Gates Hudson respects your concerns about privacy. References in this Privacy Policy to “Gates Hudson”, “we”, “us”, and “our” are references to the Gates Hudson entity responsible for the processing of your personal information, which generally is the Gates Hudson entity that collects your personal information.
This Privacy Policy describes the types of personal information we obtain, how we may use that personal information, with whom we may share it and how you may exercise your rights regarding our processing of that information. The Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.
This Privacy Policy applies to the personal information we obtain through Gates Hudson properties, including websites, products, services, desktop and mobile apps, and other tools offered by Gates Hudson that reference this Privacy Policy (“Online Channels”); offline collection, including Gates Hudson events, surveys, questionnaires, customer user research and evaluations (“Offline Channels”); and third-party sources, including business partners, ad networks and vendors (collectively, the “Offerings”).
In connection with providing support, cloud and other services, Gates Hudson processes certain data maintained in environments that Gates Hudson may access to perform cloud, consulting and support services (“Customer Content”) on behalf of and at the direction of its customers and partners, as well as log data (e.g., regarding access and authentication requests) that we collect for analysis and security purposes across our services. Our use of such Customer Content and log data is subject to the terms of our customer agreements and is not governed by this Privacy Policy. In contrast, the information we collect through our customers’ and partners’ use of our websites (such as names, addresses, billing information and employee contact information) and through our offline interactions with customers and partners is subject to the terms of this Privacy Policy.
The Online Channels may provide links to other third-party websites and features. Some of these third-party websites may be co-branded with a Gates Hudson logo even though they are not owned, controlled, operated or maintained by Gates Hudson. Gates Hudson does not share your personal information with those websites and is not responsible for their privacy practices. These websites are subject to their respective privacy policies. In some cases, we may provide the Offerings jointly with other businesses. For these co-branded offerings in which a third party is involved in your transactions, we will sometimes share or jointly collect customer data related to those transactions with that third party.
Personal Information We Obtain
The data we obtain varies based on the Offerings you use. We obtain personal information through your interaction with the Offerings, such as when you:
● create an account in an Online Channel;
● register or apply to a Gates Hudson Partner or Referral program;
● request access or visit our offices or facilities;
● sign up for an online program, event, seminar, promotion or sweepstakes;
● request products (including product evaluations, trials, tech preview and beta downloads), services or information;
● participate in Gates Hudson events including conferences, webinars, surveys, questionnaires, research or evaluations; or
● correspond with us or request information from us.
The types of personal information we obtain include:
● contact information (such as name email address, telephone number, postal or other physical address) for you or for others (e.g., principals in your business or billing contacts);
● information used to create your online account (such as username and password);
● business profile and practices information used to evaluate you as a partner;
● photographs, video images, voice recordings or transcripts;
● billing and financial information (such as name, billing address, payment card details and bank account information and purchase history);
● IP address and location data (such as data derived from your IP address, country and zip code);
● the precise geolocation of your mobile device;
● clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies (see our description of Cookies and Similar Technologies below);
● time and date related access to events, offices or facilities;
● information collected in on-site health self-certification forms required to access Gates Hudson facilities;
● personal information contained in forums, blogs, and testimonials you provide or that we obtain from publicly available sources (such as social media channels);
● information related to participation in classroom or online training, including programs completed and certifications achieved;
● information necessary to provide support or other paid consulting services (such as contact details, chat services, support details, and event history);
● personal information contained in content you submit to us (such as through our “Contact” feature or other in-product or in-service messaging); and
● other personal information we obtain through our Offerings.
Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.
How We Use Personal Information
We use the information we obtain to:
● provide and administer our products and services (including websites and apps for which you have registered);
● process and fulfill orders in connection with our products and services and keep you informed about the status of your order;
● help you complete a transaction or order and provide customer support;
● bill you for products and services you purchased;
● provide training, support and consulting services;
● create and manage your account with Gates Hudson;
● operate, evaluate and improve our business (such as by administering, developing, enhancing and improving our products and services; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
● perform data analytics (such as research, trend analysis, financial analysis and customer segmentation);
● communicate with you about your account and orders (including sending emails relating to your registration, account status, order confirmations, renewal or expiration notices and other important information);
● conduct advertising, marketing and sales activities (including sending you promotional materials, generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
● communicate with you about, and administer your participation in, events, programs, promotions and surveys;
● connect employees with their enterprise account administrator;
● verify your identity and protect your account against unauthorized use or abuse of our services;
● protect the health, safety and security of our employees;
● protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
● comply with and enforce relevant industry standards, contractual obligations and our policies;
● maintain and enhance the security of our Online Channels, products, services, network services, information resources and employees; and
● respond to your inquiries.
Depending on the purposes for which personal information is used, and the context in which the data is obtained, we may rely on one or more of the following legal bases:
● performance of a contract with you or a relevant party;
● our legitimate business interests;
● compliance with a legal obligation, a court order, or to exercise or defend legal claims; or
● your consent to the processing, which you can revoke at any time.
We may combine data collected from you with other sources to help us improve the accuracy of our marketing and communications as well as to help expand or tailor our interactions with you. This includes combining personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information (such as referral programs), for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.
Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.
Cookies and Other Technologies
Gates Hudson uses cookies, web beacons (including pixels and tags), and similar technologies on our Online Channels that collect certain information about you by automated means. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner includes IP address and other identifiers associated with your devices, types of devices connected to our Offerings, device characteristics (such as operating system), language preferences, referring/exit pages, navigation paths, access times, browser preferences and characteristics, installed plugins, local time zones, local storage preferences, clickstream data and other information about your online activities. We use on our Online Channels both first-party cookies (served directly by our website domain when you visit our Online Channels) and third-party cookies (served by a third-party website when you visit our Online Channels and certain third-party websites with whom we have partnered). Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).
The cookies we use on our Online Channels include (1) essential and functional cookies; (2) analytics cookies; and (3) targeting/advertising cookies, as described below.
Essential and Functional Cookies
We use cookies on our Online Channels that are necessary for us to provide you with our products and services. This includes essential cookies (such as those used to authenticate you to our website and identify you after you have logged in), functional cookies (such as those that remember what you added to your shopping cart or the language preference you selected), and user-centric security cookies used to increase the security of the products and services we provide to you (such as to detect authentication abuses). Given the necessary functionality of these cookies, they typically may not be disabled on our Online Services.
Analytics Cookies
We use analytics cookies to collect information on how users navigate and use our Online Channels, such as how the users traverse our Online Channels, the pages they view, how long they stay on a page and whether the page is displayed correctly or whether errors occur. Such cookies help us to improve the performance of our Online Channels and make the Online Channels more user-friendly. These cookies are provided by third-party analytics providers, including Google Analytics and Marketo. To learn more about Google Analytics and how to opt out, please visit Google Analytics at https://tools.google.com/dlpage/gaoptout. To learn more about these analytics services and how to opt out, please view our Cookie Consent Tool in the footer of our webpage.
Advertising Cookies
Advertising cookies are used to control and manage advertisements. These Cookies may collect information on whether a user has reacted to an advertisement and visited another website. Such cookies help us to offer you content and provide targeted information that is more relevant to your interests. They also help us to measure the effectiveness of our advertisements and communications. In the EU, we deploy analytics and advertising cookies on our websites only when users have opted-in as required by applicable law.
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Online Channels. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
Additional information about our cookie practices and how to manage your cookie preferences is available in the “Cookie Preferences” link in the footer of our webpages. To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.
The providers of third-party apps, tools, widgets and plug-ins on our Online Channels (such as Twitter, LinkedIn and Facebook) also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, Gates Hudson is not responsible for these providers’ information practices.
Interest-Based Advertising
When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) collect information about your online activities, over time and across third-party websites (such as on websites that serve our ads). We may use such information to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. You may see certain ads on other websites because we engage third-party ad buying networks. Through such buying networks, we can target our messaging to users through demographic, interest-based and contextual means. The information our ad networks may collect on our behalf includes data about your visits to websites that serve Gates Hudson advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in these ad networks. This process helps us track the effectiveness of our marketing efforts. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
Our Cookie Consent Tool in the footer of our webpages provides details about how to exercise your choices (such as changing your cookie preferences).
How We Share Your Personal Information
We do not sell or otherwise disclose personal information about you except as described here or at the time of collection. Gates Hudson may share personal data in the following ways:
● if sharing your data is necessary to provide a product, service or information you have requested;
● as part of a joint sales promotion or to pass sales leads to our business partners;
● to keep you up to date on the latest product announcements, software updates, special offers or other information we think you would like to hear from our business partners;
● within Gates Hudson (including among affiliates and subsidiaries) for the purposes described in this Privacy Policy;
● to connect employees with their company administrator(s);
● with our customers to report and help manage issues requiring support or as part of consulting services;
● with our customers and partners to inform them about their users’ use of our services (such as when a user has obtained credentials or completed a course);
● with service providers we have engaged to perform services on our behalf (such as payment processing, order fulfillment, customer support, customer relations management and data analytics).
These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements;
● with approved Gates Hudson Partners, to offer and provide our products and services to you; and
● with our joint marketing and sales partners and other business partners who help us with our business operations or other aspects of our business and for the purposes described in this Privacy Policy.
We also may disclose personal information about you (1) if we are required or permitted to do so by applicable law, regulation or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss to Gates Hudson, its users or the public as required or permitted by law, (4) to establish, exercise or defend our legal rights, and (5) in connection with an investigation of suspected or actual fraud, illegal activity, security or technical issues.
In addition, we reserve the right to transfer to relevant third parties information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business transaction.
We also may share the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.
Retention of Personal Information
To the extent permitted by applicable law, we typically retain personal information we obtain about you for as long as it is needed (1) for the purposes for which we obtained it, in accordance with the terms of this Privacy Policy, which generally means that we will keep your personal information for the duration of our relationship or as long as you keep your account open with us; or (2) to take into account applicable statute of limitation periods and comply with applicable laws, resolve disputes and enforce our agreements. As described in the “Your Rights and Choices” section above, to the extent provided by the law of your jurisdiction, you may request that we delete your information or restrict the processing of such information by contacting us as indicated below.
Children’s Personal Information
The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How To Contact Us section of this Privacy Policy.
Changes to Our Privacy Policy
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated. However, if we make any material changes we will notify you by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.
How to Contact Us
If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences,
please go to
https://gateshudson.com/services/#contact
Last Updated: September 2, 2021