Privacy Policy

FlyingPenguins is committed to managing personal information lawfully, ethically, and with the highest standards of professionalism and responsibility. We have provided the information below to help you understand how FlyingPenguins collects, uses and discloses personal information, and how you can exercise choices and rights over your personal information.

By using FlyingPenguins’ websites, apps, or other online services that link to this Privacy Policy (collectively, “Sites”), you are subject to the terms and conditions of this Policy.

Types of personal information we process
‍Personal information means any information relating to an identified or identifiable individual. The types of personal information that we process are determined by how individuals interact with us and the particular products and services that we provide. The types of personal information that we process include:Identifiers, such as name, email address, username, IP address.Contact information, such as email address, postal address, telephone number;Commercial information about how individuals engage with us, such as purchase history and subscription information;Financial information, such as a credit or debit card number;Engagement information, such as comments, feedback, posts, enquiries, and communications;Some of the personal information that we process may constitute sensitive personal information, which can be defined differently according to each country’s local data protection laws. We will only process such sensitive personal information where this is necessary to fulfill a specific and legitimate purpose.

‍Self-Assessment Data
‍Utilizing our Service involves you taking one or more self-assessment tests and providing information about yourself (collectively, “Self-Assessment Data”). Any Self-Assessment Data that you provide through the Service becomes a part of your user profile which may also be shared with your associated organization(s) and their authorized personnel. If you share Self-Assessment Data with an organization, other users within that organization will have access to your Self-Assessment Data. Your Self-Assessment Data will be displayed along with your profile to that organization. Your user profile and Self-Assessment Data may be shared with third parties and members of your organization, subject to your privacy settings. We are not responsible for the accuracy of your Self-Assessment Data or any information that you post to your profile. We cannot prevent such information from being used by others in a manner that may violate this Privacy Policy, the law or your personal privacy.
Where we collect personal information from

Information provided directly
‍We collect personal information directly from individuals who use our Sites or services, visit our office locations, or communicate with us.

‍Information collected through automated technologiesWe collect personal information when our Sites are used, either directly or through our third-party analytics providers. This might include Internet Protocol (IP) address, browser type and settings, device identifier details, internet service provider (ISP), referring and exit pages, the Site content interacted with, operating system, clickstream data, location data, or other usage information. We collect this information through tracking technologies, including first and third-party cookies, web beacons (also known as tracking pixels or pixel tags), embedded scripts, location-identifying technologies, device recognition technologies, and session replay software. We may combine this information with other information that we hold.We use this information to enable Site functionality, understand Site interaction trends, gather demographic insights about our user base, personalize user experiences, and otherwise administer and improve our Sites and services.

‍Information we receive from other sourcesWe receive personal information from third parties such as business partners that we work with to provide our services.
Use of personal information
‍Depending on how individuals interact with FlyingPenguins, we use personal information where it is necessary to perform contractual obligations, where consent has been given, where it is necessary to comply with a legal or regulatory obligation, or (if permitted by jurisdictional law) where we or a third party have a legitimate and lawful business need. This includes processing personal information for the following purposes:Administration of products and services.
- Providing, managing and supporting our products and services.
- Marketing and communication.
- Evaluating and improving our business (including enhancing our Sites, services, products, and communications; developing new Sites, services, and products).
- Performing data analytics for internal research or other business purposes.
- Business management and administration.
- Complying with legal or regulatory obligations.

We may use personal information for other purposes that we inform you of where we have prior consent, a legitimate business interest, or another lawful basis to do so.We may aggregate or anonymize information so that it is de-identified and can no longer be used to identify individuals. Subject to applicable laws, this information may be used for analytical purposes such as developing our products and services, identifying industry trends, and benchmarking.
Sharing personal information
‍Within FlyingPenguins. We may share personal information with our affiliate companies for the purposes described in the “Use of Personal Information” section above.With our service providers. We may share personal information with service providers that perform services on our behalf. Before we share personal information with any service provider, they must agree to comply with applicable laws, maintain strong data security, and only process personal information as we instruct.With partner organizations. We may share personal information with certain partners, including:Where a third party such as an academic institution, school, employer, business or other entity provides you with access to a FlyingPenguins product or service, we may share information regarding your usage of the product or service, results of assessments taken, and other information you input into the product or service.Where, even if not described above, you have consented to disclosure or we have a lawful and legitimate business reason for disclosure.With public authorities: We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.With other third parties. We will share personal information with other third parties where we have a good faith belief that disclosure is necessary to comply with the law or with legal process, to protect and defend our rights and property, to protect the safety or property of our users or the general public, or to protect against misuse or unauthorized use of our Sites and services. FlyingPenguins does not sell personal information to other organizations.
International transfers
‍FlyingPenguins is an international business. We take all necessary steps to ensure that personal information is treated securely and in accordance with all applicable data protection laws.If we transfer personal information out of the European Economic Area we implement appropriate safeguards in accordance with applicable law, such as the European Commission’s Standard Contractual Clauses.
Retention of personal information
‍We keep personal information for as long as necessary to carry out the purposes described above, to resolve disputes, and for any additional period required by law (e.g. reporting or accounting obligations).
Security of personal information
‍The security, integrity, and confidentiality of personal information is of paramount importance to FlyingPenguins. We have implemented technical, administrative, and physical security measures that are designed to protect personal information from unauthorized access, disclosure, use, modification and destruction.
Children
‍We do not knowingly collect, use, or disclose information from or about a child under 14 years old without the prior consent of their parent or guardian. If you are a minor under applicable law, you should not use FlyingPenguins’ Sites or services for any purpose.
Your rights
‍In compliance with certain privacy laws, in particular the European General Data Protection Regulation (GDPR) and the UK GDPR, you have certain rights in relation to your Personal Data. More specifically and under certain circumstances:
the right to request information about whether and which Personal Data is processed by us, and the right to request that such Personal Data is rectified or amended;
the right to request that your Personal Data be deleted;
the right to request that the processing of your Personal Data be restricted or object to the processing of your information on grounds relating to his or her particular situation, or at any time for direct marketing purposes;
the right to withdraw your consent to the processing and use of your data completely or partially at any time with future application;
the right to obtain your Personal Data in a common, structured and mechanically readable format, and to transmit those data to another controller;
the right to contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your Personal Data; and
the right to complain to the responsible supervisory authority if believed that the processing of your Personal Data is in violation of the legislation.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights or have any questions, please email support@flyingpenguins.co. This United States Consumer Privacy Notice (“State Notice”) supplements our Privacy Policy and provides additional information for residents of certain states with comprehensive privacy laws, such as California. This State Notice applies to Personal Data we collect, use and disclose from those applicable U.S. state residents.

‍Your State privacy rights
‍As a resident of certain U.S. states, you may have the right to submit certain requests relating to your Personal Data, as listed below, depending on your state of residency, such as California. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Right to Know. If you are a California resident, you have the right to know what Personal Data we have collected about you, which includes:
The categories of Personal Data that we have collected about you.
The categories of sources from which the Personal Data was collected.
The business or commercial purpose for collecting, selling, sharing or disclosing the Personal Data.
The categories of Personal Data that we sold or shared, and for each category identified, the categories of third parties to which we sold or shared that Personal Data.
The categories of Personal Data that we disclosed for a business purpose, and the categories of recipients to which we disclosed that Personal Data.
The specific pieces of Personal Data we have collected about you.

Right to Access, Confirm and Data Portability. You may have the right to confirm whether we are processing your Personal Data, to access your Personal Data, and to obtain a copy of Personal Data you provided to us in a portable format.

Right to Delete. You may have the right to delete the Personal Data that we have collected from you, subject to certain exceptions.
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Right to Correct. You may have the right to request that we correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and our purposes for processing it.

Right to Opt Out of Sales and Sharing of Personal Data for Targeted Advertising. You may have the right to opt out of the sale of your Personal Data, and to request that we do not share your Personal Data for targeted or cross-context behavioral advertising.

Right to Withdraw Consent or Limit Use and Disclosure of Sensitive Personal Data. If we process Sensitive Personal Data from you, you may have the right to withdraw a previously provided consent for processing your Sensitive Personal Data for a specific purpose. For California residents, we do not use or disclose Sensitive Personal Data for purposes to which the right to limit use and disclosure applies.

Right to Know Third Party Disclosures. You may have the right to request a list of third parties to which we have disclosed Personal Data.

Rights Related to Automated Decision-Making or Profiling. We do not use your information for profiling in furtherance of decisions that produce legal or similarly significant effects or for the purposes of automated decision-making as defined under currently applicable law.Right to Appeal. If you have previously submitted a privacy rights request to us that has been denied and you believe that we denied it in error, you may have the right to appeal for reconsideration of your request by emailing us at support@flyingpenguins.co.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination.
Questions and complaints
‍If you have any questions or comments about FlyingPenguin’s use of your personal information, or if you wish to submit a complaint or exercise your rights, please email us at support@flyingpenguins.co.
Links to third-party websites
‍FlyingPenguin’s Sites or Services may include links to third-party websites not owned by FlyingPenguins. When using such links, please be aware that any third-party website is subject to its own privacy and data protection policies and is not covered by this Privacy Policy.
Updates to this privacy policyWe periodically review this Privacy Policy to ensure it is up to date. Any changes to the Privacy Policy will be posted on this page and will become effective as of the Effective Date above. If we make a material change in the way we collect, use, or share personal information, we will post a prominent notice or provide other notice as required by law. We encourage you to periodically review this page for the latest information on our privacy practices.