTube/Google	This cookie is most likely used for demographic profiling and targeting for advertising.	Expiry date varies for these, from end of session up to two years.
VISITOR_INFO1_LIVE	YouTube/Google	This cookie is used as a unique identifier to track viewing of videos.	8 months
APISID	YouTube/Google	This cookie is used to identify browsers, devices, and generate ads based on visitor interests.	Expiry date varies for these, from end of session up to two years.
lang	Twitter	Where twitter acts as a third-party host, it collects data through a range of plug-ins and integrations, that is primarily used for tracking and targeting. Twitter does not currently provide information on the use of specific cookies.	Session
LOGIN_INFO	YouTube/Google	This cookie is used to play YouTube videos embedded on the website	1 year
NID	Google Inc.	This cookie contains a unique Google ID used to remember your preferences and other information such as languages, number of results per page, and whether you wish to have SafeSearch enabled.	Expiry date varies for these, from end of session up to two years.
lang	Twitter	Where twitter acts as a third-party host, it collects data through a range of plug-ins and integrations, that is primarily used for tracking and targeting.	Session
GPS	YouTube/Google	Registers a unique ID on mobile devices to enable tracking based on geographical location.	Session
SSID	YouTube/Google	*Recommend to combine with APISID	Expiry date varies for these, from end of session up to two years.
IDE	Doubleclick (Google)	Used to show personalized advertisements based on previous visits.	2 months
YSC	YouTube/Google	Used to collect visitor information and adjusted preferred settings	Session
SAPISID	YouTube/Google	*Recommend to combine with APISID	Expiry date varies for these, from end of session up to two years.
UserMatchHistory	LinkedIn	LinkedIn Ads ID syncing	30 days
li_sugr	LinkedIn	Browser Identifier	3 months
li-oatml	LinkedIn	Member indirect indentifier for conversion tracking, retargeting, analytics	1 month
li_fat_id	LinkedIn	Member indirect indentifier for conversion tracking, retargeting, analytics	1 month
U	LinkedIn	Drawbridge Browser Identifier	3 months

Personal information does not include deidentified or aggregated consumer information.

III. Disclosures and Sharing Practices

In the description below, we provide categories of PI that DequeU discloses to its service providers.

How Online Usage Information is shared
Categories of Personal Information Collected	Is PI shared for business purposes?	Categories of service providers with whom PI has been shared for business purposes
Personal Identifiers	Yes	Service Providers and Vendors such as: Internet Service Providers (ISP) Software and IT providers Analytics providers (Google Analytics)
Commercial information	Yes	Service Providers and Vendors such as: Internet Service Providers (ISP) Software and IT providers Analytics providers (Google Analytics)
Internet or another similar network activity	Yes	Service Providers and Vendors such as: Internet Service Providers (ISP) Software and IT providers Analytics providers (Google Analytics)
Geolocation data	Yes	Service Providers and Vendors such as: Internet Service Providers (ISP) Software and IT providers Analytics providers (Google Analytics)
Inferences are drawn from other personal information	Yes	Service Providers and Vendors such as: Internet Service Providers (ISP) Software and IT providers Analytics providers (Google Analytics)

Note to California Residents: It is our good-faith understanding that these practices are not considered ‘selling’ (as the term “sell” is defined by the California Consumer Privacy Act) since the information is shared to comply with the business purposes defined in the previous section and in most cases this information is de-identified or in aggregate. Nevertheless, in the section below, we provide you with choices to control and delete the collection of Online Usage Information.

For example, we use Google Analytics on our website to allows us to count the visitors of our website, identify the pages most visited and improve our services and offerings. We have implemented mechanisms to limit the type of information Google accesses when providing this service (e.g., we use IP masking and also how it is used (e.g., we have activated restricted data processing).

IV. Your Choices

You can control and delete these cookies and the collection of Online Usage Information using our Cookie Management Tool available hereinsert LINK], or through your browser settings as follows:

For Google Analytics cookies, you can also use the following cookie management and disposal tool from Google by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.

If you want to opt-out of our marketing or newsletter communications, you can use the unsubscribe link located at the bottom of our emails or you can contact us at privacyinquiry@deque.com.

V. Contact

If you have questions or concerns regarding our use of cookies you can contact us at:

Deque Systems, Inc.
381 Elden Street Ste 2000
Herndon, VA 20170

privacyinquiry@deque.com

Last Updated: July 17, 2020