Privacy Policy
Last updated: June 4, 2021
This privacy policy has been updated to comply with the European Union's General Data Protection Regulation (GDPR) which became effective May 25, 2018.
Click here for the GDPR Information Notice and Related Provisions.
Our Privacy Policy is designed to assist you in understanding how we collect and use personally identifiable information (“Personal Information”) that you provide to us and to assist you in making informed decisions when using our website and services (collectively, “Cornerstone” or “Website”).
For our client data privacy policy, please see the related page.
By visiting or using any part of this Website, you agree to the terms of this Privacy Policy as they may be amended from time to time. As we update and expand our Website, this Privacy Policy may change, so please check this web page for updates to our Privacy Policy. Furthermore, this Privacy Policy is incorporated into, and is a part of, this Website’s Terms of Use agreement, which also governs your use of this Website.
Collection of information
When you visit our Website, we may collect information regarding your visit from your computer. Such information helps us to determine information about how you found our Website, the date you visited our Website and search engines that may have led you to our Website. We collect this information to continually improve and enhance the functionality of Cornerstone.
The information you may provide us with is classified into two general types (user-provided information and website usage information), both of which are discussed in greater detail below.
Personal information you choose to provide
In order to make your visits to our Website as enjoyable as possible, we may ask you for Personal Information. Personal information includes, for example, your name and e-mail address, both of which you may be asked to provide when registering with Cornerstone. A description of some of the ways that you may provide personal information to us, as well as further details on how we may use such personal information, is given below.
1. Contact us/feedback
If you e-mail us through a "Contact us" link on our Website, we may ask you for information such as your name and e-mail address so we can respond to your questions and comments. If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages, your e-mail address and our response to you. In certain cases, and with your permission, we may post content from your e-mails to us on the Website.
2. Questionnaires and surveys
We may occasionally ask viewers of our Website to complete online surveys and opinion polls about their activities, attitudes and interests. These surveys help us serve you better and improve the usefulness of Cornerstone. When requesting your participation in these surveys, we may ask you to provide us with your name and e-mail address.
3. Bulletin Boards
Our Website may offer its users the opportunity to use bulletin board blogs and chat rooms and to engage in discussions with other users. If you choose to use these features, you should be aware that any personal information you submit through these features can be read, collected or used by other viewers of these forums and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums.
Website usage information
1. Cookies
When visiting Cornerstone, we may use cookies on or in connection with our Website to maintain information about you. A cookie is a very small text document, which often includes an anonymous unique identifier and additional information necessary to support the site's intended functionality. Cornerstone uses session cookies. A session cookie is temporary and disappears after you close your browser.
When you visit our Website, it will send a session cookie to your browser if your browser’s preferences allow this, but (to protect your privacy) your browser only permits our Website to access the cookies it has already sent to you and not the cookies sent to you by other websites. Except as otherwise set out herein, all of our cookies are necessary for the provision of our services.
Some of the cookies we use and their functionality are included in the table below:
Functional Cookies:
Analytical Cookies:
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.
2. Clear GIFs
When you visit Cornerstone, 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 Cornerstone better for our users.
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 CSOD. 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.
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 Cornerstone’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@csod.com, specifying whether (i) you would like to opt out of receiving promotional correspondence from Cornerstone 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 Cornerstone’s e-newsletters or correspondence.
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.
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).
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 Cornerstone is subject.
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.
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.
Consent to worldwide transfer and processing of Personal Information (applies unless otherwise agreed in writing between you or your organization and Cornerstone)
By providing Personal Information to us through this Website, you agree that it may be used by us and our Affiliated Parties for the purposes described herein, and you further understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, which may have different privacy laws from your country of residence, and which may afford varying levels of protection for your Personal Information. Regardless of the laws in place in these countries, we will treat the privacy of your information in accordance with this Privacy Policy. By providing your Personal Information to this Website, you consent to us transmitting and processing your information in any jurisdiction, in accordance with this Privacy Policy.
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.
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.
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.
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@csod.com with the alternative contact information you would like us to use.
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.
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.
Language
The governing language of this Privacy Policy is English, which shall prevail over any other language used in any translated document.
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:
Attn: Cornerstone Privacy
Address: 1601 Cloverfield Blvd., Suite 620 South, Santa Monica, California 90404, USA
E-mail: info@csod.com
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
2) Data Protection Officer:
José Alberto Rodríguez Ruiz
40 rue de la Boétie, 75088 Paris, France
Email: GDPR@csod.com
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 organisation, and the associated relationship, as well as to comply with legal obligations we may have.
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 analyse your interactions with us to understand your profile and level of interest in our products and services, (e.g., to decide whether or not include you in a given campaigns).
The information may be collected directly from you, from your organisation or from other authorized third-parties.
When consent is required, a consent form will be provided to you.
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.
5) International Transfers
Data 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 Cornerstone is subject. All locations either benefit from an Adequacy Decision (Israel, New Zealand, and the United States under the Privacy Shield) or from alternative suitable safeguards (EU Model Clauses for India).
6) Data Retention
Generally, we will retain data for between two (2) and four (4) years after the last contact.
7) Data Subject Rights
You may to exercise your rights as a data subject (access, rectification, erasure, restriction and objection, as well as portability) by reaching out to us via the email addresses provided above.
When processing is based on consent, you have the right to withdraw your consent at any time.
Finally, you also have the right to lodge a complaint with a supervisory authority.
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.