Most web browsers can be set to tell you when a cookie has been sent to you and give you the opportunity to refuse that cookie. Information about disabling cookies from your browser and deleting all cookies currently stored on your computer may be found here: http://www.allaboutcookies.org/manage-cookies/ 

 
Refusing a cookie may in some cases preclude you from using or negatively impact the display or function of our Website or certain areas or features of our Website. There are numerous resources on the Internet that can provide more information about how cookies work and how you can manage them. One very informative not-for-profit site is www.allaboutcookies.org. 

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2. Clear GIFs 
When you visit the Website, we may also use “Clear GIFs” (a.k.a. “web beacons” or “pixel tags”) or similar techniques in our Website and/or in our communications with you. A clear GIF is typically a one-pixel, transparent image located on a web page or in an e-mail or other type of message that helps us to verify an individual’s viewing or receipt of a web page or message. Clear GIFs allow us to know whether you have viewed a web page prior to visiting our Website and may enable us to relate such information to other information, including your Personal Information. We use information provided from clear GIFs to allow more accurate reporting, improve the effectiveness of our marketing and make the Website better for our users. 

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3. IP address and Clickstream data 
Our servers automatically collect data about your Internet Protocol address when you visit us. When you request pages from our Website, our servers may log your IP address and sometimes your domain name. Our servers may also record the referring page that linked you to us (e.g. another website or a search engine); the pages you visit on this Website; the website you visit after this Website; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Website or a referral website; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our servers and to administer our Website. Such information may also be used to gather broad demographic information, such as country of origin and Internet service provider. Personal Information (including IP addresses) is not used to facilitate contact with users who have not provided their contact details to the Foundation. Your IP address may be used to identify the clickstream that led you to our site; however, Personal Information is not shared with any third-party marketing companies. 

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Your Privacy Rights 

 

Depending on your jurisdiction of residence, under applicable privacy laws, depending on residence, you may be entitled to exercise some or all the following rights, regarding our collection, use, disclosure, and sharing of your Personal Information:  

 

For California residents, the California Consumer Privacy Act (“CCPA”) specifically provides the following rights regarding your Personal Information which can be exercised directly or, where permitted in certain cases, through an authorized agent: 

 

 

Right to Know 

 

You may request, (1) the categories of Personal Information we have collected about you, (2) the categories of sources from which the Personal Information was collected, (3) the business or commercial purpose for collecting, selling, or sharing this Personal Information, (4) the categories of third parties with whom we share or have shared your Personal Information, (5) as applicable, the categories of Personal Information that we have shared about you and the categories of third parties to whom the Personal Information was shared, by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold or shared, (6) the categories of Personal Information that we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose, and (7) a list of the specific third parties to whom we sell personal data. 

 

Right to Access 

 

You may receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person. 

 

Right to Portability 

 

You may receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person. 

 

Right to Confirm 

 

You may confirm if we are processing your Personal Information and to access your Personal Information, as just stated above. 

 

Right to Delete 

 

You may request that we delete Personal Information that we collected from you, subject to certain exceptions. 

 

Right to Correct 

 

You may request we correct inaccurate Personal Information (to the extent such an inaccuracy exists) that we maintain about you. 

 

Rights to opt in/opt out 

You have the right to “opt in” and/or “opt out” of certain of our uses of your Personal Information. For example, you may have the opportunity to choose whether you would like to receive correspondence from us and/or third-party service providers. Your Personal Information will not be shared with third-party service providers unless you give consent. You will have the opportunity to opt out of the Foundation’s promotional e-mails by clicking the "opt out" or “unsubscribe” link in the e-mail you receive. You can also request this by sending an e-mail to info@csodfoundation.org specifying whether (i) you would like to opt out of receiving promotional correspondence from the Foundation in general, or just via e-mail, post and/or by phone, and/or whether (ii) you would only like to opt out of certain Foundation e-newsletters or correspondence. 

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Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. 

 

Right to Non-Discrimination 

 

You have the right to not be discriminated against or retaliated against for exercising any of the above rights. 

 

Right to Appeal 

 

You may, depending on your jurisdiction of residence, have the right to appeal our refusal to act on a request. 

 

To protect your privacy and security, we take reasonable steps to verify your identity before granting access to your Personal Information. Please follow the instructions below based on your relationship with the Foundation and provide the requested information to allow us to adequately address your request. 

 

We will respond to your request within a reasonable timeframe and as otherwise required by applicable law in your jurisdiction. 

 

 

Notice of Right to Opt-Out of Profiling, Automated Decision Making, and Targeted Advertising 

 

You may have the right to opt out of targeted advertising and selling of your data. You may submit a request to exercise this right by submitting a request through one of the two options provided in the “Submitting a Consumer Request” section below. 

 

We may create a profile regarding your interests and preferences for our products and services including your potential to purchase a product or service. For job applicants or independent contractors, we may create a profile regarding predispositions, behavior, attitudes, intelligence, abilities, and aptitudes for recruiting and hiring assessments and decisions. You may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. 

 

Submitting a Consumer Request 

You can submit any of the above types of consumer requests through either of the options below: 

 

• Submit an email to info@csodfoundation.org 

• Via postal mail at the Contact Us mail address below 

 

How We Will Verify That It Is You Submitting the Request 

 

When you submit a request through one of the methods provided, we will need to confirm and verify your identity. 

 

We will ask you to provide some information reasonably necessary to verify your identity and respond to your request. During verification, we will only request only the minimum Personal Information necessary to correctly identify you for the purpose of fulfilling your request. 

 

We may decline a request to exercise the rights described above when we are unable to verify your identity or locate your Personal Information in our systems. If we are unable to comply with your request, we will explain the reasons for declining to comply with your request. 

 

Designated Authorized Agent 

 

You may have the right to designate an authorized agent to submit one of the above requests on your behalf. To do so, you must either (a) execute a valid, verifiable, and notarized power of attorney or (b) provide other written, signed authorization that we can then verify. We maintain the right to deny any request from an authorized agent that does not submit sufficient proof that they have been authorized by you to act on your behalf. 

If you are not a California resident and would like to request access to your Personal Information or request erasure (right to be forgotten) of Personal Information previously provided, please email us at info@csodfoundation.org 

 

 

Use, disclosure, and sharing of Personal Information 

1. Service providers ​

We may use third-party partners to help us operate and maintain our Website and deliver our products and services. We may also share your information with our service providers and other third parties (“Affiliated Parties”) that provide products or services for or through this Website or for our business (such as website or database hosting companies, address list hosting companies, communications providers, e-mail service providers, analytics companies, distribution companies, fulfillment companies, credit card processing companies and other similar service providers that use such information on our behalf). 

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Third-party service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our behalf or to comply with legal requirements. Data may be processed in the European Union, the United States, India or Israel depending upon contractual requirements and in accordance with legal jurisdictions for the region(s) to which the Foundation is subject. 

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2. Aggregated statistics 
We may disclose non-personally identifiable aggregated statistics regarding user behavior as a measure of interest in and use of our Website and e-mails to third parties in the form of aggregated data, such as overall patterns or demographic reports that do not describe or identify any individual user. Information relating to aggregated statistics will be collected through the use of third-party cookies and other third-party tracking devices. 

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3. Legally compelled disclosures 
We may disclose your Personal Information if required to do so by law or subpoena or if we believe that such action is necessary (a) to conform to the law, comply with a judicial or court order or comply with legal processes served on us or Affiliated Parties; (b) to protect and defend our rights and property, the Website, the users of the Website and/or our Affiliated Parties; or (c) to act as needed under the circumstances to protect the safety of users of our Website, ourselves or third parties. 

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International transfers and processing of Personal Information 
We and our service providers may process Personal Information in the United States and other countries where we or our service providers operate, as necessary to operate the Website, provide the Services, support our relationship with you or your organization, comply with legal obligations, and perform the purposes described in this Privacy Policy. Where applicable law requires a transfer mechanism for Personal Information transferred across borders, we rely on legally recognized mechanisms, which may include adequacy decisions, standard contractual clauses, data transfer agreements, or other appropriate safeguards permitted by applicable law. Regardless of where Personal Information is processed, we apply protections consistent with this Privacy Policy. 

 

GDPR INFORMATION NOTICE AND RELATED PROVISIONS 

 
1) Controller Identity and Contact Details: 
Cornerstone OnDemand Foundation 
Attn: Cornerstone OnDemand Foundation Privacy 
1601 Cloverfield Blvd., Suite 620 South, Santa Monica, California 90404, USA 
E-mail: info@csodfoundation.org 

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2) Data Protection Officer: 
José Alberto Rodríguez Ruiz 
40 rue de la Boétie, 75088 Paris, France 
Email: dpo@csod.com   

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3) Purposes and Legal Basis for the Processing 
We collect and use your Personal Information when required for the management of the products and services we offer to you or your organization, and the associated relationship, as well as to comply with legal obligations we may have. 

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We also may collect and use your Personal Information under the GDPR’s legitimate interest legal basis to build and maintain a network of professionals interested in the Foundation and Foundation’s activities, to provide related information and resources, and to promote our professional products and services. We will analyze your interactions with us to understand your profile and level of interest in our products and services, (e.g., to decide whether to include you in a given campaigns). 

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The information may be collected directly from you, from your organization or from other authorized third parties. 

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When consent is required, a consent form will be provided to you. 

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4) Information Sharing 
We may use third-party providers to help us operate and maintain our Website and Activities, as well as deliver our products and services. Third-party service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. 

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5) International Transfers 

Personal Information may be processed in the European Union, the United States, India, New Zealand or Israel depending upon contractual requirements and in accordance with legal jurisdictions for the region(s) to which the Foundation is subject. All locations either benefit from an Adequacy Decision (Israel, New Zealand, and the United States under the Data Privacy Framework) or from alternative suitable safeguards (EU Model Clauses for India). 

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6) Data Retention 
Generally, we will retain data for between two (2) and four (4) years after the last contact. 

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7) Data Subject Rights 
You may to exercise your rights as a data subject, including rights of (access, rectification, erasure, restriction, and objection, as well as portability,) by contacting us through the email addresses provided above.  

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When processing is based on consent, you have the right to withdraw your consent at any time. 

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Finally, you also have the right to lodge a complaint with a supervisory authority. 

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8) Automated Decision-Making 
We will not use the information we collect for making automated decisions that would have a legal or significant effect on you. 

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Third-party websites 
When you are on this Website, you may have the opportunity to visit or link to other websites, including other websites operated by us or by unaffiliated third parties. These websites may collect Personal Information about you, and (because this Privacy Policy does not address the information practices of those other websites) you should review the privacy policies of such other websites to see how they treat your Personal Information. 
  

Privacy of minors 
This Website is not directed at children under the age of thirteen. We do not knowingly collect Personal Information from children under the age of thirteen on our Website. If we become aware that we have inadvertently received Personal Information from a visitor under the age of thirteen on our Website, we will delete the information from our records. 

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Security 
We use commercially reasonable and industry-standard physical, management and technical safeguards to preserve the integrity and security of your Personal Information. We also use Secure Sockets Layer (SSL) encryption when transmitting sensitive information. Whilst we endeavor to protect the security and integrity of sensitive Personal Information provided to this Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee information, either during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. 

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If you contact us by e-mail or a “Contact us” or similar feature on the Website, you should be aware that your transmission might not be secure. An unaffiliated third party could view information you send by these methods in transit. We accept no liability for disclosure of your information due to errors or unauthorized acts by third parties during or after transmission. 

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In the unlikely event that we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If notification is appropriate, we shall endeavor to do so as promptly as possible under the circumstances, and (insofar as we have your e-mail address) we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you would prefer us to use another method to notify you in this situation, please e-mail us at info@csodfoundation.org with the alternative contact information you would like us to use. 

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Updates to our privacy statement 
This Privacy Policy may be updated periodically and without prior notice to reflect changes in our online information practices. We will post a prominent notice on this Website to notify you of any significant changes to our Privacy Statement and indicate at the top of the statement when it was most recently updated. 

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Conditions of use 
If you choose to visit csod.com, your visit and any dispute over privacy shall be subject to this Privacy Policy and our Terms of Use Agreement (incorporated by reference herein, as amended from time to time), including limitations on damages, arbitration of disputes and application of the law of the State of California. 

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Language 
The governing language of this Privacy Policy is English, which shall prevail over any other language used in any translated document. 

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Contact us 
If you have any questions or comments about this Privacy Policy, or if you would like to review, delete or update information we have about you or your preferences, please contact us as follows: 

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Attn: Cornerstone Foundation Privacy 
Address: 1601 Cloverfield Blvd., Suite 600S South, Santa Monica, California 90404, USA 
E-mail:  info@csodfoundation.org