Privacy Policy

This privacy policy (“the Policy”) tells you about the information that our Company, its subsidiaries, and its affiliated companies collect. In addition, it explains how we use that information and how you can opt out of certain uses of information that we may collect. If the practices described in this Policy are not acceptable to you, then please do not provide our Company with information about yourself.

If we make a material change to this Policy, then we will contact you with respect to the material change. If we decide to change this Policy otherwise, then we will post a new statement on our website www.linkageinc.com (“Website”). We therefore encourage you to check the date of this Policy whenever you visit our Website for any updates or changes.

All references to “Company,” “we,” “us,” and “our” in this Policy shall mean Linkage, Inc.

Collecting Your Personal Information

We collect “Non-Personal Information,” which is information that does not identify you. Examples of Non-Personal Information include your age range and your gender, as well as certain other aggregate information.

In addition to Non-Personal Information, we also collect “Personal Information,” which refers to information that relates to an identified, or identifiable, person. Examples of Personal Information include your first and last name, your work address, your email address, and your work and mobile phone numbers.

The Personal Information that we collect depends on what services you use or information that you request. Our collection and processing of your information is based on different circumstances and contexts, including our obligations under applicable law, our legitimate interest in conducting our business, our performance of certain contracts, protection of a natural person’s vital interests, and/or upon your consent. The following are examples of some Personal Information that we may collect – and when and how we collect that information.

Registration and Transactional Data
When you register on or use our Website, we may collect various kinds of Personal Information, including your first and last name, your email address, your work address, and your work and mobile phone numbers. We use this information to process your registrations and requests as well as to send you information about our Company and/or our programs, products, and services. We may also use this information to create a convenient and easy-to-use online reservation service or shopping process that includes an online “shopping cart” that allows you to track selected programs, products, and services and proceed through purchase. We also collect and store access information related to your account, including user name and user password. When you make purchases from our Website, we may collect information such as product, program, and service orders, shipping address(es), and credit card information in order to process your purchase.

Customer Service Correspondence
When you submit comments, questions, or suggestions to our Customer Service Department, we may collect information that identifies you individually (such as your first and last name, your email address, your work address, and your work and mobile phone numbers). We use that information to verify your identity and to respond to your submission of such comments, questions, or suggestions.

Surveys
From time to time, we may post surveys on our Website or otherwise send you surveys. These surveys may request demographic information (such as age range, gender, areas of interest, and familiarity with our Company and/or our programs, products, and services) as well as customer feedback. Participation in these survey requests is completely voluntary. With each request, you will have the choice of whether or not to disclose information. We use such survey information to improve our programs, products, and services as well as the overall experience on our Website.

Marketing and Promotion
We may also use your Personal Information for the marketing and/or promotion of our Company, our subsidiaries, our affiliated companies, and/or our programs, products, and services, as well as our sponsors and their programs, products, and services.

Internal Analysis
We may use information about you for statistical, design, or operational purposes, such as to estimate our audience size, to measure aggregate traffic patterns, and/or to understand demographics, customer interest, purchasing, and other trends among our users and customers, including you.

 

Sharing Your Personal Information

We do not sell or share information that identifies you individually or makes it possible for other parties to contact you directly without your consent, except as disclosed in this Policy and in the following circumstances:

Legal Purposes
We may share information:
a. to conform with the law, respond to claims, or comply with legal process served on Company (e.g., a lawful subpoena, warrant or court order, or discovery request);
b. to enforce or apply our policies or agreements (including to bill and collect for amounts owed to us);
c. to protect and defend our Company, our rights or property, our Website, our employees, our users and their rights and property, or the public, including but not limited to in the instance of fraudulent, abusive, or unlawful use of our Website; or
d. if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

Service Providers
We may share your information with service providers who are acting on our behalf. Such service providers are prohibited from using your information for other purposes.

Affiliated Companies
We may share your information with companies that are under common ownership or control with Company, our subsidiaries, and/or our affiliated companies.

Sale of Assets
We may share or sell your information as an asset of Company in conjunction with the sale to a third party of our Company, our subsidiaries, and/or our affiliated companies, in whole or in part.

 

Protecting Your Information

We have put in place certain physical, electronic, and managerial procedures to help maintain data accuracy, prevent unauthorized access to or disclosure of your Personal Information, and ensure the appropriate use of your Personal Information. In the event that we are required by law to inform you of any unauthorized access to your Personal Information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Retaining Your Information

We retain Personal Information for the period necessary to fulfill the purposes outlined in this Policy or until you request that we delete your Personal Information in the manner noted above, unless a longer retention period is required or is permitted by law. If you would like additional information concerning how long we keep specific types of such information, you can contact us pursuant to the “How to Contact Us” section below.

Your Choices

You may make the following choices regarding your Personal Information:

  1. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send you free newsletters, surveys, offers, and other promotional materials, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive or by contacting us with such request pursuant to the “How to Contact Us” section below. Please note that, in the instance where you decide not to receive promotional emails, we may still send you service-related communications.
  2. Promotional Mailings.If at any time you do not want to receive offers, mailings, and/or circulars from us, you can remove yourself from our mailing lists by contacting us with such request pursuant to the “How to Contact Us” section below. In the instance where you contact us via email, please include “NO SNAIL MAIL” in the subject line along with your name, address, and zip code. Although we will remove your name from our mailing lists after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
  3. Promotional Text Message If you receive a text message from us that contains promotional information, you can opt out of receiving future text messages by replying “STOP.” or otherwise contacting us with such request pursuant to the “How to Contact Us” section below.
  4. Access to Your Personal Information.If required by law, upon request, we will grant you with reasonable access to the Personal Information that we have about you. You may request access to your Personal Information by contacting us with such request pursuant to the “How to Contact Us” section below.
  5. Changes to Your Personal Information.We rely on you to update and correct your Personal Information. Our Website may allow you to modify or delete your account profile. If our Website does not permit you to update or correct certain information, please contact us with such request pursuant to the “How to Contact Us” section below. Please note that we may keep historical information in our backup files as permitted by law.
  6. Deletion of Your Personal Information.You may request that we delete your Personal Information by contacting us with such request pursuant to the “How to Contact Us” section below and we will delete such Personal Information to the extent required by law. Please note that we typically retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. In addition, we may keep your Personal Information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
  7. Revocation of Consent.You may revoke consent or object to specific processing of your Personal Information by contacting us with such request pursuant to the “How to Contact Us” section below. If you revoke your consent for the processing of Personal Information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if we are unable to adequately verify your identity or if the law permits or requires us to do so.
  8. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
  9. California Residents.California residents may be entitled to ask us for a notice describing what categories of Personal Information (if any) we share with third parties or affiliates for direct marketing purposes. If you are a California resident and would like a copy of such notice, please submit a written request to us pursuant to the “How to Contact Us” section below.

 

Miscellaneous

Aggregate Information
We collect aggregate information about you and your use of our Website whenever you visit us online. For instance, we may collect various forms of “click stream” information such as entry and exit points for our Website (e.g., referring URLs or domains), site traffic statistics, page views, impressions, and operating system and browser types. In addition, when you request pages on our Website, our servers automatically log your IP addresses. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Internet. We also use third-party software that tracks traffic directed to the Website from affiliate websites and the purchases that result from this traffic. This information is aggregated and is not tied to an individual purchase.

This aggregate information generally will not identify you or be correlated to you individually for external purposes. We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all aggregate information, provided that such information does not reveal your identity. When we share such information with other companies, it is not traceable to any particular user, and will not be used to contact you. If we do correlate any aggregate information to you, such information will be treated like any other Personal Information under this Policy.

Transmission of Information to Other Countries
As an international company, we transmit information between and among Company, our subsidiaries, and/or our affiliated companies. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where reasonably possible, we take steps to treat Personal Information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your Personal Information to us, you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States of America. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction, you can contact us pursuant to the “How to Contact Us” section below.

Third Party Tracking
We reserve the right to participate in behavior-based advertising. This means that a third party may use technology (e.g., cookies) to collect information about your use of our Website so that it can provide advertising about products and services tailored to your interests. That advertising may appear either on our Website, or on other websites. You can opt out of receiving advertising based on your browsing behavior from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely prevent advertising based upon your browsing behavior you should also disable the cookies on your browser.

Links to Other Websites
Please be aware that we provide links to third-party websites as a service to our users, and that we are not responsible for the content or information collection practices of those websites. Please note that the privacy policies of these websites may differ from our Policy. We encourage you to review and understand their privacy practices before providing them with information.

 

How to Contact Us

If you have any questions about this Policy or our use of your information, or if you need help accessing, changing, or deleting your information, or otherwise electing to make any of the choices in “Your Choices” above, you can email or contact us as set forth below.

Email us at: customerservice@linkageinc.com

Or send a letter to:
Linkage, Inc.
Attention: Digital Marketing
200 Summit Drive
Burlington, MA 01803

Important Note: If you are a person located in the European Union, please use the specific contact information in the box area below.

For Persons Located in the European Union

Email us at: EUcustomerservice@linkageinc.com

Or send a letter to:
Linkage, Inc.
Attention: Digital Marketing
200 Summit Drive
Burlington, MA 01803

If you are not satisfied with our response, and you are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

Effective Date: December 18, 2019