Privacy Policy for U.S., U.K. & Canada

This Privacy Policy describes Sandler Systems, Inc.’s (“Sandler”, “we” or “us”) practices
regarding the collection, use and disclosure of the information we collect from and about you
when you use Sandler’s learning management system known as Sandler Online.
By accessing or using Sandler Online, you agree that you have read and understand this Privacy
Policy and that you accept and consent to the privacy practices and uses or disclosures of
information about you that are described herein.
In order to deliver personalized and relevant information to you through Sandler Online, we
collect certain information from users. Please do not provide any sensitive information or health
information. We do not want, nor will we ask for sensitive information. Sandler Online is not
designed to process sensitive information.
Information We Collect
We collect personal information, such as your name, email address, phone number and contact
information, company name, title, division, industry and location when you log in. We also
collect other information, such as your trainer’s name, manager’s name, franchisee affiliation,
survey feedback and referral names when you use Sandler Online. We may also deliver surveys
and inquire about voluntary client testimonials based on the programs offered. If you make a
purchase, we will collect your payment, billing and shipping information.
We also collect information about you from third party sources, such as your employer, other
Sandler franchisees, and our third-party partners. Information we collect about you from these
third parties includes your name, title, company name, address, phone number, referring training
location, website address, email address, social media profiles, and demographic data such as
number of employees at your company and course content interests. This Privacy Policy
describes Sandler's collection and handling of your personal information, you should also refer to
the privacy notices of any third parties in respect of their disclosure of your personal information
to us.
Information We Automatically Collect
We may automatically collect the following information about your use of Sandler Online
through cookies, web beacons, and other technologies: your domain name; your browser type
and operating system; web pages you view; links you click; your IP address; the length of time
you visit or use Sandler Online; and the referring URL, or the webpage that led you to Sandler
Online. Some of this information may be treated as personal information, in accordance with
applicable local laws. We may combine this information with other information that we have
collected about you, including, personal information. Please see the section “How We Use
Cookies” below for more information.
How We Use Cookies
We use “cookie” technology to collect additional web site usage data and to improve Sandler
Online and our service. A cookie is a small data file that we transfer to your computer’s hard
drive through your web browser (if you allow) that enables us to recognize your browser and
capture and remember certain information. We can correlate the cookie to the user’s login name
in our database and then determine the name of the user. We do not otherwise use cookies to
collect personally identifiable information. We use cookies to compile aggregate data about site
traffic and site interactions, in order to improve the LMS and our products and services, to offer
better site experiences and tools in the future, and to display personalized content and materials
(including marketing materials) within the LMS.
You can choose to have your computer warn you each time a cookie is being sent, or you can
choose to turn off all cookies. You do this through your browser settings. If you turn cookies
off, some features will be disabled, and some of the features that make Sandler Online
experience more efficient may not function properly.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique
identifier, similar in function to cookies. In contrast to cookies, which are stored on your
computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs
(a.k.a. web beacons, web bugs or pixel tags) in connection with Sandler Online to, among other
things, track the activities of visitors and users, help us manage content, and compile statistics
about usage of Sandler Online. We and our third-party service providers also use clear GIFs in
HTML emails to our customers, to help us track email response rates, identify when our emails
are viewed, and track whether our emails are forwarded.
Third-Party Analytics. We use automated devices and applications, such as Google Analytics,
to evaluate usage of Sandler Online. We also may use other analytic means to evaluate Sandler
Online. One of our providers is Google Analytics and more information about the ways in which
they process your personal information can be found here:
https://www.google.com/policies/privacy/partners. We use these tools to help us improve
Sandler Online, the site’s performance and user experiences. These entities may use cookies and
other tracking technologies to perform their services. We do not share your personal information
with these third parties.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You
may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Use of Your Information
We may use the information we collect from you in the following ways:
 To provide our services to you, including to deliver appropriate training and email
training notifications to you and/or your manager.
 To track your progress in completing courses.
 To deliver products and certificates for selected programs.
 To personalize your experience and to allow us to deliver the type of content and product
offerings in which you are most interested.
 To ask for ratings and reviews of our services and products.
 To improve Sandler Online in order to better serve you.
 To contact you for marketing purposes, including to send you personalized and relevant
information through email and text messaging in accordance with local law and consent
requirements. You may unsubscribe from our mailing lists at any time by using the
“unsubscribe” feature in any marketing emails you receive from us.
 To provide customer support and to follow up with you after correspondence (live chat,
email or phone inquiries).
 To understand the lessons learned.
 To calculate certification credit hours.
 To offer and deliver content based on vertical markets and/or your initial training path.
 To comply with applicable legal obligations, including responding to a subpoena or court
order.
 Where we believe it is necessary to investigate, prevent or take action regarding illegal
activities, suspected fraud, situations involving potential threats to the safety of any
person or violations of our Terms of Use or this Policy.
Security
We have put in place security measures to safeguard and secure the information we collect in
Sandler Online. Nonetheless, the transmission of information via the Internet is not completely
secure and therefore we cannot guarantee the security of data sent to us electronically in Sandler
Online, and transmission of such data is therefore entirely at your own risk.
Disclosing Your Information
The information you enter into Sandler Online may be shared amongst our Sandler trainers and
franchisees, and your employer, supervisors and managers, who may also use your information
for the purposes set forth in the “Use of Your Information” section above. We do not allow the
franchisees and trainers to use the personal information you enter into Sandler Online for their
own direct marketing use. We also may disclose the information we collect from you to thirdparty
vendors, service providers, contractors or agents who perform functions on our behalf. We
take appropriate steps to ensure that such third parties treat your personal information with the
same consideration that we do. We do not sell, trade, or otherwise transfer to outside parties your
personally identifiable information.
Sandler Systems, Inc. is a U.S. company, and our trainers and franchisees may be based in the
United States and in other jurisdictions that do not have equivalent data protection laws to your
home jurisdiction. In accordance with local laws, we will take steps to ensure that your personal
information receives an adequate level of protection as required by applicable law, such as
through the use of the EU standard contractual clauses approved by the European Commission,
relevant national equivalents outside the EU, or other safeguards as permissible. By providing us
with your personal information, you expressly acknowledge that we may transfer your personal
information to, or access it in, jurisdictions which may not provide equivalent levels of data
protection to your home jurisdiction.
We may also share information in the following circumstances:
 Business Transfers. If we are acquired by or merged with another company, if substantially
all of our assets are transferred to another company, or as part of a bankruptcy proceeding,
we may transfer the information we have collected from you to the other company.
 In Response to Legal Process. We also may disclose the information we collect from you in
order to comply with the law, a judicial proceeding, court order, or other legal process, such
as in response to a court order or a subpoena.
 To Protect Us and Others. We also may disclose the information we collect from you where
we believe it is necessary to investigate, prevent, or take action regarding illegal activities,
suspected fraud, situations involving potential threats to the safety of any person, violations
of our Terms of Use or this Privacy Policy, or as evidence in litigation in which Sandler is
involved.
 Aggregate and De-Identified Information. We may share aggregate or de-identified
information about users with third parties for marketing, advertising, research or similar
purposes.
Special Information for California Consumers; Your California Privacy Rights
California residents may request a list of all third parties to which we have disclosed certain
personal information about you for the third party’s own marketing purposes. You may make
one request per calendar year. In your request, please attest that you are a California resident and
provide a current California address for our response to you. We will respond to you within
thirty (30) days. You may request this information in writing by contacting the Privacy Officer
identified in section “Contacting Us” below.
Third-Party Web Sites and Interaction
Sandler Online may contain links to third-party web sites or applications which are outside our
control and are not covered by this Privacy Policy. If you access other sites or applications using
the links provided, the operators of those sites may collect information from you which will be
used by them in accordance with their privacy policy and terms of use, which may differ from
ours. We do not accept any responsibility or liability for their policies whatsoever as we have no
control over them.
Users Only of Legal Age of Majority
Sandler Online is designed and may only be used by those who have reached the age of majority
(18 years of age in most jurisdictions). By using Sandler Online, you affirm that you are at least
18 years of age or older. We are not liable for any damages that may result from a user’s
misrepresentation of age.
Access to Information
If you believe that any information we are holding about you is incorrect or incomplete, or have
any complaints about Sandler Online, please inform us as soon as possible at the address below.
We will respond to your request in accordance with applicable local law.
You can also update certain of your personal information by logging in in to your account.
Please note that we may maintain a copy of any personal data that you have updated for a period
of time as part of our backups and business records; please see the “Retention of Your
Information” section below for an explanation of our retention practices.
EU users have additional rights in respect of your personal information; for example, to access or
erase your personal information, object to our use of it, or require it be made available in a
portable format. If these rights apply to you, and you would like to exercise them, please contact
us using details set out below.
Retention of Your Information
Sandler Online applies a general rule of keeping your personal information for only as long as is
required to fulfil the purposes for which it was collected. However, in some circumstances we
may retain personal information for longer periods of time, for instance where we are required to
do so in accordance with legal, tax or accounting obligations, or where we would like to have an
accurate record of your dealings with us in the event of any complaint or challenge.
Changes to this Policy
We do update this Privacy Policy from time to time so please review this Privacy Policy
regularly. If we materially alter our Privacy Policy, we will notify you of such changes by
posting a notice in Sandler Online. Your continued use of Sandler Online will be deemed your
agreement that your information may be used in accordance with the new policy. If you do not
agree with the changes, then you should stop using Sandler Online and you should notify us that
you do not want your information used in accordance with the changes.
Contacting Us
We welcome any queries, comments or requests you may have regarding this Privacy Policy.
Please do not hesitate to contact us at:
Shannon Haaf Howell, Privacy Officer
Sandler Systems, Inc.
300 Red Brook Blvd, Suite 400
Owings Mills, MD 21117
USA
410-653-1993
[email protected]
EU Data Controllers: Sandler Systems, Inc. (contact information above) and the corresponding
franchisee. The applicable address and contact information of the franchisee can be found here:
https://www.sandler.com/training-centers.
Effective Date: January 1, 2017