Credly collects Personal Information when you choose to submit it through e-mail, an online form, or other method. We also collect information through cookies (see “Credly Use of ‘Cookies’ section below for detail).
Credly also maintains a log of certain information concerning visitors to our websites, including but not limited to, internet protocol (“IP”) address (a computer's numerical Internet address), third party websites from which visitors access our website, type of web browsers used, and pages viewed. Such information may be treated as Personal Information.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
THE CREDLY SERVICE
The Service is an internet-based, hosted platform designed to enable subscribers to the Service (“Issuers”) to issue digital badges and credentials (“Credentials”) to individuals who meet prescribed requirements (“Earners”), and for those Earners to display the Credentials online on the Service or on third party sites, as elected by Earners.
We may provide your information to trusted partners who work on behalf of, or with, Credly under confidentiality agreements to help Credly provide the Service. They may also assist Credly in communicating with you about the Service and about offers from Credly and our partners, where you have given us appropriate permissions.
Information about you that you give us
When registering for or using the Service, you may be prompted to give us information about yourself such as your name and email address. When you configure your account settings, you may enter additional information about yourself. You may also select user configuration settings that determine how the Service looks and functions. You may, at times, also send us an e-mail which may contain not only your e-mail address, but other information about you, including home or business addresses, telephone numbers, or account details. The information you give us may also include statements you make on the Service such as testimonials, services reviews, or other statements that may identify you personally.
We will provide you with a user ID (an e-mail address) and account activation e-mail for you to access the Service and create a user “profile” for use as described below. When you first sign onto the Service, you will be presented with your profile, which contains the information supplied to us. You will be able to update or correct any of the contact information in your profile. You may receive certain e-mails relating to your use of the Service. Your contact information is also added to Credly's directory of current and former users of the Service. If you receive another Credential from other Issuers, your user ID will be authorized to access the Service, and your contact information will be added to the participant list for that Issuer.
We may use your Personal Information to contact you regarding your use of the Service, for customer support purposes, and to inform you of updates, modifications and other matters relating to the Service, and information about others services that we offer in accordance with your subscription preferences. You may decline to receive mail or e-mail from us that does not relate directly to your access to or use of the Service by selecting the opt-out link contained in any such e-mail or by contacting us at email@example.com.
Credly also will maintain a history of your access to the Service, and certain actions taken by you while accessing the Service, a log of users' IP addresses, the third-party Website from which users access the Service, the type of web browsers used to access the Service and the browser's settings that may affect Service performance (collectively, “Usage Log Information”). For purposes of maintaining and enhancing Service performance and security, Credly may use Usage Log Information, information about your browser, and other local computer settings. We also may use Usage Log Information to tailor our communications to you about the Service, and contact you in relation to providing support. We also may aggregate Usage Log Information to create or publish statistical analyses and reports about Service usage. We will not authorize the publication of Personal Information about any user without the prior written consent of such person.
Information about You Received from Issuers
Issuers provide Personal Information to us, including Credential requirements, and information about you to confirm that you have earned the applicable Credential. The use of information collected from Issuers shall be limited to the purpose of providing the service for which these Organizations have engaged Credly.
If you are an Issuer, by using the Website or Services, you confirm that you have obtained prior, specific, and informed consent to provide Personal Information to us. We may request a copy or evidence of such consent.
Credly collects information under the direction of the Issuer, or as provided directly to Credly by the Earner. If you are a customer of one of the Issuers and would no longer like to be contacted by one of the Issuers that use our service, please contact the Issuer that you interact with directly.
An individual who seeks access, or who seeks to correct or amend inaccurate Credentials should direct their query to the Issuer. We retain Personal Information we process on behalf of the Issuers for as long as needed to provide services to the Issuers and the Earners. Credly shall continue to make the Service available to Earners, including in cases where the Issuer terminates its use of the Service. Individual Credentials and an Earner’s entire account may be deleted by the Earner at any time directly through the Service. Credly will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Information about You Received from Third-Party Services or Other Users
If you log into the Service using credentials associated with your account at third-party services such as Facebook, LinkedIn, or Twitter (collectively, “Third-Party Services”), you thereby authorize Credly to access certain information associated with your account with the Third-Party Service, based on the privacy settings you establish at the Third-Party Service. Please review the privacy policies of any Third-Party Services from which you access the Service (please see Third-Party Sites Section below regarding use of those Third-Party Services).
If you utilize a Third-Party Service to log into the Service, other users to whom you may be connected through such Third-Party Service may able to see that you are a user of the Service or may view or follow information about you on the Service.
Information about You Received from Mobile Application
When you download and use the Service via our mobile application, we automatically collect information on the type of device you use, operating system version, user identification, and device identifier.
We may send you push notifications. You may turn off push notifications at the device level.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any Personal Information you submit within the mobile application.
Additional Uses of Service Information
In addition to the uses described above of the information received in connection with your use of the Service, Credly uses and, where specified, shares your information:
- To display Credentials. Credly may use your information to display Credentials that you receive through the Service or through Third-Party Services, embeds that you make on the Service or third parties’ Website, or on social network services you link to your account.
- To provide support or other services that you have requested, and to respond to your inquiries.
- To engage in transactions with you, including contacting you about your account or transactions.
- To process transactions, Credly may use financial, credit card and payment information that you provide. Credly may need to share some of this information with suppliers, delivery services, credit card clearing houses and other third parties to complete the transactions.
- To notify you of relevant opportunities such as new product releases and service developments, related facts or programming that may be relevant to you.
- To provide online forums and social networks. The Service allows users the option to participate in interactive discussions and post comments and other content. Note that any information you share may become publicly accessible.
- To improve quality and facilitate use of the Service.
- To comply with legal requirements. In addition, we may also disclose information about you as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is reasonably necessary to enforce our rights or protect our operations or users or others investigate fraud, or in response to legal processes or governmental investigations in accordance with our internal policy on access by governmental authorities, or under exigent circumstances in response to a perceived significant threat to a person's health or property.
The device you use to access the Website or Service may provide your location to us. This information may be shared with Issuers in connection with the issuance of Credentials, where location is relevant to completion of the achievement recognized by the Credential.
The Service allows you to customize the information about yourself that is made accessible to others. When you establish an account, the Service applies default settings. Default settings also apply to new features introduced on the Service. Credentials issued to you will default to the “public” setting. You may activate a “private” setting such that the Credential will no longer be publicly accessed at any time, on a Credential-by-Credential basis. Until you terminate your use of the Service, the fact that you are a user, as indicated by the public display of your full name and avatar, is available to others on the Service. Review your privacy settings regularly to ensure that they match your preferences.
We protect the security of your information during transmission by using Transport Layer Security (TLS) and Secure Sockets Layer (SSL) software or other encryption technology, which encrypts information you input. Wherever appropriate, we obfuscate and/or encrypt information in our systems and/or during information transfer. Credly regularly reviews the cryptographic protocols it uses to protect the privacy and security of your Personal Information.
Because of the nature of internet and for other reasons, we cannot guarantee the security of your Personal Information, so you should take precautions to protect it when you are on the internet, such as changing passwords often, using a combination of letters and numbers when creating passwords, using a secure browser and being sure to log off the Service when finished using a shared computer.
Your California Privacy Rights
If you reside in California, under California Civil Code Section 1798.83, a California resident with a business relationship with Credly that is primarily for personal, family or household purposes, may request certain data regarding Credly’s disclosure, if any, of Personal Information to third parties for the third parties’ direct marketing. To make such a request, please send an e-mail to firstname.lastname@example.org with "Request for California Privacy Information" in the subject line. You may make such a request once per calendar year. If applicable, we will provide you a list of the categories of Personal Information disclosed to third parties for their direct marketing during the immediately preceding calendar year, along with the third parties' names and addresses. Not all Personal Information sharing is covered by Section 1798.83.
Information collected by Electronic Communications Protocols and Web Beacons
We may collect information about you and your use of the Service through electronic communications protocols, web beacons, cookies, embedded URLs, pixel tags and related devices or technologies.
As is true when you visit most websites, certain information is automatically generated and stored about your visits. Such information may include: network routing information (for example, where you came from); equipment information (for example, device type, operating system, browser type); IP address, and dates and times of your visits.
We may use your Personal Information to inform you about other Credly services that might interest you and to gather feedback from you.
Credly Use of "cookies"
We use the following cookies:
- Strictly necessary cookies required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website.
- Analytical/performance cookies that collect information about how you use our Website. They allow us to recognize and count the number of visitors and to see how visitors move around our Website. This helps us to improve the way our Website work. These cookies are sometimes placed by third party providers of web traffic analysis services, such as Google Analytics.
- Functionality cookies that remember choices you make and recognize you when you return. This enables us to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies that collect information about your browsing habits such as the pages you have visited and the links you have followed. We use this information to make our Website more relevant to your interests, and, if we enable advertising, to make advertising more relevant to you, as well as to limit the number of times you see an ad. These cookies are usually placed by third-party advertising networks. They remember the other Website that you visit and this information is shared with third-party organizations, for example advertisers.
We use Google Analytics. For information on how Google processes and collects your information regarding this product and how you can opt-out, please see https://tools.google.com/dlpage/gaoptout.
Credly and its service providers, vendors and partners, may use cross-device/cross-context tracking. For example, you might use multiple browsers on a single device, or use various devices (such as desktops, smartphones, and tablets), which can result in your having multiple accounts or profiles across these various contexts and devices. Cross-device/cross-context technology may be used to connect these various accounts or profiles and the corresponding data from the different contexts and devices.
Third-Party Cookies and Functions
Your European Data Protection Rights
If you reside in the European Economic Area (“EEA”), subject to certain exceptions, you have a right to:
- Learn whether we are processing your Personal Information and, if so, to gain access to it and certain information about it.
- Have inaccurate Personal Information corrected or removed, and have incomplete Personal Information completed.
- Have your Personal Information erased when:
- It is no longer necessary for the purposes collected;
- You withdraw consent to process it;
- We have processed it unlawfully; or
- EU or Member State law to which we are subject requires erasure.
- Restrict our processing of your Personal Information when:
- You contest its accuracy (for a period necessary to verify it);
- The processing is unlawful and you prefer restriction of use to erasure; or
- We no longer need the data, but you need it in connection with legal claims.
- Obtain in usable form the Personal Information you gave us and, if technically feasible, require its transmittal directly to another controller that you designate.
- Lodge a complaint with a Member State data protection supervisory authority.
If you reside in the EEA, Credly will process your Personal Information in accordance with all applicable data protection legislation.
Do not send us any sensitive Personal Information (e.g., social security numbers or other national identifiers, or information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life or sexual orientation, genetic or biometric information, criminal background, or trade union membership).
Access, Retention and Deletion
Upon request Credly will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account or contacting us at email@example.com. We will respond to your request within a reasonable timeframe.
Viewing of Data for Support
For the purpose of providing the Service and associated support including answering any questions you may have, Credly may view and process your Personal Information from nations outside the EEA that are deemed by the EU to have non-adequate data protection laws, including the United States.
Use by Minors & COPPA Compliance
The free version of the Service is intended for use by adults only. Credly does not promote online to children and does not intentionally collect any personally identifiable information from children under the age of thirteen, except for pursuant to the COPPA-Compliant solution described below. If you believe that a person under the age of thirteen has disclosed Personally Identifiable information through the Service, other than through the COPPA-Compliant solution, please report this to us immediately by e-mailing us at: firstname.lastname@example.org with “Notice of Underage Person” in the subject line.
Credly complies with the Children’s Online Privacy Protection Act (“COPPA”), and offers an alternative version of the Service for children under the age of thirteen and the Issuers that serve them. The COPPA-compliant Service is available only through Credly’s paid, enterprise-level offering, including a private credential catalogue and management environment accessible only to students and authorized school officials. Schools working with Credly to offer digital credentials to children under 13 represent to Credly that they have obtained parental consent directly or that they act as parents’ agents and provide consent on parents’ behalf.
You will be notified via email or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. You have the right to request that your Personal Information be removed from our records at any time.
349 5th Avenue
New York, NY 10016-5019
Attention: General Counsel