Privacy Policy

Last updated October 2024

Overview

CBT Nuggets, LLC dba Adept (“Adept”, “us”, “we”, “our”) operates the Adept Learning Platform, associated applications and https://www.adept.at (“Services”). By accessing or using the Services, you expressly agree to this Privacy Policy. This Privacy Policy describes the types of information that we may collect from you or that you may provide to us when you visit the Adept website located at https://www.adept.at (the “Website”) or the Adept mobile applications (“Apps”) (collectively the “Services”), and our practices for collecting, processing, protecting and disclosing such information.

This Privacy Policy applies to information we collect: (i) through the Services, and (ii) in communications between you and Adept. For purposes of this Privacy Policy, we use the terms “personal information” and “personal data” interchangeably.

Except as otherwise expressly provided, this Privacy Policy only addresses the use and disclosure of information Adept collects from you. The Website may contain hyperlinks to other third-party websites, which may collect and disclose information in a manner not consistent with this Privacy Policy, and such collection and disclosure would be governed by that website’s privacy policy, and any questions or concerns should be directed to that company’s site administrator or provided contact information. We are not responsible for the collection, use, or disclosure of information collected through any third-party websites, and we expressly disclaim any and all liability related to such collection, use, or disclosure.

By visiting our Website or using our Services and submitting information, you unambiguously consent and agree to:

  • The use of cookies, tracking pixels, and similar technologies;
  • The cross-border transfer of your personal information to locations outside your jurisdiction of residence;
  • The collection, processing, transfer or use of your personal information, as described in this Privacy Policy; and
  • The use of e-mail notifications as a primary source of communication between you and Adept.

If you do not consent to any collection, processing, transfer or use of such information, please discontinue use of the Services.

Information We Collect

Adept Website Visitors

When you visit or interact with our Services, we and our partners may use a variety of technologies that collect your personal information. We also collect information your web browser sends whenever you interact with our Services which may include IP address, browser and device information, time, the server your computer is logged onto, the area code and zip code associated with your server, and other statistics such as which pages and features of the Services that you engage with.

We may use cookies, web beacons, tracking pixels, and other tracking technologies in the Services to help customize the Services and improve your experience. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Services. Learn more about cookies at www.aboutcookies.org. You may not decline web beacons; however, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

We may use vendors, who use first-party and third-party cookies together to inform, optimize, and serve ads based on your past visits to our Website. Google Analytics offers tools to manage your cookie settings at tools.google.com/dlpage/gaoptout and Google’s My Ad Center (myadcenter.google.com) allows you to easily customize certain ad settings. Microsoft Ads allows users to opt out at their website at about.ads.microsoft.com/en-us/resources/policies/opt-out-of-the-microsoft-advertising-optimization-program On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests. Additional information for mobile users can be found at: youradchoices.com/appchoices.

Our Website does not respond to Do Not Track signals. You may visit aboutads.info to receive more information about the collection and use of information about your online activities for online behavioral advertising or to learn how to opt-out of having your data used for online behavioral advertising by Digital Advertising Alliance (DAA) participating companies. Canadian users can also visit youradchoices.ca European users can also visit youronlinechoices.com to learn how to opt-out of having their data used for online behavioral advertising by European Interactive Digital Advertising Alliance (EDAA) member companies.

By interacting with our Website without disabling cookie functionality and other similar technologies, you hereby consent to the use of cookies and similar technologies as described above.

Mailing Lists

When you sign up to receive marketing emails from Adept, the personal information that you provide is collected in order to identify you and personalize the email content we send to you. You may unsubscribe from the marketing email list at any time by using the “Unsubscribe” link in the email. Please note that this does not unsubscribe you from System/Transactional emails such as subscription notices, receipts, follow up communications, or other compulsory commercial or legal correspondence.

Adept Learning Platform Users

In order to provide you with the Services or to complete transactions which you have requested, we may request your personal information, including information required to register for an Adept Learning Platform account to provide you with the Services or to complete transactions which you have requested. This information may include your username, email and your first and last name. We and our third party-partners must process your personal information in order to make the Services available to you pursuant to the terms of your access. The particular data that is processed, and by whom, is relative to the particular content you access and the particular service you interact with.

When registering for or managing an Adept Learning Platform account, you may be asked whether you want to allow your profile to be discovered by organizations and users of other organizations on the Adept Learning Platform. This election is entirely voluntary and can be revoked at any time through your Account settings. Electing to allow your profile to be discovered means that other users or administrators in outside organizations will have the ability to invite you to the organization through a search function locating your profile via by name (first name / last name), username or email address, displaying some or all of this information via the search function. Additionally, if you add a Profile image and elect to allow your profile to be discovered, third party users will see that image when searching to invite you to their organization.

Account Administrators have access to certain account, subscription and enrollment information for Learners in their group. Account Owners, Group Administrators, Learning Administrators and Billing Administrators similarly have access to their group's Learner information, with Account Owners and Billing Administrators having additional access to payment and billing and information.

As applicable, when registering for an Adept Learning Platform account, you may be asked to enter payment information, such as PayPal or credit card. We collect your payment information, as well as your billing address, email address and telephone number for validation, compliance and recordkeeping purposes. We may further leverage third party email tracking pixels to track the opening of billing emails. Payment processing is securely handled by third parties.

Adept uses the personal information it collects to provide for and improve upon the Services. When you access the Services, Adept may collect and aggregate anonymized data related to the consumption of the Services, including what content users consume, to better curate learning experiences and generate content recommendations.

The Services may provide the ability to connect to other websites or service providers. These third party services may operate independently from us and may have their own privacy notices or policies, and we strongly suggest you review those notices and policies. If any third party service is not owned or controlled by us, we are not responsible for its content, any use of the third party service or the privacy practices of the third party service.

Finally, please be mindful of the personal information which you provide in any service forum which may be visible to other visitors or users, or your organization if applicable.

Communicating With Us

When you contact us for support, or otherwise communicate with us, we will attempt to connect that email, telephone call, or chat with your Adept account. If we are able to connect the communication to the account, this means your method of communication and the substance of the communication will become associated with your information.

Adept expressly discourages any customers from sending or transmitting any sensitive data via any unsecured networks or channels, including, but not limited to, any customer primary account number (“PAN”) or other credit card or payment data. You assume any and all risk associated with such transmissions.

Accessing Services Via Apps

When you download our Apps and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best application version to provide you with. During your use of the App, we and our partners may further collect data regarding your device, operating system, and location in order to optimize the Services we provide to you.

Information We Disclose

We will NEVER rent, sell, share, or otherwise disclose your personal data with third-parties for their direct marketing purposes. Before disclosing your data with third-parties or controllers (respectively defined under applicable law), we will provide you with notice and an opportunity to opt-out.

We may disclose your personal information with:

  • Our contractors, service providers, processors and other businesses that we use to support our business and to the following categories:
    • Website Hosting
      • Data storage centers, database solutions and internal development tools.
    • Administration Services
      • Billing, accounting, payment processing, customer relationship management (CRM), customer account maintenance, internal and external communication tools.
    • Service Delivery
      • Video encoding, content delivery, and customer service tools.
    • Mailing List
      • Email marketing as opted into by customers and other necessary transactional communications.
    • Website Interaction Technologies
      • Cookies, web beacons, tracking pixels and similar website interaction technologies
    • Contractor Services
      • Software engineering, video and written content creation and design, and other marketing services
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Adept is among the assets transferred.
  • To your organization’s designees, or any account administrator if any.
  • To other third parties with your express consent or that of your organization’s designees, if any.

We may also disclose your personal information:

  • To comply with a lawful request by public authorities, including valid court orders or to meet national security or law enforcement requirements.
  • To enforce our agreements with you, including for billing and collection purposes.
  • To prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity; this may include exchanging information with third parties for the purposes of fraud protection and credit risk reduction.

We accept full responsibility for any and all transfers of your personal data to third parties acting as our agents unless we can prove we were not a party giving rise to the damages.

Where We Keep Your Data

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff both within and outside the EEA who work for us or for one of our service providers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and/or the provision of support services. Your data is maintained in servers that are located in the United States, and your data may be processed in the United States, Mexico, Australia, United Kingdom, and countries for which there has been an adequacy decision and/or with appropriate safeguards. Not all of these countries are considered by the European Commission to offer adequate protection of your personal data. For these cases, Adept has put into place appropriate safeguards to ensure adequate protection of your data as well as other technical and organizational safeguards.

Data handled by our service providers is maintained in the United States. Our employees and contractors may, on occasion, process personal data through a dedicated and encrypted connection to this data. There is no data at-rest, only occasional data in-use. By submitting your personal data, you agree to this transfer, storing or processing as described in this Privacy Policy. Adept will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

We retain personal data for seven years from a User’s last system access or termination of the last subscription period, whichever is later, unless such data must be retained for the establishment, exercise, or defense of legal claims.

Your Rights

Through the Website you can access information regarding your recent transactions, your personal information, marketing preferences, and payment settings. With respect to your marketing preferences, you can unsubscribe from Adept marketing emails by following the unsubscribe link in any marketing email you receive. We offer marketing email recipients the opportunity to unsubscribe from further communications in every email, with the exception of non-commercial service emails, such as service orders, system updates, or support issues.

If your password or username is compromised, please notify us as soon as possible by using the contact information below. We reserve the right to reset passwords for inactive accounts or due to suspicious account activity.

Adept acknowledges that you may have certain rights relating to your personal information/data, subject to local data privacy laws (“Data Privacy Laws”). Depending on the applicable Data Privacy Laws, this may include the right to:

  1. Access your personal information that we maintain;
  2. Request that we correct any inaccuracies in your personal information;
  3. Request that we erase or delete your personal information;
  4. Request more information about how we process your personal information (subject to the public availability of such information in this Privacy Policy), including:
    1. Categories of your personal information processed
    2. Categories of the source of your personal information
    3. Business purpose for processing the specific categories of your personal information
    4. Categories of third parties that process your personal information
    5. Specific pieces of personal information collected
  5. To opt out of sharing your personal information with a “third party” or “controller” (excluding “service providers,” “businesses,” “contractors” or “processors”);
  6. Not be discriminated against for exercising your rights under applicable Data Privacy Laws; and
  7. Request that Adept transfer your personal information to another controller/business to the extent possible.

Appeal Process

Should you decide to request to exercise a right under an applicable Data Privacy Law, Adept may deny such request. If Adept declines to act regarding your request, Adept will notify you within 45 days of the receipt of the request and explain why. You may appeal the denial of your request by contacting the Adept Support Team as described in the Contact Information section of this Privacy Policy.

Data Privacy Framework

Data Subjects of the United Kingdom, European Union and Switzerland, please review the following information:

  1. Adept complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Adept has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Adept has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (“Principles”), the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit www.dataprivacyframework.gov/
  2. Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Please review the WHERE WE KEEP YOUR DATA section of this Privacy Policy for details on where data is processed and maintained. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to support@cbtnuggets.com. If requested to remove data, we will respond within a reasonable timeframe. For more information please review the YOUR RIGHTS section of this Privacy Policy.
  3. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents (contractors, service providers, processors and other businesses that we use to fulfill service delivery), or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to support@cbtnuggets.com.
  4. Please review the INFORMATION WE COLLECT section of this Privacy Policy for details on the types of personal data collected.
  5. Adept commits to apply the Principles to all personal data received from the EU, Switzerland, and the UK in reliance on the Data Privacy Frameworks.
  6. Please review the INFORMATION WE COLLECT section of this Privacy Policy for details on the purposes for which Adept collects and uses personal data.
  7. Please review the CONTACT INFORMATION section of this Privacy Policy for details on how to contact Adept with any inquiries or complaints.
  8. With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, Adept is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
  9. In certain situations, individuals can invoke binding arbitration. For more information, please review the CONTACT INFORMATION section of this Privacy Policy.
  10. Adept remains liable to third parties in cases of onward transfers.

Contact Information

ADEPT:

Any individual who seeks to exercise a right under an applicable Data Privacy Law should direct their query to the Adept Support team:

CBT Nuggets, LLC dba Adept
2850 Crescent Ave
Eugene, OR 97408

www.cbtnuggets.com/contactus
support@cbtnuggets.com
Toll-free, US only: 1-888-507-6283
International: +1 541-284-5522

UK DATA SUBJECTS:

If you are a Data Subject of the United Kingdom (UK), and have any concerns about our use of your personal information, you can make a complaint to us at support@cbtnuggets.com.

You can also contact the ICO if we have not addressed your concern in a satisfactory manner

The ICO's address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

EU DATA SUBJECTS:

If you are a Data Subject of the European Union (EU), and have any concerns about our use of your personal information, you can make a complaint to us at support@cbtnuggets.com.

You can also contact the EDPS if we have not addressed your concern in a satisfactory manner.

See: https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en

EDPS website: https://edps.europa.eu/_en

DPF INDEPENDENT RECOURSE MECHANISM:

In compliance with the EU-U.S Data Privacy Framework (EU-U.S DPF), the UK Extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework (Swiss-U.S DPF) Principles, Adept commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the EU-U.S DPF, the UK extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework Principles. European Union, United Kingdom, and Swiss individuals with inquiries or complaints should first contact Adept at support@cbtnuggets.com.

Adept has further committed to refer unresolved privacy complaints under the Data Privacy Framework program to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

CALIFORNIA CONSUMERS:

If you are a California Consumer, and have any concerns about our use of your personal information, you can make a complaint to us at support@cbtnuggets.com.

You can also contact the CPPA if we have not addressed your concern in a satisfactory manner.

How to file a complaint: https://cppa.ca.gov/webapplications/complaint

Contact Info:

CPPA
ATTN: PRA Coordinator
2101 Arena Blvd
Sacramento, CA 95834

PRA@cppa.ca.gov with the Subject: ATTN: PRA Coordinator

Unfortunately, no online data transmission can be fully guaranteed to be secure. Thus, by accessing the Website and/or utilizing the Services, you acknowledge that: (a) there are online security and privacy limitations that are beyond Adept’s control; (b) the security, integrity and privacy of any and all information and data exchanged between you and Adept through the Website cannot be fully guaranteed and we shall have no liability to you or any third party, unless otherwise provided by law, for loss, misuse, disclosure or alteration of such information not resulting from the direct tortious fault of Adept; and (c) any such information and data may be viewed or tampered with in transit by a third party.

Changes To This Privacy Policy

Adept shall post any revisions to this Privacy Policy on this web page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Website and this Privacy Policy to check for any changes.

Your continued use of the Services after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to be bound by the modified Privacy Policy.

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