Last updated: March 21, 2019
Click here for the GDPR Information Notice and Related Provisions.
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 registered learners 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 our websites and learning portals. 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 learning portals may offer registered learners the opportunity to use online forumsto 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
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:
|blog-visit-count||Persistent||Cornerstone||Integer used to track if user already subscribed to the blog. Does not contain any personal information.|
|last_view||Session||Cornerstone||Keeps track of last blog article viewed by user in the session. Used for navigation purposes.|
|_ar_v4||Persistent||AdRoll||Uses AdRoll to provide interest-based advertisements to show our ads on other websites. The Technology to do this is made possible by cookies and as such we may place a so called "remarketing cookie" during your visit. The whole process is entirely anonymised.|
|_atuvs||Persistent||AdRoll||Uses AdRoll to provide interest-based advertisments to show our ads on other websites. The technology to do this is made possible by cookies as such we may place a so called "remarketing cookie" during your visit. The whole process is entirely anonymised.|
|_atuvc||Persistent||AdRoll||Uses AdRoll to provide interest-based advertisments to show our ads on other websites. The technology to do this is made possible by cookies as such we may place a so called "remarketing cookie" during your visit. The whole process is entirely anonymised.|
|_ga||Persistent||Google Analytics||Used to distinguish users.|
|_gat||Persistent||Google Analytics||Used to throttle requet rate|
|_mkto_trk||Persistent||Marketo||Allows us to collect information about how the site is used via e-mails. The cookies track data linked to your e-mail address and includes data such as how you arrived at the site, how often you have visited the site, and which pages you viewed. Does not contain any Personal Information.|
|optimizelyBuckets||Persistent||Optimizely||Used to store the different versions of a web page variants for better comparison and performance testing and to ensure the user gets a consistent experience.|
|optimizelyEndUserId||Persistent||Optimizely||Contains the end user's unique identifier. Used by Optimizely to track information per user. This cookie has an expiration time of ten years to ensure an end user will continue to be properly identified and thus prevent duplicated data even over long periods.|
|optimizelyPendingLogEvents||Persistent||Optimizely||Used to cache a user's actions between tracking calls. The cookie is wiped when the tracking call is made. This is to ensure all events are tracked even if the user is committing actions in rapid succession.|
|optimizelySegments||Persistent||Optimizely||Performance of the user's experience and the appearance of the site.|
|trackalyzer||Persistent||LeadLander||Unique ID used for behavior tracking purposes. The cookie includes the collection of IP addresses and search-related data in order to evaluate visits to, and monitor use of, the Site. This cookie is persistent so that data can be linked over multiple sessions.|
|_utma||Persistent||Google Analytics||Keeps track of the number of times a visitor has been to the site pertaining to the cookie, when their first visit was, and when their last visit occurred.|
|_utmc||Session||Google Analytics||Takes a timestamp of the exact moment in time when a visitor leaves a site.|
|_utmv||Persistent||Google Analytics||Used to store visitor-level custom variable data. The cookie is updated every time data is sent to Google Analytics.|
|_utmz||Persistent||Google Analytics||Keeps track of where you came from, what search engine you used, what link you clicked on, what keyword you used, and where they were in the world when you accessed a website. It expires in 6 months.|
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 our websites and learning portals, 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 our websites and learning portals 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 Cornerstone. 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 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 firstname.lastname@example.org, 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 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)
In compliance with the Privacy Shield Principles, Cornerstone OnDemand Inc commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union and in Switzerland with inquiries or complaints regarding our Private Shield policy should first contact their employer, as Cornerstone OnDemand inc. data processing is on behalf of their clients. Cornerstone OnDemand Inc. can be contacted at:
Attn: Cornerstone Privacy Address: 1601 Cloverfield Blvd., Suite 600 South, Santa Monica, California 90404, USA E-mail: email@example.com
Cornerstone OnDemand Inc. has further committed to cooperate with EU data protection authorities (DPAs) and with the Swiss Federal Data Protection and Information Commissioner with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs or the Swiss Federal Data Protection and Information Commissioner for more information or to file a complaint. The services of EU DPAs and the Swiss Federal Data Protection and Information Commissioner are provided at no cost to you.
Cornerstone OnDemand Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
It is also possible, under certain conditions, to invoke binding arbitration. Please visit the Privacy Shield website for additional information.
In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Cornerstone OnDemand Inc. shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage. Such could be the case with subjects whom have no direct affiliation to the Data controller whom is tasked in performing other tasks than those commercially under Cornerstone OnDemand Inc.
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.
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 firstname.lastname@example.org with the alternative contact information you would like us to use.
Updates to our privacy statement
Conditions of use
Attn: Cornerstone OnDemand Foundation Privacy
Address: 1601 Cloverfield Blvd., Suite 620 South, Santa Monica, California 90404, USA
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
2) Data Protection Officer:
José Alberto Rodríguez Ruiz
28 Rue de Londres, 75009 Paris, France
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.