What information does Franklin Covey collect and how is it used?
Franklin Covey collects personal information through its Site in connection with user registration and purchase of goods/services offered on the Site, including contact information (i.e., name, postal and e-mail addresses, phone and billing information) and demographic information (i.e., ZIP code, gender or age). We use this information to send our users information about our Site and to contact the user when necessary. From time to time, Franklin Covey or its business affiliates may also use your registration information to send you offers and promotions that may be of interest to you. By providing your contact information, you give us permission to send you such materials. Users may opt-out of receiving certain future mailings. See the choice/opt-out section below. Demographic and profile data is also collected during registration. We use this data to tailor the user’s experience at Franklin Covey, showing users content we think they might be interested in, and displaying the content according to their preferences. This information is shared with advertisers on an aggregate basis.
Does Franklin Covey share personal information?
Occasionally, we make our customer list available to a few carefully screened firms offering products that may be of interest to you. If you prefer not to receive such mailings or not to have your information shared in this manner, you may opt-out at any time. See the choice/opt-out section below.
Our Site provides users the opportunity to opt-out of receiving communications from Franklin Covey at any time through our Unsubscribe page. Please allow 45 days for your opt-out request to take effect. Note that regardless of your opt-out selections, Franklin Covey may continue to correspond with you, via e-mail and other communications means, in connection with your customer relationship with Franklin Covey.
If you would like to change or update your personal information please visit the Change of Address page.
We receive and store certain types of information whenever you access the Site. We may set and access cookies on your computer and use web beacons, clear GIFs or pixel tags to provide us with information about your browsing experience. We may also allow other companies that show advertisements on our pages to set and access their cookies on your computer. Other companies’ use of their cookies is subject to their own privacy policies.
We use the information collected to help diagnose problems with our server and to administer our Site, as well as to deliver content targeted to your interests and to save your password so you don’t have to reenter it each time you visit our Site.
If you prefer not to accept cookies, you can set your browser to reject them or to alert you before one is placed on your computer. Note that some features of our Site may not be available if you do not accept cookies.
How does Franklin Covey work with other companies and how do these relationships affect user privacy?
The Site contains links to other websites. Franklin Covey does not control the privacy policies of business partners, advertisers, sponsors or other websites to which Franklin Covey provides hyperlinks.
Occasionally we also share user’s personal information collected on our Site with our sponsors and partners. In this regard, we share such information on an aggregate basis and do not reveal information about individual users of the Site without consent.
What is Franklin Covey’s policy regarding posts on message boards?
Franklin Covey message boards are available to all Site users. Please remember any information disclosed in public message boards becomes public information and you should exercise caution when deciding to disclose your personal information.
Use of Site By Minors
The Site is intended for use by adults only. In connection with the Site, Franklin Covey does not promote online to children and does not intentionally collect any personally identifiable information from children under the age of 13.
Franklin Covey collects Your Data (defined below) by means that are fair, legal, and transparent. If you visit Franklin Covey’s website, your web browser automatically discloses, and Franklin Covey’s web server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether or not your request was successful. This data may or may not be sufficient to identify you. Any additional data that you provide, e.g. in a web form, may also be logged. This data may or may not be sufficient to identify you.
Any additional data your web browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in cookies and submits them each time you request a web page within a particular domain (such as FranklinCovey.com). This data may or may not be sufficient to identify you.
If you disclose personal data to Franklin Covey in conjunction with an identifier such as your name or your credit card details, Franklin Covey will collect Your Data. Moreover, any data that becomes available to Franklin Covey through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, Franklin Covey will collect Your Data from you and not from other parties. This is qualified as follows:
- where Franklin Covey reasonably considers the protection of its financial interests requires it gather Your Data from other sources, or from additional sources. This applies in particular where Franklin Covey has a lending exposure to you, and seeks information about your creditworthiness;
- where Franklin Covey reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering Your Data from other sources. This applies in particular to consumer profile data
- where Franklin Covey collects Your Data from sources other than you, it will do so by legal means, with your Consent, and to declare to you what sources it uses, and under what circumstances.
Franklin Covey undertakes to store Your Data in a manner that ensures security against unauthorized access, alteration or deletion, at a level commensurate with its sensitivity.
Franklin Covey will use its best effort to transmit Your Data in a manner that ensures security against unauthorized access, alteration or deletion, at a level commensurate with its sensitivity.
Franklin Covey will implement appropriate measures to ensure security of Your Data against inappropriate behavior by Franklin Covey’s staff members and contractors. These include: (1) training for staff in relation to privacy; (2) access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it; (3) particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data; (4) reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behavior; (5) declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behavior (5) clear communication of policies and sanctions; and (6) processes to audit, to investigate and to impose sanctions.
Use refers to the application of Your Data by any part of Franklin Covey, or any staff-member or contractor of Franklin Covey in the course of their work.
Franklin Covey will use Your Data only for: the purposes for which it was collected; such other purposes as are subsequently agreed between Franklin Covey and You; such additional purposes as may be required by law. In these circumstances, Franklin Covey will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and such additional purposes as are authorized by law (in particular to protect Franklin Covey’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfill your obligations to Franklin Covey or have committed a breach of the criminal law).
Franklin Covey will use Your Data only if it has demonstrable relevance to the particular use to which it is being put.
Franklin Covey undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
Disclosure refers to making Your Data available to any party other than Franklin Covey and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
Franklin Covey discloses Your Data only under the following circumstances:
- in the course of business being conducted between You and Franklin Covey, where disclosure is necessary to a contractor, such as a transport company. Where Your Data is disclosed in this way, Franklin Covey undertakes to exercise control over Franklin Covey’s contractors to ensure that their actions are compliant with these Terms;
- in other circumstances that are directly implied by the purpose agreed between You and Franklin Covey at the time of data collection or subsequently. Where Your Data is disclosed in this way, Franklin Covey undertakes to exercise control over Franklin Covey’s contractors to ensure that their actions are compliant with these Terms;
- with your consent, or at your request;
- where required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena. In these circumstances, Franklin Covey will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
- where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Franklin Covey believes on reasonable grounds that the disclosure of Your Data will materially assist in the protection of the life or health of some person), provided that Franklin Covey will apply due diligence to ensure that the exercise of the permission is justifiable.
In all cases, Franklin Covey undertakes to disclose only such of Your Data as is necessary in the particular circumstances.
Data Retention and Destruction
Subject to the qualifications immediately below, Franklin Covey will: (1) retain Your Data only as long as is consistent with its purpose; and (2) destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.
- Your Data may be retained in Franklin Covey’s logs, backups and audit trails within short-term retention cycles that are devised to protect the company’s operations. In such cases, Your Data will be destroyed in accordance with those cycles;
- Your Data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, Franklin Covey:
- will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law; and
- will only retain Your Data while that provision is current, and will then destroy Your Data;
- Your Data may be retained beyond the expiry of its purpose if it is authorized by law (in particular to protect Franklin Covey’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your obligations to Franklin Covey or have committed a breach of the criminal law). In these circumstances, Franklin Covey will only retain Your Data while that situation is current, and will then destroy Your Data.
Access by You to Your Personal Data
Franklin Covey provides you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, Franklin Covey undertakes to enable access: conveniently; without unreasonable delay; and without cost.
Franklin Covey establishes and operates identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with Franklin Covey (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.
In the event that you dispute some aspect of Your Data, Franklin Covey undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.
You agree to: not to seek access for frivolous purposes, or unreasonably frequently; and to accept that deletion of some data may not be consistent with the provision of particular services by Franklin Covey to you.
Information about Data-Handling Practices
Franklin Covey will make information available to you about the manner in which Franklin Covey handles your data: in general terms, in a readily accessible manner; and in more specific terms, on request.
Where Your Data is disclosed to a contractor, Franklin Covey will make information available to you on request about the manner in which Franklin Covey’s contractors handle your data.
Franklin Covey ensures that the information provided is meaningful, and addresses your concerns.
You will: not seek such information for frivolous purposes, or unreasonably frequently; and accept that the disclosure of excessive detail may harm the security of Your Data and Franklin Covey’s business processes, and may harm Franklin Covey’s commercial interests.
Handling of Inquires, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about Franklin Covey’s behavior in relation to these Terms, may: communicate them in the first instance: to Franklin Covey only; in sufficient detail; through a channel made available by Franklin Covey for that purpose;
Franklin Covey desires: (1) to provide one or more channels for communications to Franklin Covey, which are convenient to users; (2) to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and Franklin Covey’s reference code for the communication; (3) to promptly provide a response to the communication, in an appropriate and meaningful manner.
You further desire to not pursue Franklin Covey through any Regulator or the media: until and unless Franklin Covey has had a reasonable opportunity to respond to the initial communication; and while Franklin Covey and you are conducting a meaningful dialogue about the matter.
These Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.
Enforcement may only be sought in a jurisdiction that is relevant to the transactions that have taken place between You and Franklin Covey, in particular the jurisdiction in which you live or in which you performed the relevant acts, and the jurisdiction in which Franklin Covey is domiciled or performed the relevant acts.
Changes to These Privacy Provisions
Franklin Covey will: not unilaterally make any material change to these Terms in a manner that reduces the protections for Your Data; take all practicable steps to prevent any company that acquires this company or any of its relevant assets from materially changing the Terms applicable to Your Data in a manner that reduces the protections for Your Data; where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to consult with appropriate representative and advocacy organizations; where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible; to maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.
Franklin Covey means Franklin Covey Co. (NYSE: FC), incorporated in Utah, USA, and with corporate offices located at 2200 West Parkway Blvd., Salt Lake City UT, 84119. For more information, please refer to the Franklin Covey corporate website, http://www.FranklinCovey.com/tc/about.
“Your Data” means data that is capable of being associated with you, whether or not it includes an explicit identifier such as your name or customer number. In particular, it encompasses all data that Franklin Covey is capable of correlating with you, using such means as server logs and cookie contents. Your Data does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.
“Consent” means your concurrence with an action to be taken by Franklin Covey. Consent may be express or implicit, but in either case must be informed and freely-given.
“Jurisdiction” means the area of authority within which relevant legal powers may be exercised, in particular within which a particular court has authority. Franklin Covey is incorporated in Utah, USA. Its primary operations are in Utah, USA. Its officers and agents are in many locations around the world, and hence Franklin Covey may under various circumstances be subject to laws in a wide variety of jurisdictions.