Table of Contents
- What information do we collect?
- How we use the information we collect
- How we share or transfer data
- Marketing and sponsored content
- Third parties and online advertising
- Your choice and options relating to data collection and use
- How to access, update, or delete your personal information
- Our approach to data security
- International visitors
- European Union data protection
- Links to other sites
- Contacting Waters Center for Systems Thinking
1. What information do we collect?
We take the information you provide to us very seriously, and we strive to put you in control of decisions around your information.
You can use many features of the Service without signing up for an account or providing any other personal information. If you create an account on the Service, or communicate with us, you may provide to Waters Center what is generally called “Personal Information” or “Personal Data,” such as your full name, email address or other information that can be used to identify you. Information which cannot be used to identify you as an individual is “de-identified” or non-personal information.
We collect information, including personal information, in a variety of ways which may vary according to your use of the Service and your account settings. The categories of personal information we collect may include:
- Contact and profile information
- Location information
- Donation and applicant data
- Information about your browser or device
- Non-personal information which may be linked to your Personal Information
Below, we describe examples of the categories of information we collect from and about you when you use our Service:
Information you provide to us and information we receive about you from others:
Contact and profile information
When you create an account on the Service, or communicate with us, we may collect personal information including your name and email address. After signing up, you may also choose to provide additional information in your profile, such as your nickname, location (city) and other personal or demographic information. In addition, we may ask you for personal information at other times, such as when you contact our technical support team, send us an email, complete a user survey, or otherwise communicate with the Service.
We may collect and use information about your location (such as your country) or infer your approximate location based on your IP address, but we don’t collect the precise geolocation of you or your device. You may be able to change the settings on your computer or mobile device to prevent it from providing us with any location information.
Donation and applicant information
If you donate to Waters Center or Thinking Tools Studio via PayPal, we may obtain your name and mailing address to send a thank you note.
Usage and device information
To provide a personalized learning and high-quality experience for our users, we may use various technologies that automatically record certain technical information from your browser or device when you visit our website, read our emails, use our Service or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, Flash objects, log files, and similar technology (collectively, “tracking technologies”). These tracking technologies cookies collect information about how you use the Service (e.g., the pages you view, the links you click, and other actions you take on the Service), information about your browser and online usage patterns (e.g., Internet Protocol (“IP”) address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email, links clicked), and information about the device(s) you use to access the Service (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and whether you access the Service from multiple devices). We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Sites and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to better display our website, to save you time, to provide better technical support, for promotional purposes, and to track website usage. For example, cookies help us to:
- Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you.
- Track website usage for various purposes including sales, marketing, and billing.
- Temporarily save responses to prompts until a user account is established.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services (particularly those that require you to sign-in) may not function properly if your cookies are disabled. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects – including how to manage privacy and storage settings for Flash cookies – on Adobe’s website or by clicking here. Various browsers may offer their own management tools for removing HTML5 LSOs. Please consult your browser’s “Help” function to learn more.
2. How we use the information we collect
The Waters Center and The Thinking Tools Studio use this information in the following ways:
To provide and enhance our Service
We use the information you provide or that we collect to operate, maintain, enhance, and provide all of the features of our Service.
To personalize your experience
We use the information to personalize your experience while using the Service, including on various devices you may use to access the Service. For instance, Thinking Tools Studio remembers your recent activity so we can recommend the most appropriate content for you on your next visit and provide personalized learning experiences.
To communicate with you
We use your information to communicate with you about your account and respond to inquiries. We may also use your Personal Information to provide you with information about features, services and other offerings that may be of interest to you.
To understand, improve, and develop our Service
We use all of the information that you provide or that we collect from users to understand and analyze the usage trends, learning behaviors, and preferences of our users, to improve the way the Service works and looks, and to create new features and functionality.
We may also use information to maintain, develop, support and improve our Service and other products and services.
To enable your participation in Waters Center partnership arrangements
We use your information to enable your participation in programs or features we may offer in partnership with third parties, to the extent you wish to participate in such programs.
For personal data subject to the European Union General Data Processing Regulations (“GDPR”), we rely on several legal bases to process the data. These legal bases include where:
- The processing is necessary to perform our contractual obligations in our Terms of Service or other contracts with you (such as to provide you the Service as described in our Terms of Service).
- You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time).
- The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims.
- The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Service, marketing the Service, such as new features or products that may be of interest, and promoting safety and security as described above.
If you have any questions about or would like further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at the bottom of this document.
3. How we share or transfer data
Waters Center takes great care to protect the information you provide us. We do not rent or sell Personal Information that we collect from users with third parties.
We will disclose Personal Information when you post content that is visible to others on the Service, when you consent or instruct us to share your Personal Information with third parties, 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. To learn more, see the additional description below.
When information is visible to others on the Service by default
Certain features and functions of the Service 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. You may wish to use a nickname or alias in your profile if you do not want your personal information shared with others in this way. For example, your personal information may be visible to others in the following circumstances:
- Information you post to public spaces of the Service. When you post a question or answer to the Service, your profile, which could include your name, short biography, and city-level location, as well as the content of your posted comment, is visible to others on the Service.
- Information visible to Waters Center. When your account is connected to some of our Services, such as connection with a Coach or our certification program, Waters Center will be able to see your profile information and your activities on the Service, such as which courses you have completed, the questions and responses you post, and other usage information. Coaches may also be able to see your name (not only your username) as well as your email address, if you include that information in your account profile.
With your consent or according to your instructions
- We may share data with social networks at your request. Some of our users choose to connect their account with social networks. This functionality is entirely optional. If you have explicitly agreed that we may do so, we may disclose your Personal Information through a social network or similar service (like Facebook, Twitter or Google). To control the information that you share, you have the option of modifying your Waters Center or social network settings or disconnecting your social network account from your Waters Center account. You may also choose to share content with others by email, or by posting Waters Center content to social media sites such as Facebook or Twitter. These third parties may use your information as described in their own privacy policies.
We may share anonymous or aggregate data with others.
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 our Services.
Other instances where we may share or disclose information for legal or business purposes
- We will share data with employees and service providers. Waters Center 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.
- Other instances Waters Center 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 applicable Terms of Service, 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 Waters Center, our users, or the public; or (f) as required or permitted by law.
4. Marketing and sponsored content
Messages from Waters Center and Thinking Tools Studio
We may, from time to time, send you emails regarding our products and services.
Waters Center does not display any third party advertisements on the Service. From time to time, we may permit third parties to sponsor content displayed on our Service. For example, for-profit organizations may wish to sponsor new content. Sponsored content will always be labeled (e.g., “Sponsored by ___”). Waters Center does not share any of our users’ Personal Information with these sponsors without explicit consent, and these sponsors do not have the ability to track or collect information about our site visitors or users. As a non-profit organization, Waters Center relies on our sponsors, donors, and other contributors to provide funding necessary to provide the free Service to our users.
Please note: From time to time, we may display YouTube video content created by third parties and not by Waters Center. While Waters Center-created video content does not display video advertisements, third party content may include advertising which we cannot control.
5. Third parties and online advertising
Waters Center does not display any targeted advertising on our Service. However, we participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements on other websites, apps or services, including on Facebook and other social networks, or on other devices you may use. These third party ad networks use tracking technologies to recognize your browser or device and to collect information about your visit to our Service to provide you customized content, advertising and commercial messages which may be more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at http://www.aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at http://www.youronlinechoices.eu/. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
Waters Center uses YouTube to display video content on the Service. YouTube incorporates tracking technologies, which may be present in the YouTube videos embedded on the Service, which may collect information from your browser when you view the video on the Service, including device identifiers and/or cookie IDs. This information is collected directly and automatically by YouTube and its partners, and Waters Center does not participate in these data transmissions. Waters Center does not provide any Personal Information, such as user names, to YouTube.
6. Your choice and options relating to data collection and use
At Waters Center, we use Personal Information as needed for the purposes for which it was collected or where you have consented to our use of your Personal Information. We take reasonable steps to ensure that the Personal Information we store and use is accurate, complete, and up-to-date. If you discover that Personal Information or other data pertaining to you is inaccurate, incomplete, or out-of-date, please update your account information or contact us as outlined below.
You can choose not to provide us with Personal Information.
You may always decline to provide your Personal Information to Waters Center. Registration is not required to access most of our online resources. If you decline to sign up, however, Waters Center will not be able to provide to you certain features and functionalities found on our Service. You may later enable or access those features by providing us with the necessary Personal Information.
You can choose to provide only information which does not reasonably identify you to others. We recommend you select a username which is not related to your actual name, for example. You can also decline to provide any optional data in your profile.
You can disconnect us from Integrated Services.
You can unsubscribe from email communications.
Waters Center may, from time to time, send you email regarding our products and services, or products and services we think you may enjoy. Only Waters Center (or our vendors or service providers operating on our behalf) will send you these emails. You can choose not to receive these emails by clicking the unsubscribe link in any e-mail. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Service, or technical or security notices.
7. How to access, update, or delete your personal information
How to access or update your information
We want you to have access to your information, so that you can help keep it as accurate as possible. If you sign up and provide Waters Center with Personal Information, you may update, correct, or delete your account and information at any time by reviewing your profile information and preferences on your account settings page.
How to delete your information
To request deletion of your Personal Information at any time, email firstname.lastname@example.org.
We may not be able to delete data in all instances, such as information retained in technical support logs and other business records. We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that it can no longer be used to reasonably identify a particular individual.
8. Our approach to data security
Data security is important to you, and to us.
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.
We try to ensure that our Service and information sent to us are safe, but no security measures are perfect.
Waters Center uses 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 Service. We cannot, however, guarantee the security of any or all of the information you transmit to Waters Center, and you do so at your own risk. Once we receive your transmission of information, Waters Center makes 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. In the event that 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.
The Services are intended for users over the age of 18 and are not directed at children under the age of 13. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13, or personal data (as defined by the EU GDPR) from children under the age of 16, we will take reasonable steps to delete it as soon as practicable.
10. International visitors
Our Service is operated and managed on servers located within the United States. If you choose to use our Service from the European Union or other regions of the world with laws governing data collection and use that differ from United States law, then you acknowledge that Waters Center will transfer your personal information to the United States for the purpose of performing the Service according to our contract (e.g., our Terms of Service) and for any other purpose for which you provide explicit, informed consent.
11. European Union data protection
Residents in the European Union are entitled to certain rights with respect to personal information that we hold about them:
- Right of access and portability The right to obtain access to your personal information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
- Right to rectification The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
- Right to erasure The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
- Right to restriction The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information; and
- Right to object The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
You may also have the right to make a complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
12. Links to other sites
14. Contacting Waters Center for Systems Thinking
Please contact Waters Center with any questions or comments.
By email: email@example.com
By mail: Waters Center for Systems Thinking, 7090 N Oracle Rd, Suite 178-127, Tucson, AZ 85704-4383