Privacy Policy
Effective Date: 8.21.2024
This Privacy Policy explains how Sublynk, Inc. (“Sublynk”, “we”, “our”, and “us”) collects, uses, shares, and otherwise processes your personal information (also known as personal data) in connection with the use of the Sublynk websites and applications that link to this Privacy Policy (the “Sites”), including the Sublynk platform located at Sublynk.com that is only accessible by account holders (the “Platform Services”), and in the usual course of business, such as in connection with our events, sales, and marketing activities (collectively, the “Services”). It also contains information about your choices and privacy rights.
If you are a California resident, please see our Supplemental Privacy Policy to California Residents regarding your rights with respect to your personal information.
Our Services
We provide the Platform Services to our customers and users (collectively, “Customers”) under an agreement with them and solely for their benefit and the benefit of their personnel authorized to use the Platform Services (“Authorized Users”). Our processing of Customer data, including any Customer personal data, is governed by our agreement with the relevant Customer. This Privacy Policy does not apply to (i) the data we process on behalf of our customers (where we act as a data processor or service provider) that our Customers and their Authorized Users upload, submit or otherwise make available to the Platform Services, which is addressed by our agreements with our Customers; (ii) any products, services, websites, or content that are offered by third parties or that have their own privacy notices; or (iii) personal information that we collect and process in connection with our recruitment activities.
We recommend that you read this Privacy Policy in full to ensure that you are informed of our practices and understand any rights or choices you may have. However, if you only want to access a particular section of this Privacy Policy, you can click on the link below to go to that section.
Information We Collect About You
How We Disclose Your Information
Information We Collect About You
Information that we collect from or about you includes information you provide, information we collect automatically, and information we receive from other sources.
Information you provide
When using our Services, we may collect certain information, such as:
Identifiers: We collect your name, email address, phone number, and postal address to administer your account and provide our Services to you.
Employment-related information: In addition to the Identifiers, we also collect information about your job title and company name.
Account information: If you create an account on our Services, we collect your authentication information used to access your account.
Customer service and other interaction information: We collect information that you provide through your interactions with us, including if you request information about our Platform Services, interact with our sales team or contact customer support, complete a survey, provide feedback or post comments, register for an event, or take part in marketing activities. We may keep a record of your communications with us and other information you disclose during the course of the communications.
Commercial information: We keep records of your history of past purchases and transactions with us (e.g., when you signed up for a free trial)
Financial information: We collect your credit card or other form of financial account information if chosen by you as a payment method, which may be collected directly by or disclosed to our third-party payment and billing service providers.
Information posted in public forums
Certain features of our Services may make it possible for you to post content publicly or viewable by other users, such as through a customer support community or through other public forums. Any information you post openly in these ways will be available for viewing and use by other users.
Information we collect automatically
We use standard automated data collection tools, such as cookies, web beacons, tracking pixels, tags, and similar tools, to collect information about how people use our Sites and interact with our emails. For example, when you visit our Sites we (or an authorized third party) may collect certain information from you or your device. This may include information about your computer or device (such as operating system, device identifier, browser language, and Internet Protocol (IP) address), and information about your activities on our Sites (such as how you came to our Sites, access times, the links you click on, browsing behavior, clicks and cursor movements, and other statistical information). We use this information to help us understand how you are using our Sites and how to better provide the Sites to you. We may also use web beacons and pixels in our emails. For example, we may place a pixel in our emails that notifies us when you click on a link in the email. We use these technologies to improve our communications. We may also use your IP address to derive your general location information.
When you use our Platform Services, we automatically collect information about how you are using the Platform Services (“Usage Data”). While most Usage Data is not personal information, it may include information about your account (such as User ID, email address, or Internet Protocol (IP) address) and information about your computer or device (such as browser type and operating system). It may also include information about your activities within the Platform Services, such as the pages or features you access or use, the time spent on those pages or features, search terms entered, commands executed, information about the types and size of files analyzed via the Platform Services, and other information relating to your use of the Platform Services. We collect Usage Data to provide, support and operate the Platform Services, for network and information security, and to better understand how our Authorized Users and Customers are using the Platform Services to improve our products and services.
We may also use the information we collect automatically (for example, IP address, and unique device identifiers) in combination with other information we collect directly from you as you interact with the Services or from other sources about you to identify the same unique person across Services to provide a more seamless and personalized experience to you.
Information we receive from other sources
We may obtain information about you from third party sources, including resellers, distributors, business partners, event sponsors, security and fraud detection services, social media platforms, and publicly available sources. Examples of information that we receive from third parties include marketing and sales information (such as name, email address, phone number and similar contact information), and purchase, support and other information about your interactions with our Services. We may combine such information with the information we receive and collect from you.
How We Use Your Information
We use your personal information to provide, maintain, improve and update our Services. Our purposes for collecting your personal information include:
To Provide the Services:
To provide, maintain, deliver, and update the Services
To create and maintain your Sublynk account
For billing, payment, or account management (e.g., to identify your account and correctly identify your usage of our products and services)
To register and provide you with training and certification programs
To provide you with customer service and support
Sales and Marketing
To tailor and send you newsletters, emails and other content to promote our products and services and to allow third party partners (like our event sponsors) to send you marketing communications about their services, in accordance with your preferences
To Communicate with You
To send you notifications about the Services, including technical notices, updates, security alerts, administrative messages and invoices
To respond to your questions, comments, and requests, including to keep in contact with you regarding the products and services you use
To contact you to conduct surveys, receive your feedback, conduct audits, and for market research purposes
Online Advertising
For online advertising purposes; for example, to display and measure advertising on third party websites
Personalization and Service Improvement
To personalize your experience when using our Services
To measure your use of and improve the Services, and to develop new products and services
To generate and analyze statistical information about how our Sites and Platform Services are used in the aggregate
Legal and Security Purposes
To investigate security issues, prevent fraud, or combat the illegal or controlled uses of our products and services, including within our learning and certification programs
To comply with our obligations under applicable law, legal process, or government regulation
With Your Consent
We will also use your information for other purposes, where you have given consent for such uses.
De-Identified/Anonymized Information. We may de-identify or anonymize information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified or anonymized form. Except as otherwise prohibited by applicable law, our use and disclosure of de-identified and anonymized information is not subject to any restrictions under this Privacy Policy.
How We Disclose Your Information
We may disclose your personal information to third parties as follows:
Affiliates: with our affiliates and subsidiaries for the purposes described in this Privacy Policy
Service Providers: with our service providers who assist us in providing the Services, such as billing, payment card processing, customer support, sales and marketing, and data analysis, subject to appropriate contractual prohibitions on their use of your information. We also disclose information to service providers who assist us with detecting and preventing fraud, security threats or other illegal or malicious behavior
Third-Party Partners and Sponsors: with third party business partners, such as resellers, distributors, and/or referral partners, who are involved in providing content, products or services to our prospects or Customers. We may also engage with third party partners who are working with us to organize or sponsor an event to which you have registered to enable them to contact you about the event or their services (but only where we have a lawful basis to do so, such as your consent where required by applicable law)
Online Advertising Partners: with online advertising providers that tailor online ads to your interests based on information they collect about your online activity over time and across different services (known as targeting online advertising)
Sponsoring Organizations: with the organization that is sponsoring a training or certification program that you take through the Services, for example to notify them of your registration and completion of the course
For legal purposes: when authorized by law or we deem necessary in good faith to comply with legal process; when required to protect and defend the rights or property of Sublynk or our Customers, including the security of our Sites, products and services (including the Platform Services); or when necessary to protect the personal safety, property or other rights of the public, Sublynk, or our Customers
With your consent: when you instruct us to do so or where you have consented to the disclosure of your information with third parties
Business Transactions: we may engage in transactions with other companies involving the sale of assets or parts of our business. We may disclose your information as part of, or in contemplation of, such transactions. If a portion or all of our assets are transferred to a third party in connection with such transactions, your information may be among the transferred assets, including in the course of activities leading up to such transactions
Your Choices and Rights
We offer you choices regarding the collection, use and disclosure of your personal information and we will respect the choices you make in accordance with applicable law. Please note that if you decide not to provide us with certain personal information, you may not be able to access certain features of the Sites or use the Platform Services.
Account information
If you want to correct, update or delete your account information, please log on to your Sublynk account and update your profile.
Opt out of marketing
We may periodically send you marketing communications that promote our products and services consistent with your choices. You may opt out from receiving such communications by following the unsubscribe instructions in the communication you receive. Please note that it may take us some time to process your request in accordance with applicable law, and that we may still send you important service-related communications regarding our products or services, such as communications about your subscription or account, service announcements or security information.
Your privacy rights
Depending on your place of residence, there may be applicable data protection laws that provide you with certain rights in relation to your personal information. Depending on such data protection laws, those rights may include asking for:
Access to, or a copy of, your personal information
Confirmation that we are processing your personal information
Correction or amendment of your personal information
Deletion of your personal information
Transfer of your personal information to a third party
Restriction or objection to certain uses of your personal information
The withdrawal of consent to processing your personal information for certain purposes that were originally based on your consent
Opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
If you (or an authorized agent acting on your behalf) wish to exercise any of your rights under applicable data protection laws, submit a request online by emailing us at legal@sublynk.com. We will respond to requests that we receive in accordance with applicable laws. Sublynk may take certain steps to verify your request using information available to us, such as your email address or other information associated with your Sublynk account, and if needed we may ask you to provide additional information for the purposes of verifying your request. Any information you provide to us for verification purposes will only be used to process and maintain a record of your request. Depending on the laws applicable to your request, if you are not satisfied with our response to your request, you may have the ability to appeal our response. If an appeal right is applicable to you, we will let you know in our response to you.
As described above, we may also process personal information that has been submitted by a Customer to our Platform Services. If your personal information has been submitted to the Platform Services by or on behalf of a Sublynk Customer and you wish to exercise your privacy rights, please direct your request to the relevant Customer.
Notice of Right to Opt Out of Data "Sales" and "Targeted Advertising"
Depending on your location, you may have the right to opt out of the "sale" of your personal information or the disclosure of your personal information for purposes of online targeted advertising. We do not "sell" personal information in the traditional sense of exchanging information for monetary payment. However, because the definitions of “sale” and “targeted advertising" under applicable law may include the disclosure of your information to certain types of advertising and marketing partners, we provide the right to opt-out of these activities. To opt out of such disclosures based on cookies and similar tools, please email your request to legal@sublynk.com. We do not knowingly “sell” or “share” the personal information of individuals under 16 years of age.
Other Important Notices
Notice to Authorized Users
Our Platform Services are intended to be used by organizations. Where the Platform Services are made available to you through an organization (e.g., your employer), that organization is the administrator of the Platform Service] and is responsible for the accounts and/or services over which it has control. For example, administrators can access and change information in your account or restrict and terminate your access to the Platform Services. We are not responsible for the privacy or security practices of an administrator's organization, which may be different from this Privacy Policy. Please contact your organization or refer to your organization's policies for more information.
Data Retention
Sublynk retains the personal information described in this Privacy Policy for as long as you use our Services, as may be required by law (for example, to comply with applicable legal tax or accounting requirements), as necessary for other legitimate business or commercial purposes described in this Privacy Policy (for example, to resolve disputes or enforce our agreements), or as otherwise communicated to you.
Security
We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information.
Third Party Services
Our Services may contain links to third party websites, applications, services, or social networks (including co-branded websites or products that are maintained by one of our business partners). We may also make available certain features that allow you to sign into our Sites using third party login credentials (such as LinkedIn, Facebook, Twitter and Google+) or access third party services from our Platform Services. Any information that you choose to submit to third party services is not covered by this Privacy Policy. We encourage you to read the terms of use and privacy notices of use of such third-party services before disclosing your information to them to understand how your information may be collected and used.
Children's Data
The Sites, Platform Services, and Services are not directed to children under 18 years of age and Sublynk does not knowingly collect personal information from children under 18. If we learn that we have collected any personal information from children under 18, we will take steps to delete such information. If you are aware that a child has submitted us such information, please contact us using the details provided below.
Changes to This Policy
We may make changes to this Privacy Policy from time to time. We will post any changes here, and such changes will become effective when they are posted. Your continued use of the Site, the Platform Services, or our Services, or your interaction with us following the posting of any changes will mean you consent to those changes.
How to Contact Us
Please contact us at legal@sublynk.com if you have any questions about our privacy practices or this Privacy Policy. You can also write to us at Sublynk Inc., 357 McCaslin Blvd, Suite 219, Louisville, Colorado, 80027. If you interact with Sublynk through or on behalf of your organization, then your personal information may also be subject to your organization’s privacy practices and you should direct any questions to that organization.