PRIVACY POLICY - Introduction

Gilmore Global provides a global infrastructure to sell and distribute physical and digital versions of training content, technical information and marketing collateral. We enable our customers supply chain with a cost effective and efficient delivery model for these products. This Privacy Policy applies to all users that interact with our Digital Services, our Customer Support Services and other services as a registered user of the Services, guest / transient user of the Services, or other users that may be provided with free trial access from time to time. This Privacy Policy applies when you use our Services online, via web applications, applications or in other manners which may be the case from time to time. This Privacy Policy also applies when you interact with our Customer Support Services, surveys, questionnaires, digital marketing or direct marketing services. We may from time to time exchange your Personal Information to provide a service such as access to a third party application or to a courier for the purpose of product distribution.

Collection and Use of Personal Data

Personal Data We Collect

We may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We use this Personal Data to; a) meet our contractual commitments to you / your employer, b) administer your account and respond to your requests, c) provide the products that you request, d) maintain and improve the products, e) provide you with information about the products and contemplated changes to the products (provided that you do not object to being contacted for these purposes), f) customize content supplied to you based on your use of products, g) track, evaluate and analyse individual and aggregate use of the products and to share, publish, or otherwise publicize the information, but not Personal Data describing such use, and h) prevent, investigate and deal with fraud, violation of intellectual property rights and other laws and unauthorized use of products for your account. We collect and process the following categories of Personal Data:

Identity Data: Personal Data about you and your identity such as your name, username, and other Personal Data you or your employer may provide on user account registration or purchase transactions that form as part of an account profile.

Transaction Data: Personal Data we collect in connection with a transaction or purchase, such as the details of the purchase you made, the price, your billing address, postal/zip code, and other similar information.

Contact Data: Personal Data used to contact an individual, e.g. email address(es), physical address(es), phone number(s), or social media or communications platform usernames/handles, as well as a name or other salutation.

Financial Data: Personal Data relating to financial accounts or services, e.g. a credit card or other financial account number, and other relevant information you provide in connection with a financial transaction.

Device Data: Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application ID/AdID/IDFA, identifiers from cookies, session navigation history, and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies.

Electronic Processing of Personal Data

Data: We process Identity Data, Transaction Data, Contact Data, Financial Data and certain Device Data to complete a transaction or purchase through our Digital Services.

Uses: We use Identity Data, Transaction Data, Contact Data, Financial Data and certain Device Data as necessary to complete and provide you with important information regarding your transaction. Financial Data is used only as necessary to process transactions that you request.

Customer Support (Account Management and Customer Service) Associate

Data: We process Identity Data, Transaction Data, Contact Data and certain Financial Data when you contact us via our call centre, chat, contact us forms, or other support options. For example, you may speak with a Customer Support associate that enters your information “Data” into our customer database for the purpose of processing a transaction, researching a transaction or completing a task at your request.

Uses: We use the Identity Data, Transaction Data, Contact Data and certain Financial Data as necessary in connection with your support request. Financial Data is used only as necessary to process transactions that you request.

Account Registration

Data: You may be able to register and create an account on our Digital Services or a third parties Digital Services. If you choose to register, we will process Identity Data and certain Contact Data. We may also process certain Financial Data if you choose, for example, to complete an online purchase.

Uses: We use the Identity Data and Contact Data as necessary to create, maintain, and provide you with important information about your account. Financial Data will be used only as necessary to process transactions at your request.

Surveys and Questionnaires

Data: We may process Identity Data and certain Contact Data if you choose to complete a customer survey, questionnaire, or similar form.

Uses: Subject to Your Rights and Choices, we may use this Identity Data and Contact Data to improve our services and to create a personalized user experience for you.

Marketing Communications

Data: We may process Identity Data, Device Data and Contact Data when you are enrolled to receive, and when you open or interact with, our electronic marketing communications. Note, you may be enrolled with your consent or, where allowed, in connection with account registration or a purchase.

Uses: Subject to Your Rights and Choices, we use the Identity Data, Device Data and Contact Data to improve our services and to create a personalized user experience.

Cookies and Similar Technologies

Data: We, and certain third parties, may process Identity Data, Device Data, Contact Data and certain User Content when you interact with cookies and similar technologies. We may receive this data from third parties to the extent allowed by the applicable partner; otherwise, this Privacy Policy will not apply.

Uses: We use Device Data and Identity Data to enable you to register with and/or use certain features of these technologies. Subject to Your Rights and Choices, we may use Identity Data, Location Data, Device Data, and Contact Data to improve our services and to create a personalized user experience.

Note: Some of these technologies can be used by us and/or our third party partners to identify you across platforms, devices, sites, and services.

Additional Processing

If we process Personal Data in connection with our Digital Services in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to Your Rights and Choices) unless otherwise stated when you provide it. Note that we may, without your consent, also process your Personal Data on certain public interest grounds. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

Data Sharing

Generally Information we collect may be shared with Service Providers (digital platform providers and couriers) depending upon the purpose for and context in which that information was provided. We generally transfer data to the following categories of recipients: Service Providers: In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we may share your Personal Data with service providers who provide certain services or process data on our behalf. If we share information, including Personal Data, with third parties we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell information to any third party. We share information as follows; a) to courier service providers for the purpose of transporting physical product, b) to software platform providers for the purpose of hosting digital content services, c) to governmental agencies for the purposes of importing product d) to auditors of our customers and d) to auditors of governmental authorities.

YOUR RIGHTS & CHOICES

Your Rights

Subject to the rights granted to other individuals, and our rights to limit or deny access/disclosure under applicable law, you have the following rights in your Personal Data. Note, we may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to prove your identity. You may exercise your rights by contacting us (re: data rights requests, except where noted): privacy@gilmoreglobal.com

Access: You may receive a list of your Personal Data that we process to the extent required and permitted by law.

Rectification: You may correct any Personal Data that we hold about you to the extent required and permitted by law. For Registration Data, you may be able to make changes via your account settings menu.

Erasure: To the extent required by applicable law, you may request that we delete your Personal Data from our systems.

Data Export: To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice.

Regulator Contact: You have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.

Your Choices

It is possible for you to use some of our Digital Services without providing any Personal Data, but you may not be able to access certain features or view certain content. You have the following choices regarding the Personal Data we process:

Consent: If you consent to processing, you may withdraw your consent at any time, to the extent required by law.

Direct Marketing: You have the choice to opt-out of or withdraw your consent to processing related to direct marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting us privacy@gilmoreglobal.com

Other Processing: You may have the right under applicable law to object to our processing of your Personal Data for certain purposes. You may do so by contacting us re: data rights requests privacy privacy@gilmoreglobal.com

Security

We implement reasonable administrative, technical, and procedural security measures to safeguard the Personal Data you provide us. These security measures include, at minimum, physical access controls to servers and mass storage devices, encryption, restricted access to sensitive data and ongoing monitoring for threats and vulnerabilities.

Data Retention

We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.

We may change this Privacy Policy from time to time, with such changes posted with an effective date. Your use of the Digital Service following notice of any changes indicates acceptance of any changes.

Contact Us

You may contact Gilmore Global at any time about this Privacy Policy. If you have questions or wish to generally discuss this Privacy Policy, please contact Gilmore Global at privacy@gilmoreglobal.com.

For EU residents, if you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.

Privacy Policy – Changes

Gilmore Global may change this Privacy Policy from time to time at its sole discretion. We encourage users to frequently review our Privacy Policy for any amendments that may have been made to the Policy. However, should a material change be made to our Privacy Policy, we will notify you in advance to such change taking effect or alternately at your next login to the Services provided. You confirm that your continued use of the Services after any change to the Privacy Policy will constitute your acceptance of such changes to the Policy.