Privacy Policy

Effective Date: February 15, 2022

Welcome to our Privacy Policy. Protecting your personal data while it is in our care is both an honor and a great responsibility. We have provided the information below to help you understand how your personal data may be collected, used and disclosed by us, and how to exercise your choices with respect to your personal data. If you are looking for more information about your privacy rights and how to exercise them, you can jump to the “Your Rights” section below.

By using the DevelopPEOPLE and DiscLearning Solutions websites or other online services that link to this Privacy Policy (collectively, “Sites”), you are subject to the terms and conditions of this Policy. When we say “DevelopPEOPLE,” "DiscLearningSolutions," “our,” “we,” or “us,” we mean Wings of Success, LLC and its subsidiary and affiliate companies. There may be instances when we offer different or additional privacy terms specific to a product, application, or service. If those terms conflict with this Privacy Policy, the terms specific to the product, application, or service apply instead.

Information We Collect
Use of Your Information
Sharing Your Information
International Access
Retention of Your Information
Security
Links to Third-Party Websites
Students and Minors
Your Rights
Contact Us
Updates to This Privacy Policy

Information We Collect

When you interact with us or our Sites, we may collect personal data about you in the following ways: directly from you; through automated technologies such as cookies; and from other sources, such as our business partners and data processors.

Information You Provide Directly

We may collect information directly from you if you use our Sites, visit our office locations, or communicate with us. This information may include the following, depending on how you interact with us:

• Contact details, such as your name, email address, postal address, telephone number, and social media handle;
• Demographic information, such as your age, gender, and educational, professional or other background information;
• Username and password;
• Payment information, such as a credit or debit card number;
• Comments, feedback, posts, and communications with other users of our services;
• Photo or video;
• Communication preferences, language preferences, or other preferences; and/or
• Other identifiers, such as a government-issued identification number (e.g., Social Security Number, tax identification number) or institution-issued identification number (e.g., student ID number).

You may need to create an account with us in order to access certain content and to make use of additional features on our Sites, and some additional information may be requested during registration depending on the content or service you would like to access.

Information Collected Through Automated Technologies

We may automatically collect certain information when you use our Sites, either directly or through our third-party analytics providers. This information may include Internet Protocol (IP) address, browser type and settings, device identifier details, internet service provider (ISP), referring and exit pages, the Site content you interacted with, operating system, clickstream data, location data, or other usage information. We (and third parties acting on our behalf) may collect this information through certain tracking technologies, including cookies, web beacons (also known as tracking pixels or pixel tags), embedded scripts, location-identifying technologies, device recognition technologies, and session replay software. We may combine the information collected through these technologies with other information we collect about you.

We uses this information to enable Site functionality, understand Site interaction trends, gather demographic insights about our user base, personalize your experience on our Sites, and otherwise administer and improve our Sites and services. You have several options to exercise choices about cookies and tracking technologies. For more information about cookies and tracking technologies on our Sites and how to control their use on your devices, please read our Cookies Policy.

Information We Receive From Other Sources

We may receive information about you from third parties such as: business partners and data processors in technical, payment and/or delivery services; advertising, marketing, digital and social media agencies; data brokers; analytics providers; academic institutions; search information providers; and credit reference agencies.

We may also receive information about you from publicly accessible content, such as public databases or social media platforms. When we do collect publicly available data about you, we will honor this Privacy Policy when we store and process it.

If you choose to register and sign in by using a social media or other third-party account as an identity service (such as your Facebook or Google account), the authentication of your account is managed by that third party. We will collect your name, email address and any other information that you agree to share with us at the time you give permission for your account with us to be linked to your third-party account.

You should be aware that personal data (such as your name, social media handle, image, avatar, email address, or other identifier) that you voluntarily make publicly available by posting online to other users (e.g., on social media, forums, comments, or in chat rooms) could be collected and disclosed by others. We cannot prevent or monitor the collection or disclosure of publicly available personal data you post online.

Use of Your Information

Depending on how you interact with us, and with your prior consent where necessary, we may use your personal data for purposes of:

• Performing any contract or other transaction we enter into with you;
• Providing, activating, managing and supporting our products or services;
• Notifying you about changes or updates to our Sites, products, or services;
• Communicating with you about our or our partners’ programs or events (including webinars, conferences, or promotional activities such as sweepstakes, contests, or surveys);
• Marketing our Sites, products, or services to you (including by delivering commercial emails, newsletters, targeted advertising, phone calls, and/or SMS messages);
• Operating, evaluating and improving our business (including enhancing and personalizing our Sites, services, products and communications; developing new Sites, services and products; and assessing the effectiveness of our promotions and advertising);
• Performing data analytics for internal research or other business purposes;
• Responding to your inquiries, requests, or other comments;
• Detecting fraud, investigating suspicious activity (e.g., violations of our Terms of Use) and otherwise keeping our Sites safe and secure; and/or
• Complying with our legal or regulatory obligations.

In addition, we may use your personal data for other purposes that we may notify you of from time to time where we have a legitimate business interest, your prior consent, or another lawful basis to do so. We use the information collected through automated technologies for the purposes described in the “Information Collected Through Automated Technologies” section above.

We may aggregate or de-identify information so that it can no longer identify you. Subject to applicable laws, we may use this aggregated or de-identified information for analytical purposes, such as developing and improving our products and services, identifying industry trends and developments, and benchmarking. Where permitted by law, we may share aggregated or de-identified information with third parties.

Sharing of Your Information

We may share your personal data as follows:

Within our organization. We may share your personal data with our subsidiary and affiliate companies for the purposes described in the “Use of Your Information” section above.

With our service providers. We may share your personal data with service providers that perform services on our behalf, including administrative, information technology, website and platform hosting, editing, production, payment, business management, analytics, content management, indexing, archiving, lead generation, and marketing services. Before we share your personal data with any service provider, they must agree to comply with applicable laws, maintain strong data security, and only process personal data as we instruct.

With partner organizations. We may share your personal data with certain partners, including:

• Where a third party such as an academic institution, school, employer, business or other entity has provided you with access to a product or service (such as through an integration or access code or by other means), we may share information regarding your usage of the product or service, results of assessments taken, and other information you input into the product or service;
• Where you have participated in a program or event in which we partner with third parties (such as a webinar, conference or promotional event), we may share your information with the sponsor of the activity;
• Where, even if not described above, you have consented to such disclosure or we have a legitimate business interest in making the disclosure.

With other third parties. We may share your personal data where we have a good faith belief that disclosure is necessary to comply with the law or with legal process, to protect and defend our rights and property, to protect the safety or property of our users or the general public, or protect against misuse or unauthorized use of our Sites and services. We may also share your personal data in connection with a corporate transaction, such as a transfer of assets, merger, acquisition, consolidation, change of control, or other corporate combination.

International Access

Please be aware that when you access our Sites or services from a region or another country, your region or country may have privacy laws that differ from our Policy. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and all applicable data protection laws.

Retention of Your Information

We retain your personal data for as long as necessary to carry out the purposes described above and for any additional period that may be required by law.

Security

The security, integrity, and confidentiality of your personal data is important to us. We store most information about you in computer systems and databases operated by us or our service providers. Some information about you is recorded in paper files that we store securely. We have implemented technical, administrative, and physical security measures that are designed to protect personal data throughout our systems from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

Links to Third-Party Websites

Our Sites or services may include links to third-party websites not owned by us. When using such links, please be aware that any third-party website is subject to its own privacy and data protection policies and is not covered by this Privacy Policy.

Students and Minors

If you are a minor under applicable law, you should not use our Sites or services for any purpose without first obtaining consent from your parent, guardian, or teacher. We do not knowingly collect, use or disclose information from or about a child under 13 years old without the prior consent of a responsible adult. If you would like to review any personal data that we have collected online from your child, request to delete such information, request that there be no further collection or use of your child’s information, or if you have questions about these information practices, you may contact us by email or by phone at +1-888-871-1780.

In the United States, certain information regarding students is governed by the Family Educational Rights and Privacy Act (FERPA).

Your Rights

You have the right to request to:

• Access the personal data we have about you;
• Receive an electronic copy of the personal data we have about you;
• Rectify any errors in your personal data;
• Delete your personal data; and
• Restrict or object to how we process personal data about you.

If you submit a request which cannot be fully or partially fulfilled for legal or technical reasons, an explanation for this limitation will be provided. You also have the right to lodge a complaint with a supervisory authority. You will not receive discriminatory treatment by us for the exercise of any of your rights.

To exercise your rights, you may submit a request to us by email or by phone at +1-888-871-1780. Only you, your authorized representative, or you on behalf of your minor child may submit a request. For the protection of all individuals’ personal data, we will only process your request if we can reasonably verify that you are, or are the authorized representative of, the person whose personal data we hold.

If at any point you wish to review or change your preferences regarding marketing communications, you can use the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive from us, or submit an email request. Note that you may still receive transactional communications from us if you engage with our products or services.

Contact Us

If you have any comments, requests, or questions, you may contact our Data Protection Officer, Mark Hopkins.

Updates to This Privacy Policy

We periodically update this Privacy Policy. Any changes to the Privacy Policy will be posted on this page and will become effective as of the Effective Date above. If we make a material change in the way we collect, use or share your personal data, we will post a prominent notice or provide other notice as required by law. We encourage you to periodically review this page for the latest information on our privacy practices.

Cookies Policy

What is a cookie?

Cookies are text files containing small amounts of information which are downloaded to your personal computer or mobile device when you visit a website. Cookies may then be read by the originating website on each subsequent visit. Cookies are useful because they allow a website to recognise a user’s device, and set permissions for the user based on that recognition.

How long are cookies stored for?

Persistent cookies – These cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created a particular cookie.

Session cookies – These cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering you if you have logged in to a site, and generally help improve the user experience. You have the ability through your browser to block any or all cookies from our Sites. However, please be aware that our Sites may not function in the manner intended if some or all cookies are blocked.

Cookies used on our Sites

A list of the cookies used on our Sites by category is set out below. By using our Sites, you agree that we can place these types of cookies on your device. Not all types of cookies may be set during any particular visit to a site.

Required cookies – These cookies enable services you have specifically asked for. These cookies are essential in order to enable you to move around our Sites and use their features, such as accessing secure areas of our Sites.

Performance cookies – These cookies collect information about how visitors use our Sites, for instance: which pages visitors go to most often, if they get error messages from particular web pages, and so on. These cookies do not collect information that identifies a visitor; all information these cookies collect is aggregated and therefore anonymous. Their only use is to help us improve how our Sites work.

Functionality cookies – These cookies allow our Sites to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. These cookies may also be used to provide services you have asked for, such as watching a video or commenting on a blog. The information these cookies collect may be anonymized, and they cannot track your browsing activity outside of our Sites.

Third party cookies – These cookies allow third parties to track the success of their applications or customize an application for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used set by our Sites. For example, if you choose to share content through Facebook or other social networks, you might be sent cookies from those websites. We do not control the setting of those cookies, so please check those sites for more information about their cookies and how to manage them.

Data Storage

If you create an account on our Sites, we store the personal information you provide in your user profile. All users can see, edit, or delete their own personal information at any time. Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on our Sites, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. Email your detailed request to our Data Protection Officer, Mark Hopkins.

Additional Information

The IP address of visitors to our Sites may be checked through an automated spam detection/blacklist service. In addition, the IP address, browser type, and other specific information about the device used to access our website may be collected by a third-party analytics service. As described above, this collected information is used solely to improve the performance of our Sites.