This Privacy Notice was last updated on May 16, 2018.
This privacy notice applies to any Difference Consulting, LLC website, application, service, or tool (collectively “Services”) where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices.
3. Personal Information We Collect
Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
We collect personal information from you when you use our Services. The data we collect consists of:
Data that you provide directly when you register for, or use, the Services. This data will vary, but typically consists of name, email address, postal address, phone number, and other similar contact data. We also receive data from the communications you send to us, such as customer service inquiries, program questions, and other feedback regarding the Services.
User credentials, such as username, password, password hints and similar security information used to create an account and authenticate users of the Services.
Demographic data, such as age, gender, country, and language preference.
Payment data, such as credit card information and billing address.
Device data, such as type of device, operating system, and other software installed on the device, device settings, IP address, device identifiers and error reports.
Usage data, such as the programs and features you access, items you purchase, and the timing, frequency and duration of your interactions through the Services.
Location data, such as IP addresses received from your device.
Information about your interests and preferences, such as which free resources you download from our websites, which emails you open, or your communications preferences. In addition to what you provide directly, we may infer your interests and preferences from other data we collect, such as the content and advertisements you interact with while using the Services.
Third party integrations. If you connect your use of the Services through a third party service (e.g., a social media platform), the third party may share certain information from your third party account with us.
Other third party data, such as data from our affiliates, partners, or vendors, data brokers or public sources.
4. How We Use Your Personal Information
We use your personal information to provide and improve our Services, provide you with a personalized experience on our websites, contact you about your programs or purchases with us and our Services, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate, and investigate fraudulent or illegal activities.
We use the data we collect for the following purposes:
Operating our business. We use the data we collect to operate our business, including providing and improving the Services. Specifically:
To fulfill transactions that you request.
To diagnose and fix problems with the Services and providing other customer support services.
For analytical purposes to better understand our clients and community and how they use the Services, which allows us to continually improve and expand the Services.
To build predictive models, which allow us to tailor the Services based on the data we have about how our clients and target audience use the Services.
Communicating with you. We use the data we collect to communicate with you, including responding to your requests or inquiries. Specifically:
To respond to your request if you contact us with a question or concern.
To provide information about your access to our programs, your use of the Services, or other transactions that you request.
To deliver news, updates, and other types of communications, according to your subscriptions, alerts, and other preferences.
Marketing and advertising. We use the data we collect for marketing or advertising purposes, on behalf of ourselves, as well as our sponsors and other parties. Specifically:
To send you information content, promotional messages, and information about products, services, programs, or events that may be of interest to you. These may be offered by Difference Consulting, LLC, or by our partners and other third parties with whom we have a relationship.
The promotional messages and advertisements that you see may be determined by data that we collect or receive about you, such as your demographic data, location data, usage data, interests, and preferences. We refer to this as “interest-based advertising”.
Security, compliance and enforcement. We use the data we collect for security, compliance, and enforcement purposes. Specifically:
To protect the safety and security of our clients and our Services.
To detect and prevent abuse, fraud or other unlawful or unauthorized activities.
To resolve disputes.
To enforce our agreements, including our policies and terms of service that govern your use of the Services.
We may also use your data in any other manner as disclosed at the time of collection, or when we have otherwise obtained consent. Please also note that this Policy is not intended to place any limits on what we do with aggregated, pseudonymized, or anonymized data.
5. How We Might Share Your Personal Information
We may disclose your personal information to other members of the Difference Consulting, LLC family, or to third parties. This disclosure may be required for us to provide you access to our Services, to comply with our legal obligations, to enforce our User Agreement, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. We do not sell, rent, or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your consent.
6. How Long We Keep Your Personal Information
We retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies.
7. Cookies & Similar Technologies
8. How We Protect Your Personal Information
Difference Consulting, LLC takes data security seriously. We take a number of steps to protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.
These steps take into account the sensitivity of the data we collect and use, as well as the current state of technology. This includes, for example, storing your data on systems that have limited access and are maintained in controlled facilities. We also use, and require our vendors to use, industry standard security protocols when processing any payments for your use of the Services.
It is important to remember that no system can be guaranteed to be 100% secure. We recommend that you help us keep your data safe by taking reasonable steps such as keeping your passwords private and not disclosing sensitive personal data, such as credit card information, in places that can be accessed easily (such as via email).
9. Data Controller
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. Difference Consulting, LLC is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our privacy notice, as well as any applicable national laws.
We may change this Policy from time to time to reflect changes in our business, the Services, or our practices and procedures. If we do make changes, we will post any changes on this page and indicate the date on which the Policy was last revised. We encourage you to review this Policy periodically, especially before you provide personal data directly to us through the Services. Your continued use of the Services after any changes to this Policy are in effect constitutes your acceptance of the revised Policy.
11. How to Contact Us