Privacy Policy

Introduction

FranklinCovey respects your privacy and is committed to protecting your personal data. This privacy notice describes how your personal data is collected, handled, and stored to meet Franklin Covey’s protection standards—and to comply with the law.

1. Purpose of This Privacy Notice

This privacy notice describes how Franklin Covey collects and processes your personal data through your use of this website and the services on it, including any data you may provide.

This website is not intended to be used by children; Franklin Covey does not knowingly collect personally identifiable information from children.

It is important that you read this privacy notice, together with any other privacy notice or fair processing notice provided when personal data is collected or processed, so that you are fully aware of how your data is used. This privacy notice is supplemental to any other notice and is not intended to override.

Controller

Franklin Covey is comprised of several different legal entities, details of which are available at: https://www.franklincovey.com/About/global-offices.html. This privacy notice is issued on behalf of Franklin Covey Co. Reference to “Franklin Covey,” “we,” “us,” or “our” in this privacy notice implies Franklin Covey Co., who is responsible for processing your data. Unless otherwise stated, Franklin Covey Co. is the controller of this website.

Franklin Covey’s data privacy manager will respond to questions regarding this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details provided below:

Contact Information

Legal Entity: Franklin Covey Co.

Data Privacy Manager: Blaine Carter

Email Address: [email protected]

Postal Address: 2200 W Parkway Blvd, Salt Lake City, UT 84119, United States

The contact for our EU Representative:

Legal Entity: Franklin Covey Europe Ltd

Data Privacy Manager: Stephen Asker

Email Address: [email protected]

Postal Address: Ground Floor Blenheim Court, 19 George Street, Banbury, Oxfordshire OX16 5BH, United Kingdom

You have the right to file a complaint at any time with the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues. However, we would appreciate the opportunity to resolve your concerns before you approach the ICO, so please consider contacting us first.

Changes to the Privacy Notice and Request for Current Data

This Privacy Notice was last updated on May 11th, 2018

It is important that the personal data we hold about you is accurate and current. Please notify us of any changes to your personal information during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. Data Collection

Personal data or information means any information about an individual from which that person can be identified. It does not include data where identity is removed (anonymous data).

We may collect, use, store, and transfer a variety of personal data, including:

• Identity Data, including first name, last name, username, or similar identifier, title, date of birth and gender.
• Contact Data, including email address and telephone numbers.
• Technical Data, including internet protocol (IP) address, your login data, browser type and version, time zone and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website and our services.
• Profile Data, including your username and password, preferences, feedback, and survey responses.
• Usage Data, including information on how you use our website and services.

We also collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data, but is not considered personal data by law as this data does not reveal your identity, either directly or indirectly. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combining Aggregated Data with your personal data directly or indirectly identifies you, we treat the combined data as personal data and subject to the terms of this privacy notice.

Failure to Provide Personal Data

Where collection of personal data is required by law or under the terms of a contract with you or your employer on your behalf, failure on your part to provide the requested data may impede the performance of the contract. You will be notified if cancellation of the contracted service is necessary in this situation.

3. Personal Data Collection

Data is collected through various methods, including:

Direction interaction, including personal Identity and Contact Data entered to complete a form, or in correspondence via post, phone, email, or otherwise. Included is personal data provided when you:

• Create an account or make a purchase on our website;
• Subscribe to our service, or
• Provide feedback.

Automated technologies or interactions, including Technical Data about your equipment, browsing actions, and patterns. Personal data is collected using cookies, server logs, and other similar technologies. Collected information is used to help diagnose problems with our server and to administer our website, and allows us to deliver content tailored to your interests. We may also receive Technical Data about you when you visit other websites using our cookies.

Third parties or publicly available sources, including personal data (Identity, Contact, and Profile Data) supplied by you or your employer to enable us to provide services via our website.

4. Using Your Personal Data

Use of your personal data is limited by law. Most commonly, personal data is used:

• To allow us to fulfill a contract entered into with you or your employer.
• Where it is necessary for our legitimate interests (or those of a third party), if your interests and fundamental rights do not override those interests.
• To comply with legal or regulatory obligations. Click https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en to learn more.
• Generally speaking, we do not rely on your consent as a legal basis to process your personal data, except in sending direct marketing communications via email or text message. You may withdraw consent to receive these marketing messages at any time by contacting us at [email protected].

Your personal data may be processed for more than one lawful ground, depending on the specific purpose for its use. Please contact us at [email protected] if you require additional information.

Using Your Personal Data

Cookies

Your preferred browser can be set to refuse all or some browser cookies, or to alert you when websites set or access cookies. If cookies are disabled or refused, some parts of the website may be inaccessible or fail to function properly.

Change of Purpose

Personal data is collected and used for a specific purpose, unless we determine its use for another reason is compatible. Please contact us at [email protected] to receive an explanation of how processing for another purpose meets that criteria.

If your personal data must be used for an unrelated purpose, we will notify you and explain the legal basis that allows its use.

We may process your personal data without your knowledge or consent, in compliance with the rules stated above, where required or permitted by law.

5. Disclosure of Personal Data

We may be required to share personal data with the parties listed below for the purposes identified in the table provided in “4. Using Your Personal Data” above.

• • Internal Third Parties as defined in the Glossary
  • Third parties to whom we may choose to sell, transfer, or merge part of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change to our business occurs, new owners may use personal data in the same manner as set out in this privacy notice.

We require all third parties to respect the security of your personal data and treat it in accordance with the law. Third-party service providers are not allowed to use your personal data for their own purposes. Use of personal data is permitted only for specified purposes and must be in accordance with our instructions.

6. International Transfers

We share your personal data within the Franklin Covey Group, requiring the transfer of your data outside the European Economic Area (EEA). Additionally, many of our external third parties are located outside the EEA, again requiring the transfer of your personal data to allow processing.

Whenever your personal data is transferred outside of the European Economic Area, we ensure a similar degree of protection is implemented using at least one of the following safeguards:

• Transfer is only allowed to countries sanctioned by the European Commission to provide an adequate level of protection for personal data.
• Where certain service providers are used, specific contracts provided by the European Commission may be used to ensure personal data will have the same protection as in Europe. For further details, see European Commission: Model Contracts for the transfer of personal data to third parties.
• Data may be transferred to third-party providers in the U.S. who are members of the Privacy Shield, requiring them to provide similar protection to personal data shared between Europe and the U.S. For additional information, see European Commission: EU-US Privacy Shield.

Please contact us at [email protected] if you require additional information about our process for transferring your personal data outside of the EEA.

7. Data Security

Appropriate security measures are in place to prevent personal data from accidental loss, misuse, alteration, or unauthorized disclosure. Additionally, access to personal data is limited to those employees, agents, contractors, and third parties who are authorized to process the data on our behalf, under specific instruction, and subject to a duty of confidentiality.

Procedures are in place to deal with any suspected personal data breach. You and, if legally required, any applicable regulator will be notified of a breach.

8. Data Retention

Your personal data will be retained only as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Law requires that we keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years following the last use of the website and/or services for liability and tax purposes.

In some circumstances, you can ask us to delete your data. See Request Erasure below for further information.

We may anonymize personal data (to remove any association with personal identity) for research or statistical purposes, in which case the information may be used for an indefinite period without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have rights relating to your personal data under the General Data Protection Regulation (GDPR). Click on this link to find out more about these rights: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en

If you choose to exercise any of the rights contained in GDPR, please contact us at [email protected]. These rights are subject to certain exceptions and exclusions, and we may be unable to comply in full with your request.

Fees

You are not required to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Request for Specific Information

We may request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This security measure ensures that personal data is not disclosed to an unauthorized person. We may also contact you to ask you for additional information to speed up our response.

Response Time

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer if your request is particularly complex. In this case, we will notify you and keep you informed.

10. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected].

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation.

Internal Third Parties are other companies in the Franklin Covey Group acting as joint controllers or processors, and who are based in countries all over the world. A list of Internal Third Parties is available here: https://www.franklincovey.com/About/global-offices.html and provides IT and system administration services.