Last updated: May 3, 2013
Cornerstone OnDemand complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Cornerstone OnDemand has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Cornerstone OnDemand’s certification, please visit http://www.export.gov/safeharbor/
Collection of Information
When you visit our Website, we may collect information regarding your visit from your computer. Such information helps us to determine information about how you found our Website, the date that you visited our Website and search engines that may have led you to our Website. We collect this information in order to continually improve and enhance the functionality of Cornerstone.
Generally, you may provide us with two types of information (User-Provided Information and Website Usage Information), both of which are discussed in greater detail below.
Personal Information you choose to provide
In order to make your visits to our Website as enjoyable as possible, we may ask you for Personal Information. Personal Information includes, for example, your name and e-mail address, both of which you may be asked to provide when registering with Cornerstone. A description of some of the ways that you may provide Personal Information to us, as well as further details on how we may use such Personal Information, is given below.
1. Contact us/feedback
If you email us through a "Contact us" link on our Website, we may ask you for information such as your name and e-mail address so we can respond to your questions and comments. If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages, your e-mail address and our response to you. In certain cases, and with your permission, we may post content from your e-mails to us on the Website.
2. Questionnaires and surveys
We may occasionally ask viewers of our Website to complete online surveys and opinion polls about their activities, attitudes and interests. These surveys help us serve you better and improve the usefulness of Cornerstone. In requesting your participation in these surveys, we may ask you to provide your name and e-mail address to us.
3. Bulletin Boards
Our Website may offer its users the opportunity to use bulletin board blogs and chat rooms, and engage in discussions with other users. If you choose to use these features, you should be aware that any Personal Information you submit through these features can be read, collected or used by other viewers of these forums and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums.
Website usage information
When visiting Cornerstone, we may use “cookies” on or in connection with our Website to maintain information about you. A cookie is a very small text document, which often includes an anonymous unique identifier and additional information necessary to support the sites intended functionality. Cornerstone employs the use of “session” cookies. A session cookie is temporary and disappears after you close your browser.
When you visit our Website it will then send a session cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits our Website to access the cookies it has already sent to you and not the cookies sent to you by other websites. Except as otherwise set forth herein, all of our cookies are necessary for the provision of our services. We do not employ any third-party advertising cookies on our site. The following is a list of the cookies we use and their functionality
- Description: This cookie provides our 24x7 global performance monitoring system with regional statistics to ensure our pages load quickly and consistently.
- Contains the name of the portal logged into and the numeric system identifier of the logged in user. Does not contain any Personal Information.
- Description: This cookie is used for automated course launch functionality in the Curriculum Player. The cookie keeps track of the Curriculum ID if launched in the Curriculum Player and the next Learning Object to be launched.
- Contains Curriculum and Learning Object GUIDs. Does not contain any Personal Information.
- Description: This cookie is used to temporarily hold items placed in the shopping cart by an anonymous user. The items are transferred to the user's shopping cart once they log in with their individual account. Selected items would be lost without this cookie.
- Contains Learning Object GUID. Does not contain any Personal Information.
- Description: This is a default cookie that is required for ASP based pages to load. Without this cookie, our website will not function.
- Contains the unique session identifier. Does not contain any Personal Information.
- Description: This cookie is required to support content file encryption and Java applets.
- Contains the IP address of incoming machine and the name of the portal logged into.
- Description: This cookie is used to support session timeout due to inactivity.
- Contains the unique session key and the URL.
- Session-based or persistent depending on back-end configuration setting.
- Description: This cookie is used to ensure our login and maintenance pages load in the local language of origin.
- Contains the Region (ex. U.S.) of the incoming machine.
- Description: Carries over error message from the originating page to the actual page that displays the error.
- Contains error message GUID. Does not contain any Personal Information.
- Description: This cookie is required for query string encryption when the user is logged out of their session so that the user’s ReturnUrl link can navigate back to the same page and be successfully decoded.
- Contains first eight characters of the session ID. Does not contain any Personal Information.
Most web browsers can be adjusted to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact, the display or function of, our Website or certain areas or features of our Website. There are many resources on the internet that can provide more information about how cookies work and how you can manage them. One very informative non-profit site is www.allaboutcookies.org
2. Clear GIFs
When visiting Cornerstone, we may also use “Clear GIFs” (a.k.a. “web beacons” or “pixel tags”) or similar technologies in our Website and/or in our communications with you. A Clear GIF is typically a one-pixel, transparent image located on a web page or in an e-mail or other type of message, which helps us to verify an individual’s viewing or receipt of a web page or message. Clear GIFs allow us to know whether you have viewed a web page prior to visiting our Website and may enable us to relate such information to other information, including your personal information. We use information provided from Clear GIFs to allow more accurate reporting, improve the effectiveness of our marketing and make Cornerstone better for our users.
3. IP address and Clickstream data
Our servers automatically collect data about your Internet Protocol Address when you visit us. When you request pages from our Website, our servers may log your IP address and sometimes your domain name. Our servers may also record the referring page that linked you to us (e.g. another website or a search engine); the pages you visit on this Website; the website you visit after this Website; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Website or a referral website; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our servers and to administer our Website. Such information may also be used to gather broad demographic information, such as country of origin and Internet service provider. Personal Information including IP addresses are not used to facilitate contact with users who have not provided their contact details to CSOD. Personal Information is not shared with any third party marketers.
Rights to opt in/opt out
You have the right to “opt in” and/or “opt out” of certain of our uses of your Personal Information. For example, you may have the opportunity to elect whether you would like to receive correspondence from us. You will have the opportunity to opt out of Cornerstone’s promotional e-mails by clicking the "opt out" or “unsubscribe” link in the e-mail you receive. You can also request this by sending an e-mail to firstname.lastname@example.org, specifying whether: (i) you would like to opt out of receiving promotional correspondence from Cornerstone in general, or just via e-mail, postal mail and/or by phone, and/or whether (ii) you would only like to opt out of certain of Cornerstone’s e-newsletters or correspondence.
Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
Use, Disclosure, and Sharing of Personal Information
1. Service providers
We may use third-party partners to help us operate and maintain our Website and deliver our products and services. We may also share your information with our service providers and other third parties (“Affiliated Parties”) that provide products or services for or through this Website or for our business (such as website or database hosting companies, address list hosting companies, communications providers, e-mail service providers, analytics companies, distribution companies, fulfillment companies, credit card processing companies and other similar service providers that use such information on our behalf).
Third-party service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. Data can be processed in the United States, India or Israel depending upon contractual requirements and in accordance with legal jurisdictions for the region(s) to which Cornerstone is subject.
2. Aggregated statistics
We may disclose non-personally identifiable aggregated statistics regarding user behavior as a measure of interest in, and use of, our Website and e-mails to third parties in the form of aggregated data such as overall patterns or demographic reports that do not describe or identify any individual user. Information relating to aggregated statistics will be collected through the use of third-party cookies and other third-party tracking devices.
3. Legally compelled disclosures
We may disclose your Personal Information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to law applicable to us, our group or out partners, comply with a judicial or court order or comply with legal processes served on us or Affiliated Parties; (b) protect and defend our rights and property, the Website, the users of the Website and/or our Affiliated Parties; or (c) act under circumstances to protect the safety of users of our Website, ourselves, or third parties.
Consent to worldwide transfer and processing of Personal Information (applies unless otherwise agreed in writing between you or your organization and Cornerstone)
Your access and correction rights
You retain the right to submit and correct your Personal Information by contacting your organization.
Privacy of minors
This Website is not directed at children under the age of thirteen and we do not knowingly collect Personal Information from children under the age of thirteen on our Website. If we become aware that we have inadvertently received Personal Information from a visitor under the age of thirteen on our Website, we will delete the information from our records.
We use commercially reasonable and industry-standard physical, managerial and technical safeguards to preserve the integrity and security of your Personal Information. We also use Secure Sockets Layer (SSL) encryption when transmitting sensitive information. Whilst we endeavor to protect the security and integrity of sensitive Personal Information provided to this Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.
If you contact us by e-mail or a “contact us” or similar feature on the Website, you should be aware that your transmission might not be secure. An unaffiliated third party could view information you send by these methods in transit. We accept no liability for disclosure of your information due to errors or unauthorized acts by third parties during or after transmission.
In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we shall endeavor to do so as promptly as possible under the circumstances, and (insofar as we have your e-mail address) we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you would prefer us to use another method to notify you in this situation, please e-mail us at email@example.com with the alternative and/or additional contact information you would like us to use.
Updates to our privacy statement
Conditions of use
Attn: Cornerstone Privacy Address: 1601 Cloverfield Blvd., Suite 620 South, Santa Monica, California 90404, USA E-mail: firstname.lastname@example.org