Privacy Policy

(Revised 1/3/23)

Substantial is committed to the protection of your personal information. This Privacy Policy sets out the basis on which Substantial collects and uses personal information about you as part of our business activities.

This Privacy Policy describes in detail who is responsible for the personal information that Substantial collects about you, what personal information is collected, how Substantial uses such personal information, who Substantial may disclose it to and your rights and choices in relation to your personal information.

This Privacy Policy generally covers information collected at https://substantialclassrooms.org and any other subdomain, website or webpage that Substantial may have in place now or in the future (collectively, the “Substantial Website”), but also relates to information collected by Substantial outside of the Substantial Website including through the provision of services.

Who is Responsible for the Personal Information That Substantial Collects?

For the purposes of all relevant data protection laws, Substantial is the data controller as to the personal information that is collected and used as part of its business activities. This is because Substantial dictates the purpose for which your personal information is used and how Substantial uses your personal information.

What Personal Information Does Substantial Collect?

While some of the information collected is required for business engagement purposes, other information is voluntarily given by you. The type of personal information that Substantial may collect could include, but not limited to, the following:

Your full name, e-mail address, phone number and email contact information;
Demographic information including but not limited to ethnicity and gender;
Your job title and the organization for which you work;
Your work experience, career goals, interests and objectives;
Preference information, such as the communications you receive from us;
Information you provide to us for the purposes of attending meetings, events, webinars and other programs; and
Any other information relating to you (or other individuals) which you may provide to us.

If you are providing personal information to Substantial relating to a third party, you confirm that you have the consent of the third party to share such personal information with Substantial and that you have made the information in this Privacy Policy available to the third party.

Sensitive Categories of Information

Some jurisdictions consider certain personal information particularly sensitive. Substantial collects this data for statistical and reporting purposes only. This information may be required in order to create an account on our platforms, as some grantors require that we track the age of our participants. Substantial does not share this information with third parties for business purposes; Substantial only shares this information with grantors when required as a term of the grant. Whenever possible, when such information is shared, Substantial will provide it in aggregate form. Such information may include the following:

Date of birth
Ethnicity
Gender
Age
Employer

Website Usage Information

Substantial collects information when you provide it to Substantial, such as when you use the “contact us” feature on the Substantial Website, register for access to services or otherwise communicate with Substantial (such as by email, via Substantial social media pages or through survey responses).

Substantial collects certain information automatically when you use the Substantial Website, such as your IP address and domain name, browser type, history of pages viewed and other usage information about your use of the Substantial Website. Substantial collects this information for site administration purposes, such as to analyze this data for trends and statistics. Substantial may share statistical or aggregated non-personal information about its users with advertisers, business partners, sponsors and other third parties. This data is used to customize the Substantial Website content and advertising to deliver a better experience to our users. Please see the section below on cookies for more information.

How Does Substantial Obtain Your Personal Information?

As noted above, we collect information from you in the course of your use of the Substantial Website. For example, Substantial collects information from you when you contact or communicate with Substantial (including through the Substantial Website, by email or otherwise) or when you register for access to services through Substantial’s website.

Substantial also collects your personal information while monitoring the Substantial Website. Substantial also gathers information about you when you provide it to us or interact with us directly including but not limited to through the completion of electronic surveys.

How Does Substantial Use The Personal Information It Collects?

Substantial collects personal information for the following principal purposes; for each purpose, Substantial has also set out below the legal basis under relevant data protection laws that we rely on to justify this use of your personal information.

Purpose	Legal Bases
To provide the Substantial Website and services through the website to you	For our legitimate business purposes (i.e., the provision of the Substantial Website) and, depending on the circumstances, to perform a contract between you and Substantial.
To communicate with you and to respond to questions that you have raised with Substantial;	For our legitimate business purposes (i.e., the provision of the Substantial Website).
To administer and improve the Substantial Website;	For our legitimate business purposes (i.e., the provision of the Substantial Website, as well as to improve and ensure the security of the Substantial Website). Substantial may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law (e.g., in relation to our use of certain cookies).
To process your payment for Substantial services, products and events;	For our legitimate business purposes (i.e., the provision of the Substantial Website).
To send you, or for our third-party partners to send you, information about products, services and events that may be of interest to you based on your preferences;	For our legitimate business purposes (i.e., the provision of the Substantial Website). Substantial may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law.
To administer surveys;	For our legitimate business purposes (i.e., the provision of the Substantial Website). Substantial may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law.
To prevent and detect fraud; and	For our legitimate business purposes and for compliance with legal obligations to which we are subject
To protect and enforce Substantial’s legal rights.	For our legitimate business purposes and for compliance with legal obligations to which we are subject

With Whom Does Substantial Share Your Personal Information?

Substantial reserves the right to disclose and/or transfer personal information to a third party, if Substantial has reason to believe that disclosing personal information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) Substantial rights or property, other Substantial Website users or anyone else who could be harmed by such activities. Additionally, Substantial may disclose personal information in response to a subpoena, warrant or other court order, or when Substantial believes in good faith that a law, regulation, subpoena, warrant or other court order requires it.

Substantial reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Substantial.

Substantial may share your information with personal advisors, such as accountants, lawyers, and grantors, who assist us in carrying out our business activities.

Substantial may share your information, including details about your engagement with a product (course completion percentage, level of participation, etc.) with your employer or other organization with which you are associated. Substantial may also share survey responses and other information provided by you with your employer or other sponsoring organization but will only share any demographic information in the aggregate.

Substantial may share personal information with third parties engaged to assist Substantial in providing services to you or to carry out one or more of the purposes described above. These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are contractually required to protect personal information disclosed by Substantial and to comply with the general privacy principles described in this Privacy Policy.

If you choose not to provide Substantial with your personal information, you may still visit the Substantial Website. However, you may be unable to access certain website options, such as use the Substantial Website functionality to its fullest extent.

Transfer of Personal Information Across Borders

Substantial is a global organization. Substantial may allow your personal information to be shared with its related entities or third-party service providers based both within the United States and in other countries. This may entail a transfer of your information from a location within the EEA to outside the EEA, or from outside the EEA to a location within the EEA.

When Substantial provides your personal information in such instances, such is done in connection with providing your requested information or services, or as required or authorized under law. It is possible the overseas entities with which Substantial shares your information with may not be subject to laws that provide the same level of protection of information as your country of residence or may not be subject to any privacy obligations. Overseas entities may be required or compelled to disclose your personal information to a third party, such as an overseas authority. When we transfer information outside of the EEA, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.

Unfortunately, the transmission of information via the internet is not completely secure. Although Substantial uses reasonable efforts to protect your personal information, it cannot guarantee the security of your personal information transmitted to the Substantial Website and any transmission is at your own risk. Once Substantial has received your personal information, it will use reasonable and appropriate procedures and security features to try to prevent unauthorized access.

Your Rights, Including Removing, Correcting or Updating Personal Information

If you change your mind on how Substantial discloses or uses your information, or wish to access, correct or update personal information (such as your address), it will endeavor to correct, update or remove the personal data you give us.

THE BELOW TABLE APPLIES TO INDIVIDUALS LOCATED IN THE EU AND EEA ONLY: You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights and who to contact to exercise them.

	Summary of your rights	Who to contact
Right of access to your personal information	You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions. Substantial may require further information in order to respond to your request (for instance, evidence of your identity and information to enable us to locate the specific personal information you require);	Substantial at [email protected]
Right to rectify your personal information	You have the right to ask Substantial to correct your personal information that it holds where it is incorrect or incomplete.	Substantial at [email protected]
Right to erasure of your personal information	You have the right to ask that Substantial delete your personal information in certain circumstances. For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which Substantial relies on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if Substantial has used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.	Substantial at [email protected]
Right to restrict the use of your personal information	You have the right to suspend Substantial’s use of your personal information in certain circumstances. For example (i) where you think your personal information is inaccurate and only for such period to enable Substantial to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) Substantial no longer needs your personal information, but your personal information is required by you for the establishment, exercise or defense of legal claims; or (iv) you have objected to the use of your personal information and Substantial is verifying whether its grounds for the use of your personal information override your objection.	You may effectuate this right at any time by contacting Substantial at [email protected]
Right to data portability	You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organization, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means.	You may effectuate this right at any time by contacting Substantial at [email protected]
Right to object to the use of your personal information	You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and Substantial uses your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes.	You may effectuate this right at any time by contacting Substantial at [email protected]
Right to withdraw consent	You have the right to withdraw your consent at any time where Substantial relies on your consent to use your personal information.	You may effectuate this right at any time by contacting Substantial at [email protected]
Right to complain to the relevant data protection authority	You have the right to complain to the relevant data protection authority where you think Substantial has not used your personal information in accordance with data protection law.	Find your National Data Protection Authority online

How Long Will Substantial Keep Your Personal Information?

Substantial keeps your personal information for the period of time that you are a user of the Substantial Website and for five (5) years after you discontinue use of the Substantial Website.

Links to Other Websites

The Substantial Website may contain links to other websites not controlled or legally affiliated with Substantial. These sites are not controlled by Substantial and Substantial is not responsible for any content contained on any such website. Substantial is not responsible for the privacy practices employed by other sites, and the privacy practices employed by such sites may not be the same as Substantial’s privacy practices. As with the Substantial Website, you should become familiar with any external party’s privacy policy before visiting and/or providing any personal information through any such site.

Substantial may terminate access for any party who is found to repeatedly provide or post protected material without necessary rights and permissions.

Substantial uses cookies to manage its website. A cookie is a small file placed on your computer when you visit a website. Cookies are used to store information to manage your website experience such as your type of web browser. A cookie can also store preference information to customize your website experience.

Cookies help us understand how parties use our website so Substantial can design better services in the future. You can adjust your web browser to disable cookies. However, Substantial may not be able to provide you with all the services or functionality available on the Substantial Website if you choose to disable cookies.

You may also remove Substantial cookies from your browser. Please refer to your browser’s help menu for instructions.

Contacting Substantial with Questions, Concerns or Complaints

Should you have any questions, concerns or a complaint about this Privacy Policy, please contact Substantial at [email protected]. You are entitled to make an anonymous complaint or inquiry in relation to this Privacy Policy or your privacy rights; however, Substantial may require you to identify yourself if required by law or it is impracticable for us to deal with your matter otherwise.

Substantial Website and Communications Terms of Use

Please refer to Substantial’s Terms of Use and/or Terms and Conditions on all issues related to accessing, posting and sharing information through the Substantial Website and communication services.

Changes to The Substantial Privacy Policy

Any material changes to the Privacy Policy will be posted on this page. The updated Privacy Policy will take effect as soon as it has been posted.