The Expert Institute Group, LLC ("The Expert Institute," "TEI," "we," and "us") has provided this privacy policy (“Privacy Policy” or “Policy”) to explain how TEI obtains, utilizes, shares and safeguards information collected from you. This Privacy Policy applies to information that TEI may collect from you or that you may provide on the website owned and controlled by TEI, www.expertinstitute.com (the "Website"). This Privacy Policy supplements but does not replace other applicable terms and conditions that you have agreed to related to TEI. To the extent that specific terms and conditions conflict with this Privacy Policy, the applicable terms and conditions shall govern.
If you are a California resident, please also see Appendix A “Privacy Information for California Residents” for supplemental California-specific privacy information.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it, including any rights you may have. By visiting or using our Website, or by uploading or submitting any information through the Website to The Expert Institute, you consent to the collection, use and transfer of your information pursuant to the terms of this Privacy Policy. If you do not agree with our Policy, your choice it not to use our Website. This Policy may change from time to time. Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
INFORMATION COLLECTION
Information We Collect About You. In the course of using our Website, TEI may ask users for their name, contact information, employment information, biographical information, information regarding your areas of expertise, statement of qualifications, fee schedule, references, and any feedback you provide, or any other information you provide through the Website.
Information Collected Automatically. We may collect additional information from you automatically. This information is referred to herein as "Usage Information." Such Usage Information may include information that we automatically collect when you use the Website, such as your IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, similar information concerning your use of the Website, and information about your online activities over time and across third-party websites or other online services. As you navigate through and interact with our Website, we may use automatic data collection technologies, such as cookies, to collect such Usage Information. Cookies are small packets of data that a website stores on your computer's hard drive so that your computer will "remember" information about your visit. We use cookies to help us collect Usage Information and to enhance your experience using the Website. For example, our Website includes cookies used by Google Analytics Advertising Features. If you want to disable the use of cookies by the Website, you may be able to turn that feature off on your computer. However, if you decide not to accept cookies from us, the Website may not function properly. For more information on deleting or controlling cookies, please seewww.aboutcookies.org. For more information on how Google Analytics collects and processes data, please see http://www.google.com/intl/en/policies/technologies/ads/.
Information We Receive from Other Sources. From time to time, we may also receive information about you from our third-party service providers, affiliates, customers, and partners, including our marketing, conference, and advertising partners and social media networks. We may also collect information about you from publicly available sources, including social media or information transmitted by other users of the Website or third parties.
INFORMATION USAGE
The personal information that you provide to TEI may be stored, processed, and used by TEI and its affiliates for the following purposes:
- To provide our products and services and present our Website and its contents to you;
- To provide you with information that you request from us, including updates, notifications, and details of any offers or promotions;
- To provide you with text communications which may include marketing materials with your consent;
- To provide you with notices about your account;
- To comply with our legal obligations or requests from law enforcement and government agencies;
- To analyze information for trends and statistics;
- To enforce or protect the terms of our services, rights, property, safety, or that of our users or third parties;
- As part of due diligence for, or the consummation or, a transaction involving the merger, sale, divestiture, or other transaction involving the equity or assets or TEI;
- To match you with consulting opportunities if applicable;
- To match an expert with your consulting requirements if applicable;
- To provide you with information about our products and services or to send you surveys, promotional materials, newsletters, or special offers; and
- For any other purpose with your consent.
DISCLOSURE OF YOUR INFORMATION
TEI may disclose your information with third parties as follows:
- With our affiliates;
- With experts or clients, as the case may be, in an effort to make an engagement possible;
- To our partners and service providers that assist us in providing services offered through the Website, including, but not limited to, services related to processing payments, background checks, providing marketing assistance, information technology support, and customer service;
- To the extent permitted by law, we may also disclose personal information and the Usage Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of The Expert Institute or others;
- In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the personal information and Usage Information may be disclosed or a part of the transferred assets; or
- In accordance with the consent you’ve provided.
In addition, in an ongoing effort to better understand users of our Website, we might analyze the Usage Information in aggregate form in order to operate, maintain, manage, and improve the Website. This aggregate information does not identify you personally. We may share this aggregate data for any legal purpose. For example, we may disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
YOUR CHOICES
You can opt out of Google Analytics by:
Changing your settings at Google’s Ad Settings at: http://www.google.com/settings/ads
Installing an opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/
Adjusting the settings on your web browser: See http://www.google.com/intl/en/policies/technologies/managing
Opt-Out. You may choose not to receive marketing materials regarding from TEI by simply notifying TEI at info@expertinstitute.com or by clicking the “unsubscribe” link at the bottom of the email communication. Upon receipt and processing of an “opt-out” request, TEI will, within a commercially reasonable amount of time, remove your information from any future unsolicited marketing communications. Your request regarding marketing materials will not apply to information that you request to receive or that is transactional.
If you are a California resident, please also see Appendix A titled “Privacy Information for California Residents” for further supplemental information about additional rights you may exercise.
LINKS TO OTHER WEBSITES
The Website may contain links to other websites or may otherwise provide access to other sites that are not operated or controlled by TEI. TEI is not responsible for the information collected on any such sites, the privacy policies or terms of use on those sites. We encourage you to review any privacy policies or terms of use posted on any of these sites. You agree to look solely to the third party site owners in the event of any claims related to use of your information on those sites and waive any such claims against TEI.
INFORMATION SECURITY
We use commercially reasonable physical and technological security measures designed to protect your information both online and offline from unauthorized access, processing, accidental loss, and damage. However, we cannot guarantee the security of data sent over the internet.
POLICY UPDATES
The Expert Institute may update this Policy from time to time. We will notify you of any material changes by posting a notice on the Website. Any changes to our Privacy Policy will become effective upon notice. Your continued use of the Website and membership in The Expert Institute will indicate your agreement to such changes.
CONTACT US
We welcome all requests, suggestions and questions concerning our use of your information. All such communication should be directed to:info@expertinstitute.com.
Appendix A
Privacy Information for California Residents
This Appendix applies solely to individuals who reside in the State of California (“consumers” or “you”). This Appendix complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Appendix. This Appendix applies to consumer information collected by the Expert Institute both through the Website and offline. This Appendix does not apply to personal information outside the scope of the CCPA.
1. The Expert Institute as a Service Provider
When The Expert Institute acts as a service provider for its business customers, it collects some personal information on behalf of its customers subject to its contractual obligations. When The Expert Institute acts as a service provider for its business customers, it follows the instructions of its customer on how to process personal information on its customer’s behalf. The provisions of this Appendix do not apply to the personal information that The Expert Institute processes on behalf of our business customers.
2. Disclosures
In addition to any of the practices described above, the below chart lists the categories of personal information that TEI may collect or has collected in the past 12 months and how it discloses such information. In addition, we may also disclose your personal information to a third party, upon your request or at your direction. To the extent you use TEI products or services and agree to have your personal information shared with others to use the products or services, we shall share your personal information accordingly. For example, if you are an expert, we may match you with our client customers through our services.
Categories of Personal Information
Identifiers. This may include a real name, alias, address, email address, phone number, online identifier, IP address, account username and password, or other similar identifiers.
Categories of Third Parties with whom Personal Information is Disclosed
Identifiers. Entities that we are legally required to share with pursuant to law or for legal proceedings; service providers; prospective purchasers of our business; our affiliates; analytics and advertising partners; and outside auditors and lawyers.
Categories of Personal Information
Internet and network information. This may include information on your interaction with a website, application, or advertisement, such as browsing history and how you use your account.
Categories of Third Parties with whom Personal Information is Disclosed
Internet and network information. Entities that we are legally required to share with pursuant to law or for legal proceedings; service providers; our affiliates; analytics and advertising partners; and outside auditors and lawyers.
Categories of Personal Information
Device information. This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information.
Categories of Third Parties with whom Personal Information is Disclosed
Device information. Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; and service providers.
Categories of Personal Information
Other information you submit to TEI or its service providers. This may include requests or communications you submit to us, emails, ratings, or any other communications.
Categories of Third Parties with whom Personal Information is Disclosed
Other information you submit to TEI or its service providers. Entities that we are legally required to share with pursuant to law or for legal proceedings; service providers; our affiliates; outside auditors and lawyers.
Categories of Personal Information
Inferences about you. This may include information about your preferences, characteristics, predispositions, behavior, or other trends that help us identify which products or services you may be interested in.
Categories of Third Parties with whom Personal Information is Disclosed
Inferences about you. Entities that we are legally required to share with pursuant to law or for legal proceedings; service providers; our affiliates; and analytics and advertising partners.
Categories of Personal Information
Professional or employment related information. This may include work history, technical skills, educational background, professional certifications, licensing and registrations, and language capabilities.
Categories of Third Parties with whom Personal Information is Disclosed
Professional or employment related information. Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; and service providers.
3. Sources of Information
TEI collects personal information from the following sources: you, your agents, through our third-party service providers, your references, your employer, and public sources, such as social media networks.
4. Sensitive Personal Information
Sensitive Personal Information consists of: (1) government identifiers, such as Social Security Numbers and drivers’ license numbers; (2) account log-in information (e.g., financial account or credit card numbers in combination with any required access codes or passwords); (3) precise geolocation information; (4) racial or ethnic origin, religious or philosophical beliefs, or union membership; (5) content of postal mail, email, and text messages, unless the business is the intended recipient of the subject communications; (6) genetic data; and (7) biometric information that uniquely identifies a consumer or information concerning a consumer’s health, sex life, or sexual orientation. To the extent we collect information that is considered Sensitive Personal Information under CCPA, it is listed in the chart above.
5. Uses of Personal Information
In addition to any of the practices described above, TEI may use personal information for the following purposes:
To provide our products and services and present our Website and its contents to you;
To provide you with information that you request from us, including updates, notifications, and details of any offers or promotions;
To provide you with text communications which may include marketing materials with your consent;
To provide you with notices about your account;
To comply with our legal obligations or requests from law enforcement and government agencies;
To analyze information for trends and statistics;
To enforce or protect the terms of our services, rights, property, safety, or that of our users or third parties;
As part of due diligence for, or the consummation or, a transaction involving the merger, sale, divestiture, or other transaction involving the equity or assets or TEI;
To match you with consulting opportunities if applicable;
To match an expert with your consulting requirements if applicable;
To provide you with information about our products and services or to send you surveys, promotional materials, newsletters, or special offers; and
For any other purpose with your consent.
6. Sale and Sharing of Personal Information
In the past twelve (12) months, we have not sold personal information. To ensure we can share our products with you and tailor our advertisements, we do allow some of our advertising partners to use cookies, pixels, and other technologies to collect personal information on our website or services, which may constitute Sharing under CCPA. Such tracking technology can collect personal information about you that can be used by us and our authorized third-party partners and service providers.
In the preceding 12 months, we have Shared the following categories of personal information for the purpose of showing you ads about The Expert Institute’s services and products:
Identifiers;
Internet or other similar network activity; and
Inferences.
To exercise the right to opt-out of the sharing of personal information, you (or your authorized representative) can opt-out of the sharing of personal information by submitting a request to us by visiting the following link: [DO NOT SHARE MY PERSONAL INFORMATION] or by contacting us utilizing one of the methods below.
[In addition, some browsers offer you the ability to opt out of the sharing of your personal information by turning on a Global Privacy Control. You can turn on a Global Privacy Control in your web browser or browser extension or by visiting https://globalprivacycontrol.org/. Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa for more information on valid Global Privacy Controls. At this time, we endeavor to respond to browser-based opt-out signals sent through the Global Privacy Control.]
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request. To the extent you direct us to or consent to our disclosure of personal information to third parties, such disclosure does not constitute “sharing” or “selling.” Further, our sharing of personal information we have collected from publicly available sources, does not constitute “sharing” or “selling”.
7. Data Retention
We will retain your personal information for no longer than is necessary for the purpose stated in this Privacy Policy, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The data storage period may vary depending on the scenario, product, and service. The standards we use to determine the retention period are as follows: the time required to retain personal information to fulfill business purposes, including providing products and services; maintaining business records; controlling and improving the performance and quality of the Websites; handling possible customer queries or conducting assessments of customer complaints; whether you agree to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention.
8. California Residents’ Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. In certain circumstances, you may have the following rights:
The right to request that TEI disclose certain information to you about its collection and use of your personal information, including:
The categories of personal information TEI collected about you;
The categories of sources from which TEI collected personal information from;
TEI’s business or commercial purpose for collecting that personal information;
The specific pieces of personal information TEI collected about you;
Whether TEI sold or shared any your personal information;
The categories of third parties with whom TEI discloses that personal information; or
The specific pieces of personal information TEI collected about you.
The right to request that TEI delete some or all of the personal information that it has collected from you and retained, subject to a number of exceptions.
The right to request that TEI amend your personal information if it is inaccurate or outdated, such as an outdated address. TEI is not required to correct information that is subjective, such as an opinion.
The right to limit our non-essential use of your Sensitive Personal Information, if applicable.
The right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, TEI will not:
Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
The right to opt out of the sharing of your personal information. You may have the right to direct us not share personal information we have collected about you to third parties.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices or rates. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
9. Exercising Your Rights
To exercise your rights described above, please submit a verifiable consumer request to TEI by either:
Calling us at 888-858-9511
Email us at info@expertinstitute.com
Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual. The verifiable consumer request must:
Provide sufficient information that allows TEI to reasonably verify you are the person about whom it collected personal information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
TEI may not be able to fulfill your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm the personal information relates to you. To verify your identity, TEI may request up to three pieces of personal information about you, and TEI reserves the right to take additional steps as necessary to verify your identity if it has reason to believe a request is fraudulent.
10. Response Timing and Format
TEI endeavors to respond to a verifiable consumer request within 45 days of its receipt. If TEI requires more time (up to 90 days), it will inform you of the reason and extension period in writing. TEI will deliver the written response by mail or electronically, at your option. The response TEI provides will also explain the reasons it cannot comply with a request, if applicable. For data portability requests, TEI will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. TEI does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If TEI determines that the request warrants a fee, it will tell you why it made that decision and provide you with a cost estimate before completing your request.
11. Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us through the information provided above.
28975959.10