Last Modified Date:  July 1, 2018

Protecting your private information is our priority.  This Statement of Privacy (“Privacy Policy”) applies to Revenue Storm Corporation, and its subsidiaries and affiliates (hereinafter, variously “Revenue Storm,” “we,” or “our”), and our web platforms, applications, websites, systems, tools and related support services (collectively, the “Services”), and your choices about the collection and use of your information.

By using our Services in any manner, you indicate to Revenue Storm that you have read and accept our Privacy Policy and consent to the data practices described in this Privacy Policy.  If you do not accept this Privacy Policy or do not meet or comply with the provisions set forth herein, then you may not use our Services.

INFORMATION WE COLLECT

When you use our Services, you may provide Revenue Storm with two main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you use our Services. We collect information from you when you (a) use and/or access our Services, (b) open and/or respond to our emails, (c) contact Revenue Storm, (d) visit any page online that displays our content, (e) purchase assessments and/or offerings through our Services, and/or (f) provide information to any of our partners or vendors.

Personally Identifiable Information You Choose to Provide

We may ask for certain personal information from you for the purpose of providing to you content and/or Services that you request.  We collect personal information such as your: (i) contact information (including name, telephone number, email, title, and job position); (ii) employment content (including information, text and/or other materials) submitted by you; (iii) financial information (such as credit card number, expiration date, verification number and billing address); (iv) behavioral activities and time focus (including preferences, frequencies, and performance); (v) contact information of employees or others you share with us; (vi) demographic information (including age, birthdate, place of residence and gender); (vii) location information (such as geographic location of the device you are using) (viii) preferences, feedback and behavior (such as reports and performance rates) and (ix) information of third parties such as names and email addresses, as may be provided for example, in order to invite your team to webinars, training classes, coaching events or to take assessment tests.  Once you register, you have opted in to receive electronic communications from Revenue Storm.  Revenue Storm may also provide you with the opportunity to participate in surveys through our Services.  If you participate, we will request certain personally identifiable information.  Participation in surveys, as well as any other Service, is completely voluntary and you therefore have a choice whether to disclose such information.

Non-Personally Identifiable Information We Collect

When you access or use our Services, we may automatically collect information about you, including:

Cookies:  We use cookies and web log files to track usage and trends, to improve the quality of our Service and to customize your experience.  A “Cookie” is a tiny data file that resides on your computer, mobile phone, or other device, and allows Revenue Storm to recognize you as a user when you return to our website using the same computer and web browser.  Information gathered through Cookies may include the date and time of visits, the pages viewed, and time spent at our Service. Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in our full cookie policy. You can also remove or block Cookies using the settings in your browser, but in some cases that may impact your ability to use our Services.

Device Data: We sometimes use device data, which is information concerning a device you use to access, use, and/or interact with the Services, which may include operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifiers.

Aggregate:  We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on.  This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual. We may share user information in the aggregate with third parties.

Analytics:  Revenue Storm uses analytic software to gather statistics and usage trends for product and service improvement purposes.  Our Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.

Third-Party Services:  To support the Services we provide to you, we may use services hosted by third parties.  These services may collect information sent by a browser as part of a web page request, including Internet Protocol (“IP”) addresses, browser software, and/or clickstream patterns. If such third-party services collect information, they do so anonymously without identifying individual visitors.  However, we may link the information we record using tracking technology to personal information we collect.  In addition, we may allow third parties who support us to use Cookies in connection with your use of the Services.  They may collect and store the same type of information and use it similarly to Revenue Storm, as described above.

HOW WE USE THAT INFORMATION

General Use

We use information collected as described in this Privacy Policy to provide you with the information and/or content that you have requested, and, in some cases, to contact you about or to promote our products, features and/or Services.  We also use the information collected to take the following actions:

  • operate and improve our Services for new features, content or design;
  • answer questions and respond to your requests;
  • perform analytics and conduct research;
  • send you reminders, support and marketing messages;
  • maintain and manage our administration of our Services;
  • participate in one of our surveys or other forms of customer research;
  • facilitate and process employment, time management or developmental assessments;
  • analyze programs, products and services we offer; and
  • use information for other purposes about which we notify you.

The information collected in the aggregate enables Revenue Storm to better understand your use of the Services and to enhance your enjoyment. We may use financial information to process payment or to enroll you in a Service in which you elect to participate.  If you use the Services, you agree to receive certain communications from us including but not limited to the following:

Special Offers, Newsletters and Updates.  We will occasionally send you information on products, special deals, promotions and newsletters. You can sign up for these emails from us at any time. Out of respect for your privacy, you may elect not to receive these types of communications by contacting us or replying to our emails.

Discussion Groups.  Our Service may have links or access to publicly accessible discussion groups, blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

Customer Service.  Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the Services you request and to manage your account. We will communicate with you by email most often, but by telephone as needed.

Parties with whom we may share your information:

Service Providers:  We may share your personally identifiable information as well as information from tools like Cookies, log files, and device identifiers and location data (such as usage data, referring/exit pages and URLs, platform types, number of clicks, etc.), with our employees, contractors, and/or agents that help Revenue Storm provide the Services to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services.  We strive to use commercially acceptable means to protect your personal information. If Service Providers acquire confidential or proprietary information belonging to Revenue Storm or its customers, such information is required to be handled in confidence and may not be disclosed to unauthorized third parties. Service Providers who violate our security and safe maintenance of data policies are subject to appropriate discipline including, but not limited to, termination.  We take the privacy of our users very seriously, and we do not sell, rent, and/or otherwise provide your personally identifiable information to third parties for marketing purposes.  We will not share your personally identifiable information in ways unrelated to those described in this Privacy Policy without providing you with an opportunity to opt out of such use or otherwise prohibit such unrelated use. We encourage our Service Providers to adopt and post privacy policies; however, such Service Provider’s use of personally identifiable information obtained through Revenue Storm is governed by such Service Provider’s privacy policies and is not subject to our control. Certain Service Providers will automatically collect non-identifying information about your use of our Services by using Cookies and other technologies as similarly used by Revenue Storm.

Corporate Accounts:  If you are an individual Revenue Storm registered user and the domain of the primary email address associated with your account is owned by your employer and was assigned to you as an employee of that organization, and such organization wishes to establish a corporate account, then certain information concerning past use of your individual account may become accessible to that organization’s administrator including your email address, survey responses and/or assessment results.

For Collaboration: We may share your information, including when you choose to use certain features in the Services that by their nature support sharing with third parties who you choose. Your name, email address, and any content you choose to share will be shared with such third parties, and such third parties may communicate with you (such as by posting comments or emailing you) in connection with your use of such features within the Services.

Compliance with Laws: Revenue Storm will not disclose your personal information to third parties except as set forth in this Privacy Policy and in the following circumstances: (i) to investigate and defend Revenue Storm members against any third party claims and/or allegations and/or otherwise to protect Revenue Storm from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services, (v) to pass on concerns you may raise about our Services to your employer if the Services were purchased by them, and/or (vi) protect the security and/or integrity of the Service.

Business Transfers: If we sell or otherwise transfer part or all of Revenue Storm or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.

YOUR INFORMATION CHOICES

Depending on the situation, Revenue Storm may obtain consent to the collection of personal information in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of our online Services or other Services, or when you approach us to obtain information, inquire about or request services from us.  We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to Revenue Storm, and you can limit the communications that Revenue Storm sends to you.  If you visit our Services and volunteer personally identifiable information, you can opt out of receiving notifications, and you may review, modify, update, and/or delete such personally identifiable information by contacting and/or by changing your preferences on the Service.  Please be aware that even after your request for a change is processed, Revenue Storm may, for a time, retain residual information about you in its backup and/or archival copies of its database.  Please be aware that we may still email you non-commercial emails related to your account and your transactions through our Services.  Following termination of Services, Revenue Storm may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide Revenue Storm with requested information, you may not be able to use and/or access all of our Services.

Your California Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to receive: (a) information identifying any third-party companies to whom Revenue Storm may have disclosed personal information to for direct marketing, within the past year; and (b) a description of the categories of personal information disclosed. Revenue Storm does not provide personal information to third-parties for marketing purposes. To validate such, please email your request to privacy@revenuestorm.com and we will respond within thirty (30) days of receiving such a request.  This request may be made no more than once per calendar year.  We reserve the right not to respond to requests submitted in ways other than those specified above.

SERVICE ELIGIBILITY AND CHANGES

Children and Minors. Revenue Storm does not knowingly collect personally identifiable information from anyone under the age of thirteen (13) (a Child) nor anyone that is at least thirteen but under the age of eighteen (18) (a Minor). If we learn that we have collected personal information from a Child or Minor, we will delete such information as quickly as possible. If you believe that a Child or Minor may have provided us personal information, please contact us at privacy@revenuestorm.com.  By using our Services, you represent that you are at least eighteen (18) years old which is the required age to create an account or purchase our Services.

Changes to Privacy Policy.  In general, changes will be made to this Privacy Policy to address new or modified laws, changes to ‘EU-US Privacy Shield Framework’ and/or new or modified business procedures.  However, we may update this Privacy Policy at any time, with or without advance notice, so please review it periodically. We may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances.  You can determine when this Privacy Policy was last revised by referring to the date it was “Last Modified Date” above.  If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to stop using the Services.  Your continued use of the Services after any modification to this Privacy Policy will constitute your acceptance of such modifications and/or updates.

SECURITY

We work hard to secure your personal information from unauthorized access to and/or unauthorized alteration, disclosure and/or destruction of information we hold.  Revenue Storm has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Because the internet is not a completely secure environment, Revenue Storm cannot warrant the security of any information you transmit to Revenue Storm or guarantee that information on the Services may not be accessed, disclosed, altered and/or destroyed by breach of any of our physical, technical and/or managerial safeguards.  Please do your part to help Revenue Storm.  You are responsible for maintaining the secrecy of your account information and for controlling access to emails between you and Revenue Storm at all times.  Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing our Services.  We are not responsible for the functionality, privacy and/or security measures of any other organization.

OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites and/or applications linked to or from our Services, including the information contained therein. Please remember that when you use a link to go from our Services to another website or application, our Privacy Policy does not apply to such third-party’s services.  Your browsing and interaction on any third-party, including those that have a link on our Service, are subject to such third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your personal information. If you are using a third-party website or application and you allow them to access your personal information, you do so at your own risk.

EU – U.S. PRIVACY SHIELD FRAMEWORK

Where Revenue Storm acts as a data processor, Revenue Storm has certified its compliance with the EU-U.S. Privacy Shield Framework.  Revenue Storm may from time to time collect, use, and retain personal information from individuals located within the European Union (“EU”) member countries. We are committed to subjecting all personal data received from the EU member countries in reliance with the Privacy Shield Framework and its applicable ‘Principles’. To learn more about the ‘EU-US Privacy Shield Framework’, please visit https://www.privacyshield.gov.  Revenue Storm is under the jurisdiction as well as the investigatory and enforcement powers of the US Federal Trade Commission for purposes of the ‘EU-US Privacy Shield Framework.’  This Privacy Policy applies to all personal information received by Revenue Storm whether in electronic, paper or verbal format, with the exception of the Sales Talent Indicator™ assessment and the Sales Talent Predictor™ assessment which has been discontinued for use in the European Economic Area (EEA) as of May 17, 2018.

PRIVACY SHIELD COMPLIANCE

Personal information may be transferred abroad (including outside the EU for our users in the EU) in connection with Revenue Storm’s provision of hosted application services and related support services to our customoers. Revenue Storm strives to collect and use personal information in a manner consistent with the laws of the countries in which we do business and is self-certified to the ‘EU-US Privacy Shield Framework’ developed by the U.S. Department of Commerce in coordination with European Commission. Revenue Storm is committed to cooperating with the European Data Protection Authorities or their authorized representatives in accordance with applicable law.  To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield at https://www.privacyshield.gov.

DATA INTEGRITY PURPOSE LIMITATION

Revenue Storm may process personal data on your behalf in order to provide the Services, including uploading, reviewing, sharing content and sending emails on your behalf. Revenue Storm will only process personal information in a way that is set forth herein and relevant for the purpose for which it was collected and/or authorized by you.  Revenue Storm will take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete and current.  We may occasionally contact you to determine that your data is still accurate and current.

ACCESS

Upon request, we will grant you reasonable access to personal information that we hold about you. Revenue Storm may deny requests where legitimate rights of persons other than you would be violated or where disclosure would interfere with national security, defense, or public security.  For security purposes, Revenue Storm may require verification of identity before providing access to personal information.  If you wish to access, amend, or confirm that Revenue Storm has personal data relating to you, or if you wish to correct or delete your personal information if it is inaccurate, please notify us by contacting privacy@revenuestorm.com.  We will respond to your request within a reasonable time. 

ONWARD TRANSFERS

Revenue Storm is responsible for the processing of personally identifiable information it receives, under the Privacy Shield Frameworks, and subsequently transfer to a third party acting as an agent on its behalf.  Revenue Storm complies with the ‘Principles’ for all onward transfers of personally identifiable information from the EU, including the onward transfer liability provisions.  Revenue Storm will offer users in the EU whose personally identifiable information has been transferred to the United States the opportunity to opt out from: (a) the disclosure of personally identifiable information to a non-agent third party (other than Service Providers); and (b) the use or disclosure of personally identifiable information for a purpose other than the purposes for which the information originally was collected or subsequently authorized by the individual or a compatible purpose.  Revenue Storm does not intend to receive “sensitive personal information” (which includes, without limitation, personal information specifying medical and/or health conditions, racial and/or ethnic origin), and neither our clients nor any individuals should provide sensitive personal information to us.  In the event Revenue Storm seeks to receive such information, we will request and obtain affirmative consent before disclosing such information to a non-agent third party and before using such information for a purpose other than the purpose originally disclosed and/or a compatible purpose.  Revenue Storm will provide you with reasonable mechanisms to exercise your choices should such circumstances arise. Revenue Storm will not transfer personal information originating from the EU to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your personal information as required by the principles of the ‘EU-US Privacy Shield Framework’.  We will only transfer data to our agents, resellers or third-party Service Providers who need the information in order to provide services to or perform activities on behalf of Revenue Storm, including in connection with the delivery of Services, Revenue Storm management, administration, or legal responsibilities.  Revenue Storm will make sure that any third-party agents receiving personal information subscribes to the ‘EU- US Privacy Shield Principles’.

EXCEPTIONS TO PRIVACY SHIELD PRINCIPLES

As it relates to personally identifiable information pertaining to EU individuals, please be aware that there are certain exceptions to the EU-US Privacy Shield Principles’.  For instance, our adherence to the ‘Principles’ may be limited to the extent necessary to meet national security, public interest or law enforcement requirements.  Please note that where an exception applies to the ‘Privacy Shield Principles’, we may make use of such exception. Revenue Storm discontinued the Sales Talent Predictor™ Assessment and Sales Talent Indicator™ Assessment for the EU as of May 17, 2018 but has expectations to create new assessments in the near future.

DATA TRANSFERS

Please be aware that our Services are subject to United States laws, including laws governing privacy and security of your information.  By using our Services, you agree and consent (and represent that you have the authority to provide such consent) to the information collection, use and sharing practices described in this Privacy Policy and understand that the laws of the United States and other countries and territories related to the foregoing may differ from those of other countries and may not be as protective as the laws in the country where you reside.  Regardless of the laws in place in such countries, we will treat the privacy of your information in accordance with this Privacy Policy.

RECOURSE, ENFORCEMENT AND LIABILITY

Revenue Storm uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the Privacy Policy is accurate, prominently displayed, comprehensive for the information intended to be covered, implemented and accessible and in conformity with the ‘EU- US Privacy Shield Principles’.  If you believe Revenue Storm processes your personal data under reliance of the ‘EU-US Privacy Shield Framework’ and have inquiries or concerns that you would like to discuss with us, we encourage you to raise any concerns by contacting us at privacy@revenuestorm.com and we will investigate and attempt to resolve any disputes regarding use and disclosure of personal information in accordance with the ‘EU- US Privacy Shield Principles’.  We will respond to your inquiry within thirty (30) days from our receipt of such inquiry.  If the personal information in question was transferred from the EU to the United States, and for some reason a complaint or dispute cannot be resolved through our internal process, we have further committed to refer unresolved ‘EU-US Privacy Shield’ complaints to an independent dispute resolution mechanism located in the United States.  Any dispute, controversy and/or claim arising out of or relating to this Privacy Policy, will be referred to and finally determined by Judicial Arbitration and Mediation Services (“JAMS”).  If you do not receive timely acknowledgment of your complaint, and/or if your complaint is not satisfactorily addressed by Revenue Storm, please visit the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.

These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.  Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

LANGUAGE

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

HOW TO CONTACT US

If you have questions and/or comments about this Privacy Policy, please email us at privacy@revenuestorm.com.