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This Policy was last updated on November 1, 2022 SkillsBuild, an IBM initiative (IBM) (sometimes, "we," "us" or "our") is committed to protecting the data privacy of all individual and organizational users. This policy discloses how IBM will collect, use, and disclose information that we gather related to your organization's engagement with our online learning platform (the "Services").
1. How and Why We Collect and Use Personal and Other Information
In order to operate the Services and to maximize your experience, we may collect and use information, some of which may be considered your personal information. In general, we use your personal information to serve you best, including to create your account, to maintain, operate, and improve the Services, to personalize your experience, and to administer the Services. Please note that you may choose not to provide us with certain information; by doing so, however, you may not be able to receive the full range of Services from us. We collect information in the following ways:
1. Information Provided By You. You may provide us with information, some of which may be personal information, when you interact with the Services in the following ways:
2. Information Provided By Your School or SkillsBuild for Students Administrator. Your school or SkillsBuild Administrator may provide us with personal information about you (e.g., your name, name of your school, parental consent to use the Service), and, if applicable, after it has obtained your parent or legal guardian's consent to help us register your account and to provide the Services. We will combine this with the information we collect from you. Your school or SkillsBuild Administrator can only register an account for you with your consent and, if required by law, your parent’s consent. Your school or SkillsBuild Administrator must collect your registration information in an appropriate manner and be responsible for properly entering the information into your account. If your school or SkillsBuild Administrator registered your account and you wish to update your account registration information to correct any inaccuracies, then you must contact your school or SkillsBuild Administrator to modify your account registration. If you do not approve of how your account is registered or modified by your school or SkillsBuild Administrator, you can close your account.
5. Automatic Collection.When entering one of our websites, or using an online service, we will record information necessary to provide you with access, for the operation of the website and for us to comply with security and legal requirements in relation to operating our site, such as passwords, IP address and browser settings. We also collect information about your activities during your visit in order to personalize your website experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, products and services.
6. Information from Social Media Networks and Other Third Parties.Our websites utilize a social media aggregation tool that crowdsources user-generated content from social media platforms. If you upload content to social media and use a hashtag (pound symbol) followed by string of words associated to a SkillsBuild media campaign, you are authorizing us to share and display your content on our websites. You can choose to not have your information shared or displayed in our website by not posting content with hashtags related to SkillsBuild media campaign.
2. Data Collection Technologies / Form of processing
We may contract with analytics partners to track, analyze, and report data about the use of the Services and to analyze and optimize the performance of the Services ("Analytics Partners").
Information that we collect via the data collection technologies described in this section may be linked to other information about you and may be considered personal information. We use the technologies described in this section, alone or in combination, to understand user behavior, help diagnose problems, recognize repeat visitors, and facilitate your access to and use of the Services.
Cookies: Cookies are text files containing small amounts of information that are downloaded to your computer or mobile device when you visit a website and stored within your browser. Cookies are then sent back to the originating website on each subsequent visit to that website or to another website that recognizes those cookies. Some cookies on our Services collect IP and MAC addresses, which may be considered personal information in some jurisdictions. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at www.allaboutcookies.org The cookies used on this website can be categorized in the following ways:
Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to use the Services and its features.
Category 2: Performance Cookies
These cookies collect information about how you use the Services (such as which pages you go to most often and if you receive error messages). In general, these cookies do not collect information that directly identifies you. However, some such cookies may collect GeoIP or other identifiers that may be considered personal information in some jurisdictions.
Category 3: Functionality Cookies
These cookies allow Services to remember choices you make such as language or the region you are in. These cookies can also be used to remember changes you have made to customize the Services.
Web beacons: Certain pages on the Services may contain web beacons. Web beacons allow third parties to obtain information, such as the IP address of the computer that accessed the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser used to view the page, and the information in cookies sent by the third party.
Web Storage: We may use local storage, such as HTML5 localStorage and indexedDB, to enhance user experience by, for example, storing your user preferences and settings (e.g., volume/mute) in connection with animated content on the Services. Local storage is similar to browser cookies but can store data more complex than simple text. By itself, local storage cannot do anything to or with the data stored on your device.
3. How We Share or Disclose Your Information with Others
Where appropriate and reasonable, IBM may also share your personal information with selected partners to help us provide you, or the school you attend, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take reasonable steps to ensure proper data handling processes.
If IBM decides to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is IBM's practice to require appropriate protection for personal information in these types of transactions.
Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of IBM, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.
We may share certain information with your school or SkillsBuild Administrator, including but not limited to the content of your Submissions and data related to the use of the Services such as badges, courses completed, and credentials.
4. Information Security and Accuracy
We intend to protect your personal information and to maintain its accuracy. IBM implements reasonable physical, electronic, administrative, managerial and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt certain personal information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure. Of course, we cannot guarantee that your communications with the Services will never be unlawfully intercepted or that your data will never be unlawfully accessed by third parties. Any transmission of information is at your own risk.
5. Retention Period
We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.
For Brazilian Data Privacy ("LGPD") purposes we will retain your personal information for ten (10) years. However, you can request to delete your personal information at any time as Section 6 below.
6. Your Information and Data Rights
You may access and change some of your personal information by editing your profile at any time. At any time, you can review, change, or delete your personal information by sending us an email at [email protected]. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
The processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"). You have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.
If the processing of your personal information is subject to the LGPD, in addition, you have the right to request: (i) confirmation of the existence of the treatment; (ii) anonymizing, blocking or deleting; (iii) data portability to another service or product provider; (iv) elimination of personal data processed with your consent; (v) information about public and private entities with whom the controller shared your personal information; (vi) information about the possibility of not providing your consent and the consequences of the refusal; (vii) revocation of consent. Under the LGPD, you also have the right to object to the processing when it is not based on consent and when the data is processed illegally, as well as the right to petition the National Data Protection Authority.
In the event that you consider our processing of data related your use of the Services not to be compliant with the applicable data protection laws, you can contact us or lodge a complaint:
7. Student Privacy
We are committed to protecting the safety and privacy of young people using the Internet. We do not knowingly collect personal information from children under the age required in the relevant jurisdiction (for example, in the United States, age 13) unless and until we have received consent and authorization from the proper authority to use the Services and for us to collect such information. If you become aware that we have collected personal information from a child without proper parental consent, please notify us promptly at [email protected] If we become aware that a child under the applicable age has provided us with personal information without proper consent, we will take steps to remove such personal information.
8. International Transfer
The international footprint of IBM involves a large number of transfers of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information, in connection with which IBM takes various measures, including:
9. How to Contact Us
Attn: Privacy Office (SkillsBuild for Students)
1 New Orchard Road
Armonk, NY 10504
10. California Residents
0. Disclosures about your Personal Information
Collection, Business Purposes and Disclosure of Personal Information
As described above, to support your use of SkillsBuild, we may have collected and disclosed, for a business purpose, information from the following categories in the last twelve months:
this includes Personal Information defined by the CCPA as:
Sources and Sharing of Personal Information
As explained above, we may collect Personal Information directly from you, automatically from your device, and/or from your school. We may share information about you with our subsidiaries, suppliers and, where appropriate, with selected partners to help us provide you, or your school, products or services, or to fulfill your requests, or with your consent.
1. Rights Relating to Your Personal Information
In addition to the data rights mentioned above, as a California resident, you have the right to:
Know your Personal Information
You can request specific pieces of Personal Information, or information about the categories of Personal Information that IBM holds about you by submitting a request to https://www.ibm.com/privacy/portal/contact/us-en.
Request Deletion of your Personal Information
You can request the deletion of the Personal Information that IBM holds about you by submitting a request to https://www.ibm.com/privacy/portal/contact/us-en.
If you choose to exercise any of these rights, we will not deny goods or services to you or provide different quality of services.