GoSignMeUp Privacy Policy

GoSignMeUp complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  GoSignMeUp has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

GoSignMeUp

GoSignMeUp is an online registration platform enabling people to search, sign-up and pay for both online and in-seat courses.  Our platform allows administrators to create, share and promote courses which users can then sign-up and participate in. 
GoSignMeUp is a software as a service product with features and offerings are available online through various GoSignMeUp properties and through mobile applications, web pages, application programming interfaces, and subdomains and are collectively referred to as “GoSignMeUp” or our “Services”. 

Definitions

When this Privacy Policy uses the term “Administrator” we mean course creators using the Services to create courses for consumers using our Services (a) to consume information about, or attend, courses (“Consumers”), or (b) for any other reason. Administrators, Consumers and third parties using our Services are all referred to in these Terms collectively as “Users”, “you” or “your”. 

GoSignMeUp, Inc. is an LLC with its principal place of business at 22431 Antonio Pkwy, Suite B160-656, Rancho Santa Margarita, CA 92688 (“GoSignMeUp,” “us,” “we” or “our”).

If you have any questions or concerns at any time, please do not hesitate to contact us at the address above or by contacting us at support@GoSignMeUp.com. 

Our Privacy Statement

Application

This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person (“Personal Data”) that is collected from Users on or through the Services. We take the privacy of your Personal Data seriously. Because of that, we have created this Privacy Policy. Please read this Privacy Policy as it includes important information regarding your Personal Data and other information. 

“Non-Personal Data” as used in this Privacy Policy is therefore any information that does not relate to a person and/or cannot be used to identify a person. When you interact with the Services, we may collect Non-Personal Data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data.

Personal Data That We Collect

When you use or interact with us through the Services, we may collect Personal Data. Sometimes this will be on our own behalf and other times this will be on behalf of an Administrator using our Services to run a course. This is an important distinction for EU data protection law purposes and is explained in more detail below. 

All Users

Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with inquiries, respond to one of our surveys or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and other information that enables Users to be personally identified. 

Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Services (“Automatic Data”). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Services, information about how you came to the Services.

When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you. 

Administrators

As an Administrator we will collect additional Personal Data from you. 

For transactions requiring payment, GoSignMeUp uses third-party credit card processors.  We do not have access nor do we store any of this credit-card related information. 

Consumers

As a Consumer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of an Administrator (see  below for more information). 

Information you provide via GoSignMeUp Properties or Applications: If you register for a paid course, you will provide financial information (e.g., your credit card number and expiration date, billing address, etc) none of which is collected by GoSignMeUp, but is necessary for the third-party credit card processors to conduct the secure transaction.
In addition, Administrators can set up course registration pages to collect virtually any information from Consumers in connection with registration for an Administrator’s course listed on the Services. GoSignMeUp does not control an Administrator’s registration process nor the Personal Data that they collect. Personal Data collected on behalf of Administrators is provided to the Administrator of the applicable course in accordance with “How We Disclose and Transfer Your Personal Data: Administrators” below. 

Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as Administrators or other third party integrations. 

How We Use Your Personal Data

We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may use the Personal Data as follows: 

Specific Reason

If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came. 

Access and Use

If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services. 

Internal Business Purposes

We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identity or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business. 

GoSignMeUp Marketing Communications 

Where it is in accordance with your marketing preferences, we may use your Personal Data to contact you in the future for our marketing and advertising purposes, including without limitation, to inform you about services or courses we believe might be of interest to you, to develop promotional or marketing materials and provide those materials to you, and for news relating to changes and updates to GoSignMeUp.

Administrator Emails

We allow Administrators to use our email tools to contact Consumers for their current and past courses, so you may receive emails from our system that originate with such Administrators and that we send on their behalf. If you registered for a course on the Services, your email address is available to that Administrator. The Administrator and not GoSignMeUp is responsible for sending these emails.  

Other Purposes

If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use. 

How We Disclose And Transfer Your Personal Data

No Sale

We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below. 

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of GoSignMeUp (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy. 


Agents, Consultants and Service Providers

We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of GoSignMeUp to perform certain business-related functions. These companies include our marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions. 

Administrators

When you purchase or register for a course through the course page, or through a related search page on the Services, we provide the Personal Data entered on the applicable course to the Administrators of such course page. We are not responsible for the actions of these Administrators, with respect to your Personal Data. It is important that you review the applicable policies of the Administrators, of a course before providing Personal Data or other information in connection with that course.

Similarly, if you are a member of an Administrator’s organization within GoSignMeUp, your Personal Data will be available to the Administrator and shared with those Third Party Administrators granted permission by the Administrator to view all members of the Administrator’s organization. 

Facebook and Other Third Party Connections

You can connect your GoSignMeUp account to your accounts on third party services like Facebook, however GoSignMeUp does not collect any data during this process, rather only shares the course links and information related to the course with the social media platform. 

Legal Requirements

We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability. 

How We Store Your Personal Data

We may store Personal Data itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the Personal Data collected via the Services from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.

How You Can Access, Update, Correct or Delete Your Personal Data

You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data that we process about them. 

If you are a registered User, you can exercise these rights by logging in and visiting the My Account page. Both registered and unregistered Users may also exercise these rights by contacting us directly by email or at the address specified below. 

If a Consumer initiates a data deletion request, GoSignMeUp is authorized to delete or anonymize Personal Data of the requesting Consumer from the Services even if that means removing its availability to the Administrator through the Services. However, if you are a Consumer, you understand that even if GoSignMeUp deletes or anonymizes your Personal Data upon your request or pursuant to this Policy, your Personal Data may still be available in the Administrator’s own databases if transmitted to the Administrator prior to GoSignMeUp receiving or taking action on any deletion or anonymization activity. 

We will consider and respond to all requests in accordance with applicable law. 

How Long We Retain Your Personal Data

We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

Cookies, Web Storage And Similar Technologies

GoSignMeUp uses cookies only to identify the current unique user session.  We do not use cookies for marketing or tracking purposes.

Your Choices 

You have several choices available when it comes to your Personal Data: 

Limit the Personal Data You Provide

You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services. For instance, in order to register for courses as an Consumer, your name and email address will be required by the Administrator. 

Opt Out from Electronic Communications

GoSignMeUp Marketing Communications

Where it is in accordance with your marketing preferences, GoSignMeUp may send you electronic communications marketing or advertising the Services themselves or courses on the Services, to the extent you have registered for the Services or purchased a course enrollment and/or registration to an course listed on the Services.
You can also “opt out” of receiving these electronic communications by clicking on the “Unsubscribe” link at the bottom of any such electronic communication.

Administrator Initiated Communications

Administrators may use our email tools to send electronic communications to those on their email subscription lists, including Consumers who have registered for their courses on the Services in the past. Although these electronic communications are sent through our system, GoSignMeUp does not determine the content or the recipients of these electronic communications. Administrators are required to use our email tools only in accordance with all applicable laws. GoSignMeUp provides tools for each Administrator to inform Consumers of the local site’s Privacy Policies. Contact your site administrator to modify or opt out of administrator initiated communications.

Transactional or Responsive Communications

Certain electronic communications from GoSignMeUp are responsive to your requests. For instance, if you are a Consumer, we must email you your course registration details on behalf of the Administrator when you register for a course. As a further example, if you email our customer support department, we will return your email. Notwithstanding any unsubscribe election that you have made, you will still receive these transactional or responsive emails. You can stop receiving these types of emails only by contacting us. By electing to stop receiving all electronic communications from us or through our system you will no longer receive any updates on courses you have created (including pay-out issues) or on courses you are registered to attend (including emails with registration info).  We do not recommend that you do this unless you plan to no longer use the Services, are not currently registered for a course, are not currently organizing a course and will have no need to receive further communications from us or through our system. 

Retention
It may take up to forty-eight (48) hours for us to process an unsubscribe request. Even after you opt out of all electronic communications, we will retain your Personal Data in accordance with this Privacy Policy, however, we will no longer use it to contact you. However, Administrators who have received your Personal Data in accordance with this Privacy Policy may still use that Personal Data to contact you in accordance with their own privacy policies.

Exclusions

Personal Data Provided to Others

This Privacy Policy does not apply to any Personal Data that you provide to another User or visitor through the Services or through any other means, including to Administrators on course pages or information posted by you to any public areas of the Services. 

Third Party Links

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies. 

Children – Children’s Online Privacy Protection Act 

We do not knowingly collect Personal Data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us and we will endeavor to delete that information from our databases.

International Privacy Laws

If you are visiting the Services from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy. 

EU – US Privacy Shield 

For Personal Data we receive from the EEA, GoSignMeUp, Inc has certified its compliance to the EU-US Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union countries. We have certified that we adhere to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access and Recourse, Enforcement & Liability when processing Personal Data from the EEA in the United States. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Changes To This Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, “Modifications”). Modifications to this Privacy Policy will be posted to the Site with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances GoSignMeUp may, but need not, provide you with additional notice of such Modifications, such as via email or with in-Service notifications. Modifications will be effective thirty (30) days following the “Updated” date or such other date as communicated in any other notice to you. 

Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.

Dispute Resolution

If you have a complaint about GoSignMeUp’s privacy practices you should write to us at: 

GoSignMeUp, Attn: Privacy Officer, 9200 Irvine Center Dr. Suite 100, Irvine, CA 92618, or by email. We will take reasonable steps to work with you to attempt to resolve your complaint. 

If your complaint is not satisfactorily you may have your complaint considered by an independent recourse mechanism.  If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using JAMS Arbitration Services (https://www.jamsadr.com/eu-us-privacy-shield) as a third party resolution provider.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

GoSignMeUp is subject to the investigatory and enforcement powers of the Federal Trade Commission.

The EU General Data Protection Regulation (GDPR) 

In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) becomes effective. The GDPR requires GoSignMeUp and Administrators using the Service to provide Users with more information about the processing of their Personal Data. 

Here is what you need to know: 

Legal grounds for processing your Personal Data 

The GDPR requires us to tell you about the legal ground we’re relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out above will typically be because: 

• you provided your consent; 
• it is necessary for our contractual relationship; 
• the processing is necessary for us to comply with our legal or regulatory obligations; and/or 
• the processing is in our legitimate interest as a course registration platform (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.). 

Transfers of Personal Data 

As GoSignMeUp is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA and the UK which have no data protection laws or laws that are less strict compared with those in Europe. 

Whenever we transfer Personal Data outside of the EEA or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data. For example, GoSignMeUp, Inc is Privacy Shield certified which means that it self-certifies to protect Personal Data from the EEA and the UK in accordance with established data privacy principles. Feel free to contact us as set forth in for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances. 

In cases of onward transfer of Privacy Shield data to third parties, GoSignMeUp is potentially liable.

Personal Data retention 

We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. 

Your rights

Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications. 

For the most part, you can you can exercise these rights by logging in and visiting the My Account page or changing the “cookie settings” in your browser (see our Cookie Statement for more information). If you can’t find what you’re looking for in the My Account page, please contact us using the contact information set out above. Please note that requests to exercise data protection rights will be assessed by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation. 

If you have a complaint about how we handle your Personal Data, please get in touch with us as at support@GoSignMeUp.com. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority. 

GoSignMeUp as a data controller and a data processor 

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data. 

GoSignMeUp may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances. 

For example, if you create an account with us to organize your courses, GoSignMeUp will be a data controller in respect of the Personal Data that you provide as part of your account. 

If  you register for an course as a Consumer, we will process your Personal Data to help administer that course on behalf of the Administrator (for example, sending confirmation, promotional and feedback emails, processing payments, etc.) and to help the Administrator target, and understand the success of, their course and course planning (for example, providing enrollment reports). In these circumstances, GoSignMeUp merely provides the “tools” for Administrators; GoSignMeUp does not decide what Personal Data to request on registration forms, nor is it responsible for the continued accuracy any Personal Data provided. Any questions that you may have relating to your Personal Data and your rights under data protection law should therefore be directed to the Administrator as the data controller, not to GoSignMeUp.