ThrottleUp | Privacy Policy

Privacy Policy

We are ElevenPoint2 Inc, dba ThrottleUp (“ThrottleUp,” “we,” “us,” or “our”), a provider of a training platform for workplace learning, located at 2803 Philadelphia Pike, Suite B #1066 Claymont, DE 19703, USA.

This Privacy Notice describes how we collect, use, share, and store your personal data when individuals visit our websites, submit an enquiry to us, access our ThrottleUp e-learning services, use any additional features of the ThrottleUp Platform or our website, or otherwise interact with us.

This Notice also describes how we use and share information about you, as well as certain rights and choices you have regarding your information.

If you have questions or concerns about this Notice or our collection and use of your information, please contact us at the email address listed below, and we will be happy to address them. By using the ThrottleUp Platform or our website, you agree to the policies and practices described in this Notice. If you do not agree, please do not use the ThrottleUp Platform or our website.

Links to Other Websites. This Notice does not apply to websites we do not own or control. We are not responsible nor liable for how third parties manage their own sites. Please refer to the privacy notices posted on those sites for more information.

Personal Data. Personal data refers to information relating to an identified or identifiable individual including name, phone number, company name, job, email, and postal address. In the provision of e-learning services, we do not knowingly collect sensitive personal data such as precise geolocation data, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Usage Data. Passively or automatically collected data (referred to as “Usage Data”) is collected as you use our websites or access our services. We, our affiliated entities, our service providers, and our marketing partners may use automated means to collect various types of information about you, your computer or other device used to access the sites, services, related Web applications, and downloadable software. This information is based on your usage of our sites and services and may be based on your visitation to other websites. Usage Data could be used indirectly to identify a person.

Data Controller. We act as the data “Controller” of the personal data you provide directly to us. Examples include when you fill out “Contact Us” form, create an account, participate in surveys apply to one of our jobs, or contact us via other methods.

Data Processor. If you are an employee or an authorized user of one of our customers which have entered into an agreement with us for the provision of our services, we will be acting as the “Processor” of your personal data transmitted by such customer. That customer will be acting as the Controller of your information. As a processor, we do not own, control, or direct the use of any data provided to us by our customers who act as the Controllers. If you have questions on how your personal data is being handled, please direct your inquiries to our customer, the Controller. If you contact us, we may be obligated to inform our customer of your request.

Changes to this Notice

We may update this Notice from time to time. If we make changes, we will revise the date at the top of this Notice. If we make material changes, we may provide additional notice such as sending you an email or posting a statement on our homepage prior to the changes taking effect. We encourage you to review this Notice periodically.

How We Collect Personal Data

Information You Provide to Us

We collect personal data directly from you such as when you make an inquiry through our “Contact Us” web page and other contact methods, apply to our job posting, and when you request that we send you emails. You may unsubscribe to our marketing emails by using an opt-out link contained in every non-transactional email or by updating your marketing preferences on your account page. We also store the files or other information that you upload or provide to us (“Content”) as part of your subscription.

Profile Info

We collect information about you when you register with us for an ThrottleUp ID, create or modify your online account, join our E-Learning, access and use our services, participate in a survey, make a purchase, apply for a job, request customer support, communicate with us via third-party social media sites, or otherwise communicate with us.

The types of information we may collect directly from you include your name, user name, email address, postal address, phone number, employer’s name, transactional information (including services purchased or subscribed to and billing address) as well as any contact or other information you choose to provide.

Please be aware that the information you choose to provide in your ThrottleUp ID profile may reveal information that is not expressly stated (for example, if you choose to provide your picture, your picture may reveal your gender).

Job Candidates

We collect information from you when you apply to one of our posted positions. The types of information we may collect directly from you include your name, email address, phone number, LinkedIn Profile, personal website, and information in résumé and cover letter. You have the option to provide demographic information that will be used on an aggregate basis (e.g. gender, ethnicity, veteran status, disability status). Demographics information will not be used to identify you nor used to evaluate your qualification for the role.

Information We Collect Automatically

Usage Data

When you use the ThrottleUp Platform or our website we may collect data about you including your Internet Protocol (IP) address, access times, browser type and language, Internet Service Provider (ISP), the web pages that you visit, behavior during the visit, the content you use, and the URL of the web page you visited before navigating to our services.

We collect Usage Data through cookies and similar technologies. For additional information and how to set your browser to reject cookies, see the Cookies and Similar Technologies section below.

Mobile Devices

If you access ThrottleUp from a mobile device, we collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network), or platform information (as allowed by the specific platform type). We do not ask for, access, or track any location-based information from your mobile device at any time while you are downloading or using our mobile apps.

Personal Data We Collect from Third Party Sources

We use third-party applications to add firmographic information to the data we collect from you. This data enhancement allows us to provide more helpful, personalized communication. We use Google Analytics to help us analyze the ThrottleUp Platform and our website and how they are used. You can read more about how Google Analytics handles Personal Information here, and you learn how to opt out of Google Analytics here.

The information we and our third-party service providers may automatically collect includes:

IP address and general location (such as region or city);
Device, operating system and browser types and versions;
Date, time and duration of uses of the ThrottleUP Platform or visits to our website;
Frequency and number of uses of the ThrottleUp Platform or visits to our website from a particular IP address;
Navigation actions in our website;
Referring website, if applicable; and
File uploads and downloads through the ThrottleUp Application or our website.

How We Use Personal Data

We may use the information we collect about you for a variety of purposes, including to:

Operate our services

We use the information we collect about you to provide, operate, maintain, and improve our services. We also use this information to help you use our services, including uploading, downloading, collaborating on, and sharing content, delivering learning content to learners.

We also use information about you to provide and deliver the services and features you request, to process and complete transactions, and to send you related information, including purchase confirmations and invoices.

Communicate with you

We also use the information we collect about you to send you technical notices, updates, security alerts, and support and administrative messages. We’ll also use that information to communicate with you about services, features, surveys, newsletters, offers, promotions, as well as provide other news or information about us and our select partners

Of course, we’ll also use your information to respond to your comments, questions, and requests, provide customer service and support, and deliver contest entries and rewards.

Protect our services

We also use information about our users to investigate and prevent fraudulent transactions, unauthorized access to our services, and other illegal activities.

Personalize our website and communication with you

We use cookies and similar technologies to help us see what pages you view on our site and any actions you take. That helps us develop helpful content and serve you customized web content and communication that best meets your needs. Please review the Cookies and Similar Technologies section for more information.

Help you use our services

If you’re a ThrottleUp customer, we analyze your product usage information to see how you’re doing with our apps and resources. We use customer profiles to prioritize outreach from our team, send you helpful information, and guide us in creating content to help customers make the most of their subscriptions.

Advertise to you

When you’ve visited our sites, we place cookies and a tracking pixel in your browser that helps us show you targeted ads on other sites you visit. We do not do this with visitors based in the European Economic Area (EEA).

Process your job application

We will use the information you have provided us to manage job applications and comply with legal reporting requirements such as affirmative action.

Information we share

General Disclosure Policy. We may share and disclose your personal data as described below. We may share and disclose Usage Data without restriction, including without limitation, as described below. Please contact us at info@gothrottleup.com to opt out of all information sharing with a third party.

We may share and disclose your personal data to the following types of third parties.

Service Providers. We may share your personal data and Usage Data with our third-party service providers, vendors, consultants working on our behalf to provide services to you and to operate and maintain our sites. For example, we may contract with service providers to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, reporting, and software maintenance and development services. In addition, our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.

Successors. If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your personal data.

Authorized Resellers. If you acquire our services through an authorized reseller or partner, we may share your personal data and Usage Data with those authorized resellers and partners so that they can provide customers with timely, helpful information about our products and services. Our resellers are contractually obligated to abide by this privacy notice, preventing them from sharing your personal data with any other third parties. Several of our resellers are located in the European Union (EU); however, we have determined that our authorized resellers all have suitable safeguards to protect your information. For more information regarding our authorized resellers and their safeguards, request descriptions via our Contact Us section below.

Additional Disclosures. We may disclose your personal data to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request, (b) to enforce our agreements, policies, and Terms of Use, (c) to protect the security or integrity of our services, (d) to protect us, our customers, or the public from harm or illegal activities, (e) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to respond to claims that any content violates the right of third parties. We may also share aggregated or anonymized information that does not directly identify you with third parties.

Opt Out of Marketing

If you reside in the EU or EEA, you have the option to grant your consent for receiving marketing emails from us to promote our own services. Regardless of your location, you may unsubscribe to those emails at any time by using an opt-out link contained in every non-transactional email.

Cookies and Similar Technologies

We may automatically collect Usage Data through the use of persistent or session cookies, javascripts, pixels, web beacons, local storage (HTML5), and similar technologies. Cookies are small text files a website uses to recognize repeat users, facilitate the user’s ongoing access to the site, and facilitate the use of the site. Cookies also allow a site to track usage behavior and compile site-usage information that will allow for the improvement of content.

You may reject cookies by activating the setting on your internet browser. However, if you select this setting you may be unable to access certain parts of our sites. Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you log on to our site.

Remarketing

We Google Adwords tracking cookie. This means we will continue to show ads to you across the internet, specifically on the Google Content Network (GCN) for remarketing. The third-party vendors, including Google, will place cookies on web browsers in order to serve ads based on past visits to our websites. This allows us to make special offers and continue to market ourproducts to those who have shown interest in them. We do not remarket to users in the European Union.

You may opt-out of Google’s use of cookies by visiting the Ads Preferences Manager.

Analytics

We engage third party analytics partners to monitor and analyze our web traffic and to keep track of user behavior on our sites.

Google Analytics (Google). Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of our sites, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at https://tools.google.com/dlpage/gaoptout.

Children

The ThrottleUp Platform and our website are intended for adults and are not directed to minors. We do not knowingly collect any information, including Personal Information, from or about minors. If you become aware that your minor child has provided us with Personal Information, please contact us. If we become aware that a minor has provided us with Personal Information, we will take steps to remove such information.

Privacy Shield Notice

This section applies to individuals located in the European Economic Area (EEA), United Kingdom (UK) and Switzerland.

We have certified our adherence to the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (together as “Frameworks”) and Privacy Shield Principles (“Principles”) as set forth by the U.S. Department of Commerce regarding the transfer of personal data from the EEA, UK and Switzerland to the United States. To learn more about the Privacy Shield program and to view our certification, please visit https://www.privacyshield.gov/list. We are responsible for processing personal data we receive under the Frameworks and subsequent transfers to a third party acting as agent on our behalf. We comply with the Principles for all onward transfers of personal data from the EEA, UK, and Switzerland. Please note we no longer rely on the Frameworks as a lawful transfer mechanism with respect to personal data received or transferred pursuant to the Frameworks

Complaints and Dispute Resolution

In compliance with the EU-US and Swiss-U.S. Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EEA, United Kingdom, and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at info@gothrottleup.com regarding ThrottleUp services.

If we did not resolve your complaints, you may contact your local data protection authority. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Contact details for the EU data protection authorities can be found at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm” . Contact details for the United Kingdom Information Commissioner (ICO) can be found at https://ico.org.uk/. Contact details for the Swiss Federal Data Protection and Information Commissioner (FDPIC) can be found at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html. You may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Your Rights

You may refer to the Contact Us section below on how to inquire about your rights.

Depending on your location and whether the privacy law of a geographic region applies to you, you may have certain privacy rights such as the right to 1) access – inquire what person data we have about you, 2) correction – update your personal data, 3) restrict processing – limit how we process your personal data, 4) withdraw consent – request we stop processing your personal data when permission was originally granted by you permission to do so, 5) deletion – delete your personal data in our system, 6) portability – providing you with a copy of the personal data for transfer to your chosen third party. If we

Contact Information

If you have questions or concerns about the privacy practices described in this Notice, or to communicate with us for any of the reasons described above, please write to us at info@gothrottleup.com