Last Updated: May 31, 2018
Like most website operators, Grayline collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Grayline’s purpose in collecting non-personally identifying information is to better understand how Grayline’s visitors use its website. From time to time, Grayline may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
Grayline also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on graylinegroup.com blogs/sites. Grayline only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below, except that commenter IP addresses and email addresses are visible and disclosed to the administrators of the blog/site where the comment was left.
Gathering of Personally-Identifying Information
Certain visitors to Grayline’s websites choose to interact with Grayline in ways that require Grayline to gather personally-identifying information. The amount and type of information that Grayline gathers depends on the nature of the interaction. For example, we ask visitors who sign up at graylinegroup.com to provide a name and email address. Those who engage in transactions with Grayline, such as subscribing to our paid information products, are asked to provide additional information, including as necessary the personal and financial information required to process those transactions. In each case, Grayline collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with Grayline. Grayline does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities or from using our services.
Grayline may collect statistics about the behavior of visitors to its websites. Grayline may display this information publicly or provide it to others. However, Grayline does not disclose personally-identifying information other than as described below.
Protection of Certain Personally-Identifying Information
When you use the Services, you may set up your personal profile, send messages, perform searches and queries, and transmit information through various channels, depending on the category of user you are registered as, and as permitted by the functionality of our websites. The information we gather from users enables us to personalize and improve our services and allows users to set up a user account and profile through the Services.
The Personal Information you provide is used for such purposes as responding to your requests for certain information and services, customizing your experience, and communicating with you about the Services. We also use Personal Information for creating your individual account, processing payments, customizing your experience, and for sending you notifications via the Services (“Notifications”).
Your Email Address
If you provide us your email address, we may send you email communications. Web beacons may also be used in some of our emails to let us know which emails (and which links within those emails) have been opened by recipients. This allows us to gauge the effectiveness of our customer communications.
Grayline uses this type of aggregate data to enable us to figure out how often users use parts of the Services, to develop preferences and learning profiles, to deliver content, and target content and resources to our users so that we can make the Services appealing and relevant to as many users as possible, and customize and improve those Services.
We are able to deliver our Services and improve content for you by using this information to understand how you use and interact with our Services and the content, people or things you’re connected to and interested in on and off our Services.
We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits and troubleshooting activities.
We use your information to send you marketing communications, to send targeted learning content to you, and communicate with you about our Services and let you know about our policies and terms. We also use your information to respond to you when you contact us.
As part of our use of information, we may provide aggregate information to our partners (in a non-personally-identifiable format) about how our users use our site. We share this type of statistical data so that our partners also understand how often people use our partners’ services and the Services to help provide you with an optimal online experience. We may link usage information to Personal Information that we collect through the Services, but we will only use this linked information internally (for example, to customize your experience), and will not disclose it in linked format to third parties.
Resale of Personal Information
We neither rent nor sell your Personal Information; we may share your Personal Information as described in this policy. Again, please note this references “Personal Information.”
Businesses We Do Not Control
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Examples include sending email, analyzing data, processing payment, and providing user services. Unless we tell you differently, Grayline’s agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us.
If Grayline, or some all of its assets were acquired or otherwise transferred, or in the unlikely event that Grayline goes out of business or enters bankruptcy, user information may be transferred to or acquired by a third party.
Protection of Grayline and Others
We may release Personal Information when we believe in good faith that release is necessary to comply with the law (such as to comply with a subpoena); enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Grayline, our employees, our users, or others. We will try to give you notice if we release information for these reasons, but please understand that we reserve the right not to, as it may not be practical, legal, or safe to do so.
Opt Out Policy
You can always opt not to disclose information, even though it may be needed to take advantage of certain of our features.
You may request deletion of your Grayline account by contacting us at firstname.lastname@example.org. Please note that some unrevised information may remain in our records after revision of such information or deletion of your account, or in cached and archived pages. Some information may remain viewable elsewhere to the extent that it was copied or stored by other users. We may use any aggregated data derived from or incorporating your Personal Information after you delete your information, but not in a manner that would identify you personally.
We will retain your Personal Information for as long as your account is active or as long as needed to provide you the Services; we also may retain and use your information as we deem it necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.
Application Outside the United States
When you use the Services, you are consenting to have your data transferred to and processed in the United States. All of Grayline’ servers are currently in the United States, and we aren’t able to process your information within the borders of any other country. Given this limitation, if your use of the Services or disclosure of certain information to Grayline would violate any law that is applicable to you, your right to use the Services and/or disclose such information is revoked, as it is wherever use of the Services is prohibited by law (as described in the Terms of Service).
Notwithstanding the foregoing, Grayline uses reasonable efforts to comply, and have its third party processors comply, with the European General Data Protection Regulation (“GDPR”). If you are a user accessing the Services from the European Union, Switzerland and the United Kingdom, GDPR gives you certain rights with respect to your information, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal information;
- Request correction or deletion of your personal information;
- Object to our use and processing of your personal information;
- Request that we limit our use and processing of your personal information; and
- Request portability of your personal information.
- EU individuals also have the right to make a complaint to a government supervisory authority.
Grayline will keep your personal information only for the period required unless you authorize except if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of users of Grayline’s services or the public, or (e) protect against legal liability.