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