iCohere End-User Data Privacy Policy
Effective starting: May 25, 2018
iCohere® is a hosted application that provides eLearning, collaboration and web conferencing software on behalf of subscribing organizations. iCohere, Inc. is a California corporation with a principal place of business at 1136 Saranap Ave. suite L, Walnut Creek CA 94595.
iCohere collects data on behalf of the client ("Subscribing Organization") that has licensed iCohere, for example, an association or organization where you are a member or employee. iCohere is the Data Processor of your Personally Identifiable Information which is collected through the use of our products. Our clients, the Subscribing Organization, are the Data Controllers.
Personal Data We Collect
We collect limited personal data and store it on behalf of the Subscribing Organization in order to operate effectively and provide our clients with product functionality. You provide some of this data directly, such as when you complete your user profile or take part in a webinar hosted through our systems, submit a support query to us, register for an event, upload a document, or contact us for support. We get some information by recording how you interact with our products by, for example, using technologies like cookies and session IDs, and receiving error reports or usage data from our software.
Confidentiality & Security of Personally Identifiable Information
We consider the confidentiality and security of your information to be of the utmost importance. We use industry standard physical, technical and administrative security measures to keep your Personally Identifiable Information confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases as permitted by applicable law. Because the Internet is not a 100% secure environment we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.
How We Use Personal Data
iCohere uses the data we collect on behalf of your Subscribing Organization to provide you the products we offer, which includes using data to improve our products and personalize your experiences. We also may use the data to communicate with you, for example, informing you or your subscribing organization about your account, security updates and product information. We do not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files to target ads to you. We do not provide or sell Personally Identifiable Information to third-parties. We also do not store personal financial information, age information or personal healthcare (HIPAA) information.
No Information from Children Under 16
We do not knowingly collect or maintain Personally Identifiable Information on our Site from persons under 16 years of age and no part of our Site is directed to persons under 16 years of age. If you are under 16 years of age, please do not use or access our products without the consent of your parent or guardian. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 16 years of age that has been collected in our products without verified parental consent upon learning of the existence of such Personally Identifiable Information.
Reasons We Share Personal Data
We share your personal data with others only as specified by your Subscribing Organization, such as other committee members or webinar attendees, or as necessary to complete any transaction or provide any product your Subscribing Organization has requested or authorized. We do not share personal data with other affiliates and subsidiaries or with third-party vendors working on our behalf. We may be compelled to share your personal data when required by law, or to respond to legal process; to protect our customers; to maintain the security of our products; and to protect the rights or property of iCohere.
How We Maintain Personal Data
We retain, manage and secure your personal data according to our Terms & Conditions with the Subscribing Organization. In general, this means we keep your data secure, do not share it with third-parties, and provide software tools to Site Administrators to manage and delete your personal data.
How Our Partners Store & Protect Your Data
iCohere system and user data is stored securely on servers managed by our hosting partner Cogeco Peer 1. Our hosting partner has published stringent data privacy protections which are explained here.
We interface with Cisco Webex systems to deliver web conferencing. The practices with respect to the Cisco WebEx Meetings are described here.
How to Access, Control and Delete Your Personal Data
If you would like to have your data deleted from our system, please contact us via email at Privacy@iCohere.com. You have the right to request that we:
We try to answer every email promptly where possible and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases for some time, including access logs and other records, which may contain your Personally Identifiable Information. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Deleting Application Data Other Than Profile Data
A key piece of the Personally Identifiable Information in our system is your User Profile. We can delete your User Profile information at any time, based on your request. For other information — active event registrations, transcripts and other non-profile data – please make your deletion requests to the Data Controller (Subscribing Organization), and they can delete any such items from their iCohere site(s) and/or ask for our assistance in doing so. If you do not know who to contact, please emails us at Privacy@iCohere.com and we will assist you with finding the right Subscribing Organization contact.
Questions, Suggestions and Complaints
If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via email at Privacy@iCohere.com.
Cookies & Similar Technologies
iCohere uses cookies for session management, and to enable saving your username and password for system login. We do not use cookies to track user activity. You have a variety of tools to control cookies including browser controls to block and delete cookies.
Notice to End Users
iCohere products are intended for use by organizations and are administered to you by your organization. Your use of our products is subject to your organization’s policies. When you use social features of such products, other users in your network may see some of your activity. iCohere is not responsible for the privacy or security practices of our Subscribing Organizations, which may differ from those set forth in this privacy statement.
Summary Of How iCohere Complies With General Data Protection Regulation and Other Data Protection Legislation
We require you to acknowledge iCohere's Privacy Policy the first time you log in.
We provide you with an email contact Privacy@iCohere.com so that you can request deletion of your account and data.
We will permanently delete your account and profile data once your request has been received via email and verified. Please allow three (3) business days for this operation to be completed, we will notify you via email when the deletion is complete. For non-profile data (registrations, transcript data, &etc.) you must contact the Subscribing Organization as described above.
We provide an option for you to export your profile data at any time.
If you are under 16 years of age, please do not use or access our products without the consent of your parent or guardian.
We report all system issues and any data breaches, within 72 hours of occurrence, to our Subscribing Organizations through the iCohere Users Group & Support Portal.
Revised May 2018.