OPDEV SYSTEMS, LLC
Global Privacy Policy
Last Updated: September 22, 2023
Opdev Systems, LLC and its affiliates and subsidiaries (“Opdev,” “our,” “we,” or “us”) respect your right to privacy. This Privacy Policy explains the personal data that we collect, share and use about you, and how you can exercise your privacy rights. This Privacy Policy applies to personal data that we collect through our websites, including Opdev Online, our learning management platform (the “LMS”) (collectively, the “Sites”), any offline interactions we have with you, and in the course of providing our products and services (collectively, the “Services”).
- What Does Opdev Do?
- What is Personal Data?
- What Does “Processing” Personal Data Mean?
- Personal Data We Collect
- Categories of Sources of Collection
- We Collect Personal Data You Provide
- External Links
- Information Collected Automatically
- Information Collected From Third-Party Sources
- How is Personal Data Used?
- Categories of Third Parties With Whom We Share Personal Data
- Information We Do Not Intend to Collect
- Your Rights and Choices Regarding Personal Data
- The Consequences of Not Providing Personal Data
- Data Retention
- De-Identified or Aggregated Information
- Social Media
- Information Security
- Access to Personal Data in Other Countries
- Additional Terms Applicable to California Residents
- Other Country-Specific Terms
- Updates to This Privacy Policy
- Translations
- Contact Us
This Privacy Policy does not apply to Opdev’s franchisee websites, or our franchisees’ collection, use or disclosure of personal data. Each individual franchise is owned by a franchisee as a separate legal entity from Opdev.
WHAT DOES OPDEV DO?
Opdev is a global training provider for sales, leadership and management, headquartered in the United States. For more information about Opdev, please see the “About Opdev” section of our Site at https://https://opdevinternational.uk/about.
Category of Personal Data
Data Element
Purposes / Uses
Legal Basis
- Identifier
- Full name
- Email address
- Mailing address
- Shipping address
- IP Address
- Unique personal identifiers
- Employer and Title
Operational (such as):
- Process orders
- Ship products
- Provide you access to our Services
- Respond to your requests
- Provide customer service
- Manage your account
- Operate the Sites
- Fraud Prevention
- Protect the security of the Sites and the data we collect
Services (such as):
- Develop our Services
- Improve our Services
- Improve our user experience
- Develop training materials
- Improve our Sites
- Evaluate Users needs
Advertisement, Marketing and Sales (such as):
- Direct marketing to you
- Performing market research and data analysis.
- Customize the Sites.
- Help us to understand demographics and content preferences
Legal (such as):
- To comply with legal and regulatory requirements, requests or obligations
- Business transactions
- To protect legal rights of Opdev, any third parties and you as applicable.
Legal (such as):
- Considering you for employment
- In connection with administering employee benefits
- As otherwise necessary in connection with your employment as described below
- Legitimate interest
- Performance of a Contract
- Protected Classifications
- Birthdate
- Race
- Citizenship
- Marital status
- Gender
- Ethnicity
- Military or Veteran status
- Disability status (if applicable as our employee)
- EEO job category
- To evaluate your qualifications for employment or an internship
- To perform our duties as an employer
- To comply with our legal obligations
- Legitimate interest
- Performance of a Contract
- Commercial Information
- Services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Services and products in your shopping cart that are not yet purchased
- To fulfill purchases and ship products
- To provide customer service
- To advertise and market Opdevproducts and Services
- To help us improve the Services and the Sites
- To develop new Services.
- To evaluate qualifications as a prospective franchisee or business partner of Opdev
- To evaluate your coursework
- Legitimate interest
- Performance of a Contract
- Internet Activity
- Browsing history and preferences
- Device type
- Device typePerformance / statistics
- Browser version
- Content you viewed on the Sites
- Sites you visited before and after visiting the Sites
- Links clicked on the Sites Landing pages visited within the Sites
- Session cookies Unpurchased shopping cart information
- Session ID
- Log-in / log-out activity
- Activities performed on the Sites and within your account
- To offer, operate, maintain, deliver, troubleshoot and update the Sites
- For fraud prevention
- To help us provide safe and reliable Services through the Sites
- To help us improve the Services and the Sites
- To support, analyze, develop, improve, and enhance our products, Services, user experience, trainings, and Sites
- To provide direct marketing to you
- For market research and/or data analysis
- To evaluate user needs and customize the Sites
- To help us understand demographics and content preferences
- Legitimate interest
- Performance of a Contract
- Sensory Data
- Recordings of webinars may include your voice or face if you are on camera
- We collect videos of you that you create as part of training homework
- You may upload pictures of yourself when using Opdev Online
- Webinars are posted online for your organization to review such videos for enhanced learning opportunities
- To provide the Services, evaluate your homework and provide instructor feedback
- To perform a contract
- With your consent
- For a legitimate interest
- Employment
- Employment history Employment application
- Resume
- Pay requirements
- References
- Pay requirements
- Licenses and certifications Your skills and experience Insurance coverage Schooling and degree information
- To perform background or credit checks in considering you for employment
- To evaluate your qualifications for employment or an internship
- To perform due diligence in hiring
- To perform Opdev obligations as an employer
- Performing employer related activities
- Administrating benefits.
- To assist in administering our programming and communicating with your employer.
- Legitimate interest
- To perform a contract
- Education
- Educational background
- Graduation dates
- Degrees and certifications
- Membership in professional organizations
- the licenses and certifications you hold
- To evaluate your qualifications for employment or an internship
- · To recommend and advertise additional Services that you may be interested in
- · To improve and develop our Services
- Legitimate interest
- To perform a contract
- Inferences
- Inferences drawn you’re your purchase history and the courses you have taken.
- Creation of a “buyer persona” reflecting a buyer’s preferences, characteristics, predispositions, behavior, attitudes, abilities, job duties, and aptitudes
- To recommend or advertise Services to you.
- For market research and/or data analysis.
- To help us understand demographics of the Site, product preferences and content preferences.
- To evaluate user needs and customize the Sites
- Legitimate interest
We generally collect personal data from the following three categories of sources: (1) you provide personal data directly to us, (2) we automatically collect personal data from you when you use our Site (e.g. cookies) or when we provide Services, or (3) we receive personal data about you from third-party sources (e.g. from public sources)
We collect personal data that you provide directly to us. Personal data is required to use certain features of the Sites, for example, to create an online account, download resources, purchase training or other materials, take courses, submit job applications, send us questions through our Sites, receive or request data from us, and respond to communications from us. We also collect information you provide which may not be considered personal data, such as information about your organization, the team you work on and what brought you to Opdev or its Sites.
Online Forms. We collect personal data when you fill-out online forms or send other communications through our Sites, such as our “contact us” form, when you sign-up for an account (such as when you want to access the e-Learning Library or create a Opdev Online account), when you request more information about being a franchisee or strategic partner, when you download resources, articles, white papers and other guides, and when you sign-up for a webinar, immersion program, summit or other event.
Online Accounts / Opdev Online. We offer several resources that require you to set up an account with Opdev , such as when you sign up for Opdev Online or want to use our e-Learning Library. When you create an account with Opdev through our Sites, we collect your contact information and any other information requested from you at such time. You are also required to choose a password which you should keep confidential. When you are signed into your account, we may link your account with the activities you perform on our Site.
Purchases. When you make a purchase through our Sites, you will be re-directed to a PCI-compliant payment processor (“Payment Processor(s)”). Our Payment Processors may be located in other countries, and they may transfer certain personal data to other countries in order to provide us payment processing services, such as transaction processing and fraud prevention. For example, we may use Authorize.net to power our online store–you can read more about how Authorize.net uses your personal data.
Any information that you provide directly to the Payment Processor is governed by that Payment Processor’s privacy policy, not this Privacy Policy. Opdev does not receive your credit card, debit card or other financial information when you make a payment – such information is provided directly by you to the Payment Processor. However, Opdev does receive information about your purchase and your contact information (e.g. name, email address, mailing address, phone number). Opdev will keep a record of your purchases. We may collect tax identification numbers you submit for tax-exemption purposes.
Blog / Forum / Comments. If you leave a comment on our Sites, such as a response to a blog post, those comments may be posted publicly on our Sites or removed from our Sites, in Opdev’s sole discretion. Comments you send us will not be kept confidential, and we may identify you as the source of the comment. If you are signed into your account when you comment on our Sites, we may be able to link you and your account to your comments, and others in your organization may be able to read your comments.
Franchise or Strategic Partner Information. If you apply for or request information about becoming a Opdev franchisee or strategic partner, we will collect the information requested from you in our online forms, and any follow-up information during any screening or application process. We may collect information pertaining to your financial security, such as bank account balances and information pertaining to your spouse. Additional terms and conditions will apply, as agreed to between you and us, if we decide to proceed with your franchisee or strategic partner application.
Chats with Opdev . If you use the chat feature of a Site, we will collect all text and other data that you submit via that chat feature. If you use a chat feature while signed into your Opdev account, we may link the chat information to your account.
Meet With Us. If you enter your email, you will gain access to an integrated calendar that will allow you to schedule a meeting with a representative from Opdev .
ROI Calculator. We collect the information that you provide when using our ROI calculator. We use a third party to help us run the ROI calculator, and they may collect certain personal data about your use of that ROI calculator.
Marketing Communications. We may use your email and mailing address to send you promotional and other electronic and hardcopy communications. We may use third parties or service providers to deliver these communications to you. You may opt out of such emails by using the unsubscribe link in the email or contacting us at marketing@Opdev .com with “Unsubscribe” in the subject line. To opt out of other communications (e.g., postal marketing), please contact us as set forth in the “Contact Us” section below. Opting out of marketing communications does not opt you out of other, non-marketing communications from us.
Feedback. When you provide comments or feedback about our Sites, the content on the Sites, or our products or Services (“Feedback”), we will not treat that Feedback as confidential. We may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
If you choose to submit information pursuant to our #HowToSucceed campaign, you understand that we may use your picture, a video of you and your statements about Opdev publicly, including posted on our Site, without compensation owed to you. We may shorten or modify any statements you make or videos you provide in order to fit within a certain word count or time length for posting on our Site.
Business Contracts. If you enter into a business relationship with us, such as if you become a franchisee or strategic partner, we may use information collected about you in accordance with any contract agreed to between you and us. If your employer purchased access to our LMS platform, the personal data we received directly from that employer is used pursuant to our contract with that employer; however, any information we collect from users of the LMS (including employees of such employers) is used in accordance with this Privacy Policy.
Conferences and Tradeshows. If you attend one of our tradeshows, conferences or events, such as the Opdev Summit, we may collect information to confirm your registration, provide logistics-related information, for marketing purposes, or to send related promotional or future event offers.
If any part of the Site links you to other websites, those websites DO NOT operate under this Privacy Policy, but are linked for your convenience only. We recommend you read the privacy notices posted on those websites to understand their procedures for collecting, using, and sharing personal data.
Applying to Work With Opdev . To submit job application materials online to work or intern with Opdev , you will be redirected from our Sites to a website operated by BambooHR (or another service provider we may use to help us collect job application materials). You may be required to create an account with that vendor.
Events. When you sign up for an event or purchase hotel accommodations for an event, you are re-directed from our Site to a third-party website.
HubSpot. If you choose to visit the HubSpot Academy linked on our Sites, you will be re-directed to HubSpot’s website and you may be required to sign up for a HubSpot account to access academy courses.
Applying to Work With Opdev . To submit job application materials online to work or intern with Opdev , you will be redirected from our Sites to a website operated by BambooHR (or another service provider we may use to help us collect job application materials). You may be required to create an account with that vendor.
Evernote. If you choose to download an Evernote template linked on our Sites, you will be re-directed to Evernote’s website and you may be required to sign up for an Evernote account to download such template.
Podcasts. We use a third-party service provider to host our Opdev podcasts. When you visit the “how to succeed” website to listen to our podcasts, you are visiting a third-party website. Further, our third-party service provider syndicates our podcasts with Apple and Spotify- those third parties may receive data about your interactions with those podcasts.
We obtain data about individuals from our franchisees, strategic partners, referral sources, various third-party companies and public sources. We may combine that data with personal data or other data we collect from you. This enhances our existing data about our customers and Site users, improves our ability to contact you, and enhances our marketing capabilities. If you sign up for a Opdev event through a third-party website, that third party may share certain personal data about you with us. We also receive contact information of prospective new customers from current Opdev customers if someone refers a contact to us.
In addition to the uses described throughout this Privacy Policy, we use personal data for the following purposes:
As Stated or Agreed to at the Point of Collection. We may use personal data for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use personal data to respond to your questions, comments, or complaints. We may also use personal data as requested or consented to by you.
Administration. We use personal data for administrative purposes, such as managing your accounts, facilitating transactions and processing payments, refunds and credits, to inform our business strategies, to understand the demographics of our Sites and user preferences, for evaluating applications, to live chat with you, and to provide you materials or resources that you requested or that we think may interest you.
Management of Sites and Services Improvement. We use personal data to manage the Sites, such as troubleshooting problems, improving the content and functionality of the Sites, statistical and other analyses of the Sites, and to customize the Sites to you and our users. We may also use your personal data to improve our Services and customer service efforts, and to develop new products or Services.
Advertising and Notice. We may use personal data to send you promotions or to perform targeted advertising, to notify you of new Services, products or programs, to notify you of new features of our Sites, to notify you of changes to our Terms or this Privacy Policy, and for other similar communications.
To Protect Our Rights. We may use personal data to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Sites, or to other users of the Sites. We may also use personal data to address any U.S. DMCA claims or counterclaims, to seek business, financial or legal advice, and to respond to other legal requests.
We may share your personal data with the following categories of third parties and/or service providers:
Employees, Affiliates and Subsidiaries. We may share your personal data with our employees, affiliates and subsidiaries who have a need to know the information for our business purposes. If you are a Opdev employee or independent contractor, other employees can see certain information about you, such as contact information and employment information, through Opdev’s HR platform.
Franchisees. We may share personal data with our franchisees for our business purposes, such as to refer prospects and provide local training offerings.
Service Providers and Third Parties. We may share personal data with service providers that provide services for us. For example, we may share personal data with service providers that help us host and manage the Sites; maintain physical storage for paper files and documents; provide targeted advertising and other marketing; improve the content and functionality of the Sites; perform data analysis and statistical analysis; troubleshoot problems with the Sites; provide public relations; provide email services; provide payment processing services, support delivery of our Services and products, provide data processing; and support or provide the security of the Sites. We may also share personal data with third parties such as event sponsors, referral partners and other strategic partners of Opdev .
Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose personal data: (i) if we believe in good faith we are legally required to disclose that personal data, (ii) if we are advised to disclose personal data by our legal counsel, or (iii) when necessary to identify, contact, respond to or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Opdev or any other party.
Professional Advisors. We may share personal data with certain professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Opdev .
Other Users. In the event of a copyright infringement claim relating to the Site, we may share your personal data with any person or entity to whom the notice or counter-notice relates, in order to facilitate a prompt resolution of the copyright infringement claim. For U.S. residents only, copyright infringement notices and/or counter-notices will be treated in accordance with our Digital Millennium Copyright Act Policy In addition, if you are using Opdev Online, you may be able to chat with other users of Opdev Online, and they can see certain information about you through their accounts with Opdev Online.
Business Transactions. We may use your personal data in connection with certain business transactions, including the purchase, sale, merger, rental, combination or any other type of business acquisition, transfer, disposition and securitization of financing as well as in connection with any bankruptcy or similar insolvency proceeding, including as part of any related due diligence process.
Your Employer and Our Trainers. When you sign-up for Opdev Online to take courses provided through your employer, we may share certain information with your employer, such as whether you complete certain courses. When taking courses using Opdev Online, Opdev or you may share your personal data with Opdev employees, contractors, trainers or franchisees that are providing training to you through Opdev Online.
Other. We may share personal data with third parties or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal data to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Special Categories of Personal Data. “Special Categories of personal data” is any data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of identifying a person, data concerning health or a person’s sex life and/or sexual orientation, and any other data that is considered “sensitive data” under applicable law. Except as described above when you apply to work with Opdev , we do not knowingly collect Special Categories of personal data from you. Your provision of Special Categories of personal data, or other sensitive data, is not mandatory; however, we may not be able to consider you for employment with Opdev if you do not provide certain, requested information. Please refrain from sending Special Categories of personal data to us unless requested during your job application process.
Information from Minors. We do not knowingly collect personal data from persons under the age of majority in their place of residence (typically 18 years old). Do not send us personal data if you are under the age of majority. If you are a parent or guardian and you believe your child provided us with their personal data, you may contact us as described in the “Contact Us” section below and we will make good faith efforts to delete that data.
*Various countries throughout the world and various US states have different privacy laws giving their residents certain rights. These rights may include any of the following. We will comply with any rights you have under the laws of the country or state in which you reside that are applicable. We may require you to prove your identity before we respond to your request. If there are any country or state specific sections that apply to you at the end of this Privacy Policy, those sections shall control in the event they conflict with or are inconsistent with this section.
- Right of Access – You may have the right to be informed of and request access to the personal data we process about you. This may allow you to receive a copy of the personal data we process about you.
- Right to Rectification – You may have the right to request that we amend or update inaccurate or incomplete personal data about you.
- Right to Erasure (Deletion) – Under certain circumstances, you may have the right to request deletion of your personal data.
- Right to Restrict – Under certain circumstances, you may have the right to request that we temporarily or permanently stop processing all or some of your personal data.
- Right to Object – Under certain circumstances, you may have the right to object to our processing of your personal data (including profiling).
- Right to Data Portability – Under certain circumstances, you have the right to request a copy of your personal data in electronic format and further request that we send such personal data to you or to another party.
- Right To Withdraw Your Consent. In the event we ask for, and receive, your consent to process certain personal data about you, you may withdraw your consent at any time by emailing us at legal@Opdev .com, and we will comply with such request if required by applicable law. This provision also applies if we secured your consent for marketing purposes.
- Automated Decision Making. Opdev does not make any Automated Decisions on your behalf or about you without first obtaining your consent. In the event we secure your consent to do so, you have the right to object to the processing of personal data via Automated Decision making at any time by contacting us at legal@Opdev .com. “Automated Decision” means an automated decision made about an individual person by automated means without any human involvement, including profiling, often where meaningful logic is involved, that produces legal effects that significantly affects the involved individual.
- Non-Discrimination. You may have the right to not receive discriminatory treatment for exercising your rights under applicable privacy laws. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this provision.
- Sale of Personal Data. Various states and countries define “sale” of personal data differently. If Opdev “sells” your personal data, as such term is described under applicable data privacy law, you may have the right to opt out of the sale of your personal data. You may submit your opt-out request here: DO NOT SELL MY PERSONAL INFORMATION
- Right to Lodge a Complaint. You have the right to lodge a legitimate complaint with the applicable supervisory authority.
How to Exercise Your Rights. To exercise any rights you have under privacy laws that apply to you, please contact us. We will respond to your request within a reasonable period of time. Requests may be denied pursuant to applicable law or if certain exceptions under applicable law apply. Ways to contact us include:
Opdev will not be able to provide some Services or provide you with access to certain parts of the Sites without processing certain personal data. For example, we need to collect login and contact information from you when you access certain parts of our Sites, and we need to collect certain contact information from you when you make a purchase.
Opdev will only keep your personal data for so long as it has a reasonable business purpose for doing so or where we are required to keep it by applicable law.
Opdev may collect, use, share, transfer, create and otherwise Process de-identified and aggregated information for any purpose in compliance with applicable laws. Opdev is the sole and exclusive owner of such de-identified and aggregated information, including if Opdev de-identifies personal data so that it is no longer considered personal data under applicable laws.
We are active on social media. The Sites may allow you to connect and share data with social media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such social media platforms to facilitate those communications and features. The Sites may also use advertising networks and services offered by social media platforms to deliver advertising content. Use of these services requires the applicable social media platforms to implement cookies or pixel tags to deliver ads to you while you access a Site.
Anything you post on social media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our social media pages any comments or content that you post on our social media pages. Your use of social media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Privacy Policy. We encourage you to review those policies and terms before using any social media features provided through our Sites or third-party websites.
If you access the Sites from outside the United States, please be aware that personal data may be transferred to, stored in, and Processed in the United States. Certain governmental authorities may not consider the level of protection of personal data in the United States to be equivalent to that required in other jurisdictions.
The European Union (EU) and the United Kingdom (UK) specifically have determined that the United States does not have an adequate level of protection for personal data. Further, certain countries require that personal data transferred to other countries can only occur if the recipient resides in a country with materially similar data protection laws. Given that the U.S. does not have data protection laws in every state that provide a materially similar level of protection of personal data as certain other countries, Opdev uses (1) the Standard Contractual Clauses in transferring personal data of EU or UK citizens across international borders or other approved methods by the EU, and (2) other data transfer agreements that may be required by other countries in order to transfer personal data across country borders. You may request a summary of the appropriate safeguards or seek inquiries regarding such safeguards by contacting us at legal@Opdev.com. We will respond to your request or inquiry within a reasonable time period.
The CCPA and Personal Information. If you are a California resident, you may have additional rights (or different rights than described above) under the California Consumer Privacy Act, as amended, and its implementing regulations (the “CCPA”). Although the terms “personal information” and “personal data” can often be used interchangeably, in this section when referring to “personal information”, we are referring to how that term is defined under the CCPA.
Collection, Source, Purpose and Sharing of Personal Information. To view the categories of personal information we collect, the sources from which personal information is collected, the purposes for which we collect personal information, and the categories of third parties and/or service providers with whom we share personal information, please click on the applicable hyperlink in this paragraph, or see the applicable section in this Privacy Policy above.
In the last 12 months we sold, or disclosed your personal information for a business purpose, if indicated below. See the section above titled “Personal Data We Collect” for more detail on the type of personal information in each category.
Category of Personal Information
Personal Information is / was sold in the last 12 months
Personal Information is / was disclosed for a business purpose in the last 12 months
Identifiers
Yes
Yes
Protected Classifications
No
Yes
Commercial Information
Yes
Yes
Internet Activity
Yes
Yes
Sensory Data
No
Yes
Employment Information
No
Yes
Education Information
No
Yes
Inferences
No
Yes
We do not sell your personal information to other companies for money. We do share personal information with certain companies to help us and them advertise to you, and as part of our strategic partner and referral relationships. Under California law, this sharing of personal information is considered the sale of personal information.
California residents may direct us not to “sell” their Personal Information at any time (this is your right to “opt-out”).
DO NOT SELL MY PERSONAL INFORMATION
Your Rights to Access and Deletion. California residents have the right to request certain information or request deletion of their personal information. Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their personal information:
Right to Access. You have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of personal information we collected from you, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting or selling your personal information, (d) the categories of third parties with whom we shared your personal information, (e) the specific pieces of personal information we collected from you (i.e. “data portability”), and (f) a list of categories of personal information we sold or disclosed for a business purpose in the last 12 months.
Right to Request Deletion. You have a right to request that we delete personal information we collected from you. We will comply with such requests, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
How to Exercise Your Rights of Access and to Request Deletion. To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:
Verifiable Consumer Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information.
When we receive your request, we may ask you to provide additional information to verify your identity, including personal information. We will only use personal information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we may decline to comply with your request, and will let you know why.
When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select the format to provide such personal information. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this section.
Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with Opdev, and (c) directly confirm with Opdevthat you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf. Furthermore, a parent or legal guardian may make a request on behalf of their child.
California Shine The Light. Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom the Opdev may have disclosed your personal information within the past year for direct marketing purposes; and (b) a description of the categories of personal information disclosed. Please contact us as set forth at the end of this Privacy Policy to receive this information.
CALIFORNIA’S “DO NOT TRACK” REQUIREMENT. WE DO NOT REACT TO “DO NOT TRACK” OR “DNT” BROWSER SIGNALS AT THIS TIME.
Australia. This Section provides additional terms and information that apply to residents of Australia. If you are not satisfied with our response to a question, you may contact the Australian Information Commissioner at:
Brazil. This Section provides additional terms and information that apply to residents of Brazil, pursuant to Brazil’s General Personal Data Protection Law (“LGPD”). In lieu of the rights described in the main body of this Privacy Policy, residents of Brazil have the following rights under the LGPD:
- I – confirmation of the existence of the processing;
- II – access to personal data;
- III – correction of incomplete, inaccurate or out-of-date personal data;
- IV – anonymization, blocking or deletion of unnecessary or excessive personal data or personal data processed in noncompliance with the provisions of this the LGPD;
- V – portability of the personal data (excluding anonymized data) to another service provider or product provider, by the means of an express request, pursuant with the regulations of the national authority, and subject to commercial and industrial secrets;
- VI – deletion of personal data processed with the consent of the data subject, subject to the exceptions of the LGPD;
- VII – information about public and private entities with which the controller has shared personal data;
- VIII – information about the possibility of denying consent and the consequences of such denial; and
- IX – revocation of consent, including if we are not complying with the LGPD.
You also have the right to petition, against Opdev, before the national authority if you believe we are not complying with the LGPD.
Sales Training and Performance Improvement Organization
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