Privacy Policy
This Privacy Policy (the “Policy”) describes how Burgett Enterprises, LLC and/or its affiliates (collectively, “BE,” “we,” “us,” or “our”) collect and use information, including the personal information you provide on this website www.nationalcioreview.com (this “Website”) in connection with our services provided through this Website (“Services”). Our members (“Members”) share their professional identities, engage with other Members, exchange knowledgeable and professional insights, post and view relevant content, learn and develop skills, and find business and career opportunities. Some of our content and data is viewable to non-Member visitors (“Visitors”). We remind you to carefully protect the personal information you submit to this Website – including your passwords, usernames, location, images, and videos – to avoid third party manipulation of identity theft.
Data We Collect
Data You Provide. We collect data that you provide to us via registration of your Member account, such as your name, email address, and/or phone number, and a password. If you register for a membership, you will need to provide payment (e.g. credit card) and billing information. We collect data from your membership profile, such as your work experience, photo, and city or area. It is your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available. We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form (e.g., with demographic data) or respond to a survey on our Services. If you opt to import your address book (if this feature is available), we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list). We log usage data when you visit or otherwise use our Services, including our sites and platform technology, such as when you view or click on content (e.g., learning video) or ads (on or off our sites), perform a search or share articles. We may use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use. When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we may receive the URL of both the site you came from and the one you go to and the time of your visit. We may also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP). If you use our Services from a mobile device, that device may send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
Data From Others. You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. We also may collect public information about you, such as professional-related news and accomplishments, and make it available as part of our Services, including in notifications to others. We may receive personal data (including contact information) about you if others send messages using our Services. If you or others opt-in to sync email accounts with our Services (if available), we will also collect “email header” information that we can associate with Member profiles. We may receive personal data (e.g., your job title and work email address) about you when you use the services of our customers and partners, such as employers or prospective employers and applicant tracking systems providing us job application data. We may receive data about you when you use some of the other services provided by us or our affiliates. Others buying our Services for your use, such as your employer, may provide us with personal data about you and your eligibility to use the Services that they purchase for use by their workers. Our Services are dynamic, and we often introduce new features, which may require the collection of new information.
How We Use Your Data
Services. How we use your personal data may depend on the Services you use and how you use those Services. We use the data that we have about you to provide and personalize our Services to you, to fulfill contractual relationships with you, to respond to your inquiries and fulfill your requests, to send you important information regarding our Services, changes to our terms, conditions, policies, and other administrative information, and where we have a legitimate, beneficial interest in using personal information to conduct our business. We may share personal information and/or personal user content with our affiliates, including (but not limited to) parent companies and subsidiaries. We may use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you) to personalize our Services for you. We may use your data to recommend jobs or mentees, show you and others relevant professional contacts (e.g., who work at a company, in an industry, function or location or have certain skills and connections). You can signal that you are interested in changing jobs and share information with recruiters. We may use your data to recommend jobs to you and refer you to recruiters. We may use automated systems to provide content and recommendations to help make our Services more relevant to our members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services. We may use your data to research social, economic and workplace trends, such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we may work with trusted third parties to perform this research. We may use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our Members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights. We may use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of this Website’s Terms and Conditions (the “Agreement”) and/or attempts to harm our Members, Visitors or others.
Advertising. We may target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety ofpartners, using the following data, whether separately or combined:
- Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;
- Member-provided information (e.g., profile, contact information, title and industry);
- Data from your use of our Services;
- Information from advertising partners, vendors and publishers; and
- Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using first names or pronoun usage to infer gender; using your feed activity to infer your interests; or using device data to recognize you as a Member).
If you take a social action (such as like, comment or share) on ads, your action may be associated with your name and viewable by others, including the advertiser. If you take a social action on this Website or using the Services, that actionmay be mentioned with related ads.
We do not share your personal data with any unaffiliated third-party advertisers or ad networks except for: (i) with your separate permission or (ii) data already visible to any users of the Services. However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.
Marketing. In addition to advertising our Services, we use Members’ data and content for invitations and communications promoting membership and network growth, engagement and our Services, such as by showing Members that you have used a feature on our Services.
How We Share Information
Our Services. Your profile is fully visible to all Members and customers of our Services. Our Services allow viewing and sharing information including through posts, likes, follows and comments. When you share an article or a post publicly it can be viewed by everyone and re-shared anywhere Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one). In a group, posts are visible to others in the group. Any information you share through companies’ or other organizations’ pages on our Services may be viewable by it and others who visit those pages. When you like or re-share or comment on another’s content (including ads), others may be able to view these “social actions” and associate it with you. We may share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we may personalize your feed based on your learning history.
Others’ Services.Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
Legal Disclosures. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect our rights and safety and the rights and safety of our Members, personnel or others. We may notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Change in Control or Sale. We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy, as may be amended.
“Cookies” – Information Stored Automatically on Your Computer or Device
We or our third party partners may collect and store certain information from your browser using “cookies.” A cookie is a piece of data (a small file, with typical content of letters and numbers) stored or downloaded on a user’s computer or other device that can be tied to information about the browser’s activities on this Website. Our cookies allow us to provide certain features of this Website. For example, among other things, we may use cookies to keep track of your preferences, conduct support and debugging, understand the duration of user’s session, and to estimate and report our total audience size and traffic. We also may use cookies to improve the content and services it provides to its users. By default, we may use a persistent cookie that stores your login ID and password to make it easier for you to login when you come back to this Website.
In addition, we may advertise using remarketing technology. In doing so, a third-party may place or read a unique ad-serving cookie on your computer or device and may use non-personal information about your browser and your activity at this site to serve ads on their content network. The ad-serving cookie is a persistent cookie.
If you want to delete or block any cookies, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of this Website.
We or our third party advertising partners may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us improve our site, for example to better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on webpages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ personal information.
We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our site to personalize your visit. Third parties, with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity, may also use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of data, type of data, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn about privacy and storage settings for Flash cookies that may be available, you can click here. Please note that we do not provide this information and are not responsible for its accuracy.
Safeguards. We have reasonable organizational, technical, and administrative measures in place to protect against the loss, misuse, and alteration of personal information about users of the online systems which is under our control. Unfortunately, however, no security system, or system of transmitting information over the Internet can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised or your user credentials are no longer secure), please immediately notify us of the problem by contacting us.
Do Not Track. At this time this Website does not recognize “Do Not Track” browser signals.
Lawful Bases for Processing. We will only collect and process personal data about you where we have lawful bases. Lawful bases include (but are not limited to) consent, contract and the progress of our legitimate interests such as, protecting you, us, or others from threats, comply with laws that apply to us, enable or administer our business, manage corporate transactions, and understand and improve our business or customer relationships generally. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
Children
We will not knowingly collect personal data from children without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. The definition of “child” or “children” should take into account applicable laws as well as national and regional cultural customs. The Website and our services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide their personal information through this Website.
Links to Other Web Sites
This Website may contain links to other websites. We are not responsible for the privacy practices or the content of other websites.
When you make a purchase on the Services, any credit card information you provide as part of your payment information is collected and processed directly by our payment processor Stripe through their Stripe API. We never receive or store your full credit card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with their own Privacy Policy here: https://stripe.com/us/privacy.
Retention
We retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). This includes data you or others provided to us and data generated or inferred from your use of our Services. In some cases, we may choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form. The criteria used to determine our retention periods include: the length of time we have an ongoing relationship with you; a period beyond the ongoing relationship if we have a legitimate internal operations need; a legal obligation to which we are subject; or whether retention is advisable considering our legal position.
Changes
Our privacy practices and this Privacy Policy are subject to change. We will post changes to our Privacy Notice on this page and you can determine when this Policy was last revised by checking the “Revised Date” legend at the bottom of the Policy. Please check this page regularly to keep up-to-date.
For California Residents
When applicable, California residents and consumers have certain rights, including the following:
California Civil Code section 1798.83 allows California residents who provide Personal Information (as defined by the California Consumer Privacy Act (“CCPA”) to a business to request and obtain information about the Personal Information the business disclosed to third parties for direct marketing purposes.
Under the CCPA, California consumers have the following rights, subject to conditions and limitations contained in the CCPA:
The right to request, at no charge, that we disclose to you the categories and specific pieces of Personal Information we have collected in the prior 12 months.
The right to request that we disclose certain information about how we have handled your Personal Information in the prior 12 months, including the categories of Personal Information collected about you; categories of sources from which we collected your Personal Information; business purposes for collecting and sharing your Personal Information; and categories of third parties with whom your Personal Information has been shared; and the specific pieces of Personal Information collected about you.
You have the right to obtain a list of categories and a copy of the Personal Information, in a portable and (if technically feasible) readily usable format, collected on you covering the 12-month period preceding the request.
Subject to certain conditions and limitations, you have the right to request the deletion of your Personal Information we have collected from you.
You have the right to be free from discrimination for exercising exercise your rights under the CCPA.
To exercise California privacy rights, it may be necessary for us to verify your identity, your authority to make the request, confirm that the Personal Information relates to you, and that you are otherwise legally eligible to exercise such rights. To do this, we will ask you to supply information we have previously collected about you.
You may exercise your California rights by emailing us at publications@nationalcioreview.com.
Last Revised: 25 March 2022
