Privacy Policy

Last Updated: January 20, 2020 

Praktio LLC, a Michigan limited liability company (“Praktio” or “we”), is committed to protecting your privacy. This privacy policy applies to all users of the websites and online services available at praktio.com, praktio.litmos.com, or any other site owned or operated by Praktio (collectively, the “Website”) and explains how we collect and use the personal data we collect when you visit the Website. Our processing of your personal data is subject to this privacy policy and any subsequent updates.

General

“Personal data” is defined as information that identifies, or can be used to identify, an individual. We collect personal data both directly and indirectly when you visit the Website.

Praktio is the controller of personal data collected through the Website, except when we’re processing on behalf of your employer, in which case we’re a processor and your employer is the controller. We will only process your personal data when we have a legal basis to do so, which include your consent, fulfilment of a contractual obligation, and where we have a legitimate interest to process your personal data, provided that our interests do not outweigh your individual rights and freedoms.

 Our legitimate interests include: 

  • Enabling our business operations, including providing services to you;
  • Understanding and improving the Website, user experience, and customer relationships;
  • Improving your experiences with our products and services;
  • Investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this policy;
  • Protecting and defending our rights and properties, including intellectual property; and
  • Complying with laws and regulations that apply to us, as well as responding to requests from law enforcement or government authorities or as otherwise required by law.

    Where we rely on your permission to process your personal data, you have the right to change, withdraw, or withhold your consent.

    Personal Data Collection

    We collect personal data that you choose to share with us, as well as information provided directly by your browser or device when you visit the Website. The information we collect will depend on how you interact with the Website.

    Personal Data Collected from You

    Submit a Contact Form

    When you contact us via our “Contact” form, we will ask you for your name, email address, and company name. We will also collect the content of your message, which will contain any additional personal data you choose to include.

    We collect this information for the purpose of responding to your request or other communications.

    Schedule a Demo

    If you schedule a demo of our products, we will collect your preferred date and time for the demo, as well as your name, email address, company, and company size.

    We collect this information for the purpose of scheduling your demo and communicating with you before and after your scheduled demo.

    Sign Up for a Trial

    If you sign up for a free trial of our products, we will collect your name, email address, and the name of your organization. We will also collect any additional information you choose to share with us, which may include any personal data you elect to share.

    We collect this information for the purpose of facilitating your online free trial and communicating with you about our products.

    Sign Up for a Prototype Course

    When you take one of our prototype courses, we will collect your name, email address, and company name.

    We collect this information for the purpose of granting you access to the prototype course and following up with you about your experiences and communicating with you about our products.

    Participate in a Quiz

    If you participate in a free quiz on praktio.com, we will collect your responses within the quiz questions, as well as your name and email address.

    We collect this information for the purpose of providing you with the results of your quiz and following up with you about your experiences and communicating with you about our products. 

    Log In

    If you log in to use our products, we will collect your username and password.

    We collect this information for the purpose of granting you access to the courses associated with your account.

    Chat with Us

    If you interact with our live-chat feature, we will collect any personal data you choose to share with us during your chat.

    We use this information for the purpose of responding to your chats and following up with you in the context of our chat session.

    Register for Praktio News

    If you register to receive news from Praktio, we will collect your email address. We use this information for the purpose of adding you to our mailing list and sending you communications and updates about our products and services. You may opt-out of such communications by clicking the “Unsubscribe” link at the bottom of any email communications or by contacting us using the information provided at the end of this privacy policy under the heading “Contact Information” to request that we remove you from our news communications.

    Make a Purchase

    If you make a purchase on the Website, we will collect your email address, name, address, and country. You also will have the option of providing your company and telephone number.

    We will also collect payment information, which includes your provided credit card number, name on card, expiration date, and security code. 

    We collect this information for the purpose of processing your purchase and delivering purchased products.

    Register Your Account to Take a Course

    If you register your account to take a course (on praktio.litmos.com), we will collect your name, username, email address, and any CLE (continuing legal education) information (including state bar numbers). You also will have the option of providing your title, manager, company, website, work phone number, mobile phone number, Skype handle, Twitter handle, address, country, time zone, language, practice group, and firm office.

    We collect this information for the purpose of registering your account and giving you access to the courses associated with your account.

    Take a Course

    If you take a course (on praktio.litmos.com), we will collect your responses for each learning activity.

    We collect this information for the purpose of: delivering courses to you; improving course content and user experience; developing new course content; in some courses, delivering conditional course content; responding to a question you submit about a specific course exercise; and, in some courses, delivering summaries of your response data to you.

    Submit Feedback in a Course

    If you submit feedback by hitting the “Feedback” button in a course module (on praktio.litmos.com), we will collect the content of the subject and message fields, which will contain any personal data you choose to include. You will also have the option to send us a file or screenshot.

    We collect this information for the purpose of responding to your request or other communications and to improve course content and user experience.

    Personal Data Collected via Web-Based Technologies 

    Take a Course

    If you take a course (on praktio.litmos.com), we will collect your behavioral data on the learning management system and within each course module, including login activity, your progress or position within a course, and your duration in each course learning activity. 

    We collect this information for the purpose of delivering courses to you; improving course content and user experience; developing new course content; and, if you’re taking a course as part of an organization, delivering progress and completion data to the applicable personnel at your organization.

    Browser or Device Information

    We automatically receive and record information on our server logs from your browser, including your IP address, cookie information, and the page(s) you request. We collect this data for the following general purposes: 

    • Customizing your user experience
    • Fulfilling your requests for products and services
    • Delivering all products and services requested by you
    • Promoting and improving services
    • Contacting you

    We also collect your IP address(es) for the purpose of analyzing Website trends, administering the site, and tracking user movement for aggregate usage analysis. This Website usage information enables us to provide our users with an ever-improving site, service, and general offering.

    Cookies and Web Beacons

    We may set and access cookies on your computer to customize the user experience. “Cookies” are small files placed on your computer by your browser and are often used to make websites work, as well as provide information to the website operator.

    We collect this information for the purpose of conducting analyses on our web traffic and improving your experience while visiting the Website. You also have the ability to decline cookies by modifying the settings in your browser. If you decline or disable cookies, please note that certain functionalities of the Website may no longer work. 

    Communications you receive from us, as well as pages of the Website, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that enable us to analyze e-mail and Website statistics, including visits and click-through rates, and, depending on the number of recipients on an email, to identify you individually.

    Third-Party Web Technologies

    We use Google Analytics to track analytics information on visitors to the Website. Google Analytics collects IP address data but does not share this information with us.

    Some content or applications on the Website are served by third parties, including content providers and application providers. Our third-party partners may use cookies alone or in conjunction with web beacons or other tracking technologies already in your browser to collect information about you when you visit the Website. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites and other online services.

    Third-party cookies and web technologies are controlled by our third-party partners and are not subject to this privacy policy. If you have any questions about the practices of such third party, you should contact the responsible third-party directly. 

    Personal Data Use

    How we use your personal data will depend on how you interact with the Website and the personal data you have shared with us.

    Respond to Your Requests 

    We use your personal data to respond to your requests, including communications, purchases, and job applications.

    Enhance Website and User Experience

    We use the information regarding the use of the Website to analyze and administer the site and track user movement for web analytics purposes. This Website usage information enables us to provide you with an ever-improving site, service, and general offering. Except where you have provided consent for us to use your identifiable personal data, for our analytics research, we only use anonymous, aggregate data that cannot be used to identify you individually.

    Manage
    Account

    If you create an account on the Website, we will use your personal data to administer your account. If necessary, we will also use your personal data to verify your identity and provide you with access to your account should you become locked out or forget your login and password. 

    Conduct
    Marketing and Advertising

    We will use your personal data to provide you with updates and communications about our products. You may opt-out of such communications by clicking the “Unsubscribe” link at the bottom of any marketing electronic communication received from us. You may also contact us using the information provided at the end of this privacy policy under the heading “Contact Information” to request that we remove you from our marketing communications.

    Meet Legal and Regulatory Obligations

    In certain circumstances, we may be required to disclose your personal data as part of court or other legal proceedings or to regulators or as otherwise required by law. We will only share the information we are required to disclose by law and only when we are required to do so.

    Security and Fraud Prevention

    When necessary, we will use your personal data to preserve the security of the Website, systems, and personal data in our control. If necessary, we will also use your personal data to investigate possible fraud, violations of this privacy policy and to prevent any attempted harm to our users.

    Personal Data Sharing and Disclosure 

    We share your personal data when you have granted us permission to do so, when it is necessary to fulfill our obligations to you, or when it is in the legitimate interest of our business to do so, provided that our interests do not outweigh your individual rights and freedoms.

    Support Vendors

    When necessary, we share your data with third-party vendors working on our behalf to provide specific business support services, including: payment processing; customer relationship management; communications for marketing, sales, or news purposes; and website hosting and management; delivery of online courses, products, quizzes, prototypes, and other materials; and management of your user account applicable to any of the foregoing.

    Website Analytics Companies

    We share information regarding visitors to the Website with third-party website analytics companies, such as Google Analytics. These companies aggregate and anonymize this data to provide us with insight regarding our visitors’ web usage patterns. We cannot trace this information back to you individually. 

    You may choose not to share your data with Google Analytics by installing the Google Analytics opt-out browser add-on, which instructs your browser not to provide the Website usage data to Google Analytics. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout to install the browser add-on.

    Please note that installing the Google Analytics opt-out browser add-on will only disable the use of Google Analytics and will not prevent data from being sent to the Website itself or to other web analytics services.

    Legal Requirements

    As required by law, regulation, or legal process, we will share your personal data with government authorities, enforcement officials, or third parties as necessary to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.

    Security and Fraud Prevention Efforts

    When necessary, we will share your personal data to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or suspected violations of this privacy policy, our agreements or arrangements with you or other policies in effect from time to time to which you are subject, or as otherwise required by law.

    Sale of Business

    We reserve the right to transfer your personal data in the event we sell or transfer all or a portion of our business or its assets. In such event, your personal data will continue to be governed by this privacy policy.

    Your Choices and Rights

    EU Data Subject Rights

    If you are an EU data subject, we provide you with choices about the collection, use, and disclosure of your personal data. You may exercise these rights by contacting us at the information provided at the end of this privacy policy under the heading “Contact Information.”  Unless explicitly stated otherwise, we will respond to your request as soon as possible but at the latest within one month. 

    Your rights include:

    • Accessing your personal data to know what information we have collected about you and how it has been shared;
    • Requesting the deletion of all or some of your personal data;
    • Changing or correcting inaccurate or outdated information;
    • Objecting to, limiting, or restricting use of all or some of your personal data; and
    • Requesting a copy of your personal data, including in a portable format.

    You also have the right to lodge a complaint with your supervisory authority if you believe we have violated your privacy rights or applicable laws and regulations. 

    California Privacy Rights

    If you are a resident of the State of California and you have provided your personal data to us, you have the right to request a list of all third parties to which we have disclosed your personal data for direct marketing purposes. If, you exercise your right to submit such a request to us, we will send you the following information: 

    • The categories of information we have disclosed to any third party for any third party’s direct marketing purposes during the preceding year; and
    • The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

    You may make such a request by contacting us using the information provided at the end of this privacy policy under the heading “Contact Information” with a preference on how our response to your request should be sent.

    California law also requires that we disclose how we respond to “do-not-track requests” from our users. At this time, we do not currently respond to “do-not-track” requests from our visitors’ browsers.

    Other Important Information

    Cross-Border Data Transfers

    We process data both inside and outside the United States. It is important to know that data protection laws in the United States may not be as strong as those in your country. Where we transfer your personal data from the European Economic Area (“EEA”) to a location outside the EEA, we will only transfer your data if an appropriate level of protection for your personal data is guaranteed, such as where we have contractual obligations to protect or transfer data with certain safeguards in place. To ensure the continued protection of your personal data while in our care, we take appropriate organizational and technical measures. In addition, we may transfer your personal data if one of the legal exceptions for such transfer can be invoked, such as with your consent or in execution of an agreement you have with us. 

    Third-Party Websites

    This website may contain links to websites owned or operated by third parties. This privacy notice applies only to the Websites and not to any third-party websites. 

    Security

    We have implemented organizational and technical safeguards for protecting the personal data you share with us against loss and against unauthorized access, use, and disclosure. We also contract with third parties that encrypt personal data while in transit and at rest. Account passwords are stored in encrypted form, but you are also responsible for the confidentiality of your user information and account password and should act accordingly. If you lose your password, you can generate a new password using the Website once you have authenticated yourself as the authorized user. 

    Data Retention

    You may request that we delete or deactivate your account or otherwise delete personal data, and we shall attempt to accommodate such requests. However, we will retain and use personal data for such periods of time as required by law or, if you are taking a course as part of an organization, as requested by that organization.

    Children Under the Age of 16

    We do not knowingly collect personal data from individuals under the age of 16. The Website is not intended for anyone under the age of 16, and no one under the age of 16 may provide information on this Website.

    Privacy Policy Changes

    We may update or revise this policy at any time, at our sole discretion. Any changes to our privacy policy will apply to your personal data from the “Last Updated” date at the top of the privacy policy. You can find the most current version of our privacy policy at any time by clicking on the “Privacy Policy” link at the bottom of the Website. If we make material changes to our privacy policy, we will notify you of those changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on the Website.

    Contact Information

    Please contact us with any questions or comments you may have at privacy@praktio.com.