Gale Privacy Overview

Personal Information is any information that can be used to identify, locate or contact you. It also includes other information that may be associated with your Personal Information. We collect the following types of Personal Information:

• Contact Information that allows us to communicate with you, such as your name, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.
• Relationship Information that helps us do business with you. For students, this may include your school affiliation, expected degree and graduation date, your courses of study, grades, learning style and how you engage with our products and content, and similar information that can help us tailor our content and offer you personalized instruction.  For professionals, this may include your professional credentials and affiliations and the products and services that may interest you or your school. If you are an instructor, we may also collect information about the types of courses you teach, your teaching style and student engagement, and similar information that can help us tailor our content and improve your effectiveness in the classroom.   
• Transaction Information about how you interact with Cengage, including your purchase history, information about your use of our content (including time spent on material and results of in-product assessments), customer account information and information about how you use our websites and applications. If you purchase products from us online, we will also collect payment  information as needed to process your payment. 

In many cases, we collect Personal Information directly from you. We will ask you for Personal Information when you interact with us, such as registering on our websites, signing up to receive a materials electronically, or making a purchase. We may collect additional about you from your school, such as information about the classes you are teaching, and from third party data suppliers who enhance our files and help us better understand our customers.  We may also collect information from publicly-available social media sites, such as Twitter. 

When you use our websites, products and applications, we collect Transaction Information about your session and your activity. In addition to any information that you submit during these sessions, we use cookies and other technological tools to automatically collect information about your computer and your use of our website and applications. We may collect or infer information about you, such as your engagement with our products and with others in your classes. We treat this information as Personal Information when it is associated with other data elements that allow us to identify you.  For more information about cookies and other technologies, please see the section Cookies and Other Data Collection Technologies below.

We also collect Personal Information when you contact us, such as for customer service purposes.

We use your Personal Information to:

• Provide you with the products, content or services selected by you or your institution and for related activities, such as customer service, account management, support and training, reporting and to provide other services related to your school’s account,
• Provide you with marketing communications and offers for products and services from Cengage and our partners, including personalized offers based on your usage of our products and to manage your communications preferences,
• Provide you with additional information that may be of interest, such as Cengage news and announcements, study tips for students or teacher guides for professionals,
• Administer surveys and other promotional events,
• Determine if you are eligible for certain products, services or offers, such as rebates or content guides offered to professionals and students for certain courses,
• Understand how you use our products, content and services, including associating you with different devices that you may use to access our content, for analytics and product development purposes as well as personalize offers that we make to you, and
• Manage our everyday business needs, such as payment processing and financial account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance.

Cengage processes personal information as defined by the applicable law where you live (“PI”) in our Services for several reasons, and only when Cengage has a legal basis for doing so, such as fulfillment of a contractual obligation or with consent.

Cengage may process PI under legitimate interest as long as such legitimate interest does not outweigh or infringe on the rights and freedoms of its customers.

We may share of your Personal Information as follows:

• If you are affiliated with an educational institution, we may share your Personal Information with your school and (if you are student) with your instructors. For example, we provide our clients with reports about how their instructors and students use our products, including information that compares instructors and students within a school. If you are a student, your instructors have access to all of the information generated by your use of the products for a class. We may also provide Personal Information to your school as needed to investigate possible academic fraud or cheating. Your school uses your Personal Information in accordance with its own privacy policies.
• We may share your Personal Information with our affiliates, which may only use your Personal Information for the purposes listed above.  
• We may also share your Personal Information with our service providers, who are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions.
• We may share your Personal Information with partners that provide services to you through MyCengage, MindTap and similar platforms, but only to the extent you have a relationship with such partner or you authorize the sharing. For example, you may request that Cengage share information about the courses you’ve taken with partners to enable the partner to provide you with resume creation, skills assessment or other services.  Additionally, we may share certain Transactional Information with our partners as needed to validate referrals and operate the platforms.  
• We may also disclose Personal Information where permitted by law, such as when needed to affect the sale or transfer of business assets, to enforce our rights, including Terms of Use or Service, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions.  We will also always disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.
• We may share your personal information with carefully selected third parties that provide products and services that may be of interest to you.  For example, we may provide lists of professionals or students with particular interests (such as pre-med classes) to other publishers that offer products or services to individuals with an interest in medicine.  If you do not want us to share your information with these third parties for their own marketing purposes, you can opt-out by contacting our Customer Service department by email at: [email protected] or phone at +1 800.354.9706 (M–F, 8:00 am–6:00 pm ET).

Please note that we may also use and disclose information about you that is not personally identifiable.  For example, we may publish reports that contain aggregated and statistical data.  These reports do not contain any information that would enable the recipient to contact, locate or identify you.

When you visit our website or use our mobile applications, we collect certain Transaction Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. 

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information.  For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns. 

In some cases, we do associate the information we collect using cookies and other technology with your Personal Information.  This Privacy Notice governs how we use that information when we associate it with your Personal Information.

Cookies

When you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser.  Cookies allow us to recognize you when you return.  They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser.  All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.  

Flash Cookies

We may also use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. A Flash cookie is a small data file placed on a computer using Adobe Flash technology. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. 

We use Flash cookies to personalize and enhance your online experience and to deliver content for Flash players. We may also use Flash cookies for security purposes, to gather certain website metrics and to help remember settings and preferences. Flash cookies are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please visit Adobe’s website at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.  If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain content and product features.

Pixel Tags and Web Beacons

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions. 

Server Logs and Other Technologies

We collect many different types of information from server logs and other technologies.  For example, we may collect information the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located.  Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to Cengage and the website you visit after you leave our site

We have relationships with third party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These third party advertising companies may place cookies on your computer when you visit our website or other websites so that they can display targeted advertisements to you.  

These third party advertising companies do not collect Personal Information in this process, and we do not give any personal information to them as part of this process.  However, this Privacy Notice does not cover the collection methods or use of the information collected by these companies. For more information about third party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org.  To opt out of being targeted by many third party advertising companies by visiting www.networkadvertising.org/consumer/opt_out.asp or http://preferences.truste.com/truste/.

Additional information from the third party advertising companies that we work with:

• Omniture: If you would like more information on how to remove yourself from the tracking and reporting functions performed for this website by Omniture, please visit the Omniture Opt-Out Page at http://www.omniture.com/en/privacy/2o7 and follow the relevant instructions.
• Google Analytics: For information on how Google Analytics uses data please visit “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/.

Although our websites currently do not have a mechanism to recognize the various web browser Do Not Track signals, we do offer our customers choices to manage their cookie preferences as described in the previous section. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/

Our websites may enable you to interact with us and others via social media platforms, such as Facebook, Twitter, Pinterest and Instagram. While we respect each social media platform’s privacy policies, we may collect Personal Information about you and your friends if you choose to use these tools.

For example, we may allow you to sign into Cengage websites and applications using Facebook Connect. If you choose to do this, we may collect information necessary to facilitate social interactions such as friend lists, birthday, check-ins, basic profile information and your profile picture but only if the privacy settings you and your friends set within Facebook allow it. We will use the information to facilitate an interactive social experience.

We may display interest-based ads to you when you are using platforms such as Facebook and Google. These platforms allow us to personalize the ads that we display to you. We do not share any of your Personal Information with these platforms, although we may convert your email address into a unique number which can be matched by the platform with its user to allow delivery of the advertising. Although we do not provide any personal information to these platforms, they may gain insights about individuals who respond to the ads we serve.

Our websites may enable you to interact with us and others via social media platforms, such as Facebook, Twitter, Pinterest and Instagram. While we respect each social media platform’s privacy policies, we may collect Personal Information about you and your friends if you choose to use these tools.

For example, we may allow you to sign into Cengage websites and applications using Facebook Connect. If you choose to do this, we may collect information necessary to facilitate social interactions such as friend lists, birthday, check-ins, basic profile information and your profile picture but only if the privacy settings you and your friends set within Facebook allow it. We will use the information to facilitate an interactive social experience.

We may display interest-based ads to you when you are using platforms such as Facebook and Google. These platforms allow us to personalize the ads that we display to you. We do not share any of your Personal Information with these platforms, although we may convert your email address into a unique number which can be matched by the platform with its user to allow delivery of the advertising. Although we do not provide any personal information to these platforms, they may gain insights about individuals who respond to the ads we serve.

Our products may provide forums and other public areas where instructors and students can communicate. Prior to posting in these areas, please read our Terms of Service carefully.  All the information you post will be viewable to anyone with access to the area, and any Personal Information you include in your posting may be read, collected, and used by others. For example, if you post your mobile telephone number, you may receive unsolicited calls.  Please use caution when posting any Personal Information.

We may offer “tell-a-friend” functionality on our websites.  If you choose to use this function, we will collect Contact Information for your friend.  We will automatically send your friend a one-time email with the information you specified or inviting him or her to visit the site. We use this information for the sole purpose of sending this one-time email and does not retain the information.

You can always limit the information you provide to us.  You can also limit the communications that we send to you.  To opt-out of emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. To revoke permissions that you may have given to send text messages, text STOP in response to any message.

Please note that even if you opt-out of commercial emails, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations.

If you do not want us to share your information with third parties for their own marketing, you can opt-out by contacting our Customer Service department by email at: [email protected] or phone at +1 800.354.9706 (M - F, 8:00 am - 6:00 pm ET).

If you have any questions about your choices or if you need any assistance with opting-out, please contact us via email to [email protected].  You can also write us at the address in the How to Contact Us section below.  If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.

Cengage respects the rights of European Economic Area (EEA) residents to access, correct and request erasure or restriction of their personal information as required by law. If you are a resident of the EEA, you generally have a right to know whether or not Cengage maintains your PI. If your information is incorrect or incomplete, you have the right to ask Cengage to update it.  You have the right to object to Cengage’s processing of your PI. You may also ask Cengage to delete or restrict your PI.

To exercise these rights, please contact Cengage via email at [email protected] and a member of Cengage’s Privacy Team will assist you.  Please understand that Cengage may need to verify your identify before processing your request.

We respect your right to reasonably access and correct your Personal Information.  If you have an online account, you can log into your account at any time to access and update the information you have provided to us.  Additionally, Cengage Learning complies with all laws regarding access and correction.  If you need assistance updating your Personal Information, please contact us via email to [email protected].

We will retain your data no longer than necessary to accomplish the purpose for which it was collected and in accordance with our retention policies. Cengage Learning will retain data as necessary to comply with our obligations, resolve disputes, enforce agreements, and to comply with retention as applicable by law. For more information on retention please contact [email protected].

Your personal information may be transferred to, stored at or processed in the United States and other countries which may not have equivalent privacy or data protection laws.  However, regardless of where your personal information is transferred, we will protect it in accordance with this Privacy Notice.

We recognize and acknowledge current data protection laws in the European Union, and around the world. To comply with privacy laws in the European Union, we have implemented appropriate contracts for the international transfer of PII, on the basis of the standard contractual clauses approved by the European Commission and other international models as required by local law, to provide a legal mechanism for transferring data to Cengage Learning, Inc. locations globally. For more information on the aforementioned model contracts and how to obtain a copy of the contract, please contact the Privacy Office at [email protected].

We have implemented reasonable technical, physical and administrative safeguards to help protect your personal information against unauthorized access or loss. For example, when we ask users to provide payment information (such as credit card number), the data is protected during transmission to us using industry-standard encryption.

This Privacy Notice only addresses the use and disclosure of information by Cengage, Inc. and its affiliates. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices.  We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

If you have applied for employment with Cengage, the Personal Information submitted with your job application will be used only for recruitment and other customary human resources purposes. Please contact us at [email protected] if you would like a copy of our HR Privacy Notice.

From time to time, we may update this Privacy Notice to reflect new or different privacy practices. We will place a notice online when we make material changes to this the Privacy Notice.

Please contact us if you have any questions or comments about our privacy practices or this Privacy Notice.  You can always reach us online at [email protected].  You can also reach us via mail to:

Cengage Learning, Inc.
Privacy Office
20 Channel Center
Boston MA 02210