| Franklin Covey Co. Privacy Shield Policy

 

This Privacy Shield Policy applies to the processing of personal information that (referred to in this Privacy Shield Policy collectively as “Franklin Covey,” “we,”, “us,” and similar terms) obtains from individuals located in the European Economic Area (EEA).   Franklin Covey has certified that it complies with the Privacy Shield Principles for transfers of your personal information from the EEA in connection with the Franklincovey.com website and Franklin Covey apps that include a link to the Franklin Covey Privacy Policy. The U.S. Federal Trade Commission has jurisdiction over Franklin Covey’s compliance with the EU-U.S. Privacy Shield. More information about our certification to the Privacy Shield is provided below. 

FRANKLIN COVEY PRIVACY SHIELD CERTIFICATION

 

Franklin Covey complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union member countries to the United States. Franklin Covey has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, i.e. Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose limitation; Access and Recourse, Enforcement and Liability. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.  

 

Descriptions about how we treat personal information that is transferred in reliance on Privacy Shield are available in the following sections of the Franklin Covey Privacy Policy:

 

·         WHAT INFORMATION DOES FRANKLIN COVEY COLLECT AND HOW IS IT USED? at https://www.franklincovey.com/privacy

·         DOES FRANKLIN COVEY SHARE PERSONAL INFORMATION? at https://www.franklincovey.com/privacy

 

 

RIGHT TO ACCESS AND LIMIT DISCLOSURE OF YOUR PERSONAL INFORMATION

 

You have the right to access your personal information. Upon request, Franklin Covey will grant you access to your personal information that it holds. In addition, Franklin Covey will take reasonable steps to permit you to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. You also have the right to choose whether your personal information is to be disclosed to a third party or to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. Franklin Covey will provide you with reasonable mechanisms to exercise these rights. 

REQUIRED DISCLOSURES OF YOUR PERSONAL INFORMATION

 

Franklin Covey may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

LIABILITY FOR ONWARD TRANSFERS

 

Franklin Covey is liable for appropriate onward transfers of your personal information to third parties as described in the Privacy Policy at https://www.franklincovey.com/privacy. If Franklin Covey has knowledge that a third party is using or disclosing personal information in a manner contrary to this Privacy Shield Policy, we will take reasonable steps to prevent or stop such use or disclosure. 

DISPUTE RESOLUTION

 

Franklin Covey commits to resolve complaints about your privacy and our collection or use of your personal information. Questions or concerns about the use of your personal information and this privacy policy should be submitted first to our Data Privacy Officer as described below.

 

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

 

Finally, as a last resort and in limited situations, you may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.  

HOW TO CONTACT US WITH INQUIRIES OR COMPLAINTS

 

Questions, comments or complaints regarding this Privacy Shield Policy should be submitted to Franklin Covey’s Data Protection Officer by mail to:

 

Franklin Covey

Data Protection Officer

2200 Parkway Blvd.

Salt Lake City, UT 84119

 

or by email to: privacy@franklincovey.com