Last updated: October 24, 2019
1. Types of Information We Collect
1.1 We collect information by which you may be personally identified, such as name, email address, mailing address, telephone number, payment information and billing address, date of birth, photographs, videos, essays, profile descriptions or comments (“Personal Information”).
1.2 We collect information that is about you but individually cannot be used to identify you, such as browser type, internet protocol (IP) address, operating system, information about how you use our Services and time spent on our Services, and other usage details.
1.3 We collect information about your internet connection, the type of device you use to access our Services, and usage details.
2 How We Collect Information
2.1 We collect information you choose to submit to us, such as when you create an account, log in to your account, communicate with us, answer surveys, fill in forms, respond to questions or tests, upload content, or engage in a financial transaction with us.
2.2 We collect information automatically when you use our Services. Our computer systems automatically log information such as your browser type, language preference and time zone, connection information like ISP or mobile operator, Internet Protocol (IP) address, log-in and log-out times.
2.4 We also collect some information from third-party sources and combine that with information we collect from you. For example, if you use your Facebook or LinkedIn account to establish your NextStep account we obtain some profile information about you from those providers.
3. Use of Personal Information. NextStep uses Personal Information: (a) to provide the Services to you; (b) to process transactions and billing; (c) for identification and authentication purposes; (d) to communicate with you concerning the Services, transactions, security, privacy and administrative issues relating to your use of the Services; (e) to improve your response to and interaction with the Services; (f) to do something you have asked us to do, or inform you about information that we think may be of interest to you; (g) to personalize and improve the Services and deliver and display targeted advertisements to you; and (h) for administration of and troubleshooting regarding the Services.
4. Sharing and Disclosure of Personal Information. NextStep does not rent or sell Personal Information that we collect from users to third parties. NextStep will disclose personal information when you post content which is visible to others through the Services, when you consent or instruct us to share your personal information with third parties, such as potential employers, or when we have a legitimate business or legal need to share your information. We may also disclose anonymous or aggregate information that does not reasonably identify you as an individual. Our sharing and disclosure practices are described in more detail below.
4.1 Certain features and functions of the Services share or make your information accessible to others. As with most online services, once you make your Personal Information available to others online, it may be collected and used by the recipients or any other website visitor without restriction. For example, your personal information may be visible to others in the following circumstances:
- Information you post to public spaces of the Services. When you post a question or answer to the Services, your profile, which could include your name, location, as well as the content of your post, is visible to others on the Services.
- When your account is connected to an instructor, the instructor will be able to see your profile information and your activities on the Services, such as videos you have watched, questions, responses and videos that you post, and other usage information. Instructors may also be able to see your name (not only your username) as well as your email address.
4.2 The placement of NextStep students with employers is a core part of our Services. In order to help facilitate such placement, we will share certain information relevant to a hiring decision with potential employers. This information includes, but is not limited to, contact information, education history, NextStep course results. By using the Services, you consent to these sharing practices. You may opt out of the sharing of your information with potential employers by notifying us at email@example.com. However, by doing so, you may prevent or limit the Services we provide to you.
- We may share data with social networks at your request. Some of our users choose to connect their NextStep account with social networks. This functionality is entirely optional. If you have explicitly agreed that we may do so, NextStep may disclose your Personal Information through a social network or similar service (like Facebook or Google). To control the information that you share, you have the option of modifying your NextStep or social network settings or disconnecting your social network account from your NextStep account
- We may share data with third-party applications that you authorize. Third-party application developers and service providers may build complementary services for our platform. If you connect your NextStep account to a third-party application or service, or approve access to your NextStep account by a third party application or service, you consent to NextStep sharing your information with that third party.
- We may share data in connection with special programs you participate in. If you participate in special programs where NextStep partners with third parties, NextStep may share data collected from or about you with its third-party partners to facilitate the program or services being offered. These program partners may use your information we share with them as described in their own privacy policies.
- We may share information with your consent. NextStep does not share your Personal Information with third-party organizations for their marketing or promotional use without your consent. In some instances, you may be able to grant us permission to share your Personal Information with authorized partners, not-for-profit organizations, and other entities that are not affiliated with NextStep. In these cases, we will only provide to these third parties the information you have authorized or asked us to share to these third parties. You may also choose to share content with others by email, or by posting NextStep content to social media sites such as Facebook or Twitter. These third parties may use your information as described in their own privacy policies.
4.4 We may use data which has been de-identified and/or aggregated for product development, research, analytics and other purposes, including for the purpose of analyzing, improving, or marketing the Services. In certain occasions, NextStep may share this data with business partners to improve our services or offerings. If we disclose information to authorized business partners to conduct research or to assist in understanding the usage, viewing, and demographic patterns for certain programs, content, services, promotions, and/or functionality on our Services, such data will be aggregated and/or anonymized to reasonably avoid identification of a specific individual.
4.5 NextStep may share information with our employees and trusted vendors, third party service providers and other individuals to provide services or products for us or on our behalf, which could include analytics, hosting, marketing and similar services. When we share personal information with third-party service providers or vendors, these third parties are contractually obligated to maintain the security and confidentiality of that personal information.
4.6 If NextStep is involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of our assets, your personal information may be transferred or disclosed in connection with such business transaction.
4.7 NextStep may release Personal Information if we have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce our End User License Agreement or other policies, including investigation of potential violations thereof; (c) investigate and defend ourselves against any third-party claims or allegations; (d) detect, prevent ,or otherwise address fraud, security, or technical issues; (e) protect the rights, property, or personal safety of NextStep, our users, or the public; or (f) as may be required or permitted by law.
5. Information Security
5.1 To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. For example, we may ask you to provide certain Personal Information to confirm your identity, and we may require that you create and use a password to access certain parts of our Service. You should create and maintain a strong password to help ensure the security of your account.
5.2 We use certain physical, managerial, and technical safeguards designed to preserve the integrity and security of your Personal Information and other information we maintain in connection with our Services. However, we cannot ensure or guarantee the security of any or all of the information you submit or that we collect from you, and by using our Services, you do so at your own risk.
5.3 We make commercially reasonable efforts to ensure the security of our systems. When you enter sensitive information, we encrypt the transmission of that information using secure socket layer technology (SSL) or similar technologies. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you of the security incident in accordance with applicable laws and regulations.
6. Your Choices About the Use of Your Information. You can choose not to provide certain information to us, but you may not be able to use certain features of the Services.
- To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive. Note that you cannot opt out of receiving transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
- The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared.
7. Children’s Privacy. The Services are not intended for use by children under 13 years of age. NextStep does not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, please do not provide your contact information or any other personally identifiable information to NextStep. If you are the parent or legal guardian of someone under the age of 13 who may have provided us with information without your knowledge or consent, please contact us to have this information removed.
8. Your California Privacy Rights. California law permits a user who is a California resident to request and obtain from NextStep, once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the types of Personal Information disclosed to those parties. NextStep does not disclose Personal Information to third parties for their direct marketing purposes.
NextStep Interactive, Inc.
119 South Main Street, suite 405
Seattle, WA 98104