Last Edited on December 29, 2017
gathering and dissemination practices for the website study.whatsnext.com (our “Site”).
We at Midlife Crossroads work diligently to protect the privacy, confidentiality, and security of any personally identifiable information (“Personal Information” as defined below)
Personal Information means any information that may be used to identify an individual, including, but not limited to, a first and last name, a home or other physical address and an
email address or other contact information, whether at work or at home. In general, you can visit our Site without telling us who you are or revealing any Personal Information about yourself.
We strive to comply with all applicable laws around the globe that are designed to protect your privacy. Although legal requirements may vary from country to country,
may not require an “adequate” level of protection for your Personal Information. In other words, our goal is to provide protection for your Personal Information no matter where
that Personal Information is collected, transferred, or retained.
WHAT PERSONAL INFORMATION WE COLLECT
When ordering or registering on our Site, as appropriate, you may be asked to enter your name, email address, mailing address, telephone number,
or other details to help you with your user experience. This may also include billing information, account information, and other information incidental to providing or receiving products
or services or which you may choose to provide to us.
WHEN WE COLLECT PERSONAL INFORMATION
We collect Personal Information from you on certain areas of our Site when you register, take an assessment, place an order, subscribe to a newsletter, sign up for webinars and other events,
and participate in user posting areas, such as member areas, discussion forums, and surveys, fill out a questionnaire or form, or enter information anywhere on our Site.
HOW WE USE YOUR PERSONAL INFORMATION
We may use the Personal Information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication,
surf our Site, or use certain other Site features as follows:
- to improve our Site in order to better serve you.
- to allow us to respond to your customer service requests.
- to quickly process your transactions.
- to customize features, improve our assessment tools and advertising on our Site.
- to send periodic emails regarding your order or other products and services.
When participating in surveys, we may collect information about you and certain demographic information pertaining to your employment such as position and tenure.
This information will be used to produce reports and consulting services as requested by you or your organization. We will also use anonymized and aggregated survey response data for research and statistical purposes.
If you use our assessment tools while visiting our Site, you will be asked to provide certain information which we will use to generate results based on our proprietary technology. The data that you provide
and the results of our assessment may, under certain circumstances, be shared with employers or third-parties if such parties specifically order the assessments. Your name will not be publicly
disseminated to anyone other than you and the party arranging for the assessment without your specific consent.
By using our assessment tools, you acknowledge and agree that the content provided by you as well as the conclusions and assessments derived therefrom may be used by us for research,
innovation, case studies, and commercial purposes (such as in speeches, articles, books, etc.) in our discretion. Your assessment data may be aggregated for research and comparison purposes.
In certain circumstances, the assessment may have been ordered or arranged for by an employer or management consultant for a variety of purposes. The engagement of our company and the use of
our assessment tools by an employer or third-party consultant is solely and wholly that party’s responsibility and the use of your data under such circumstances is subject to such parties’
independent Privacy Policies which may be different than this policy.
HOW WE RETAIN YOUR PERSONAL INFORMATION
We retain your Personal Information for as long as your account remains active or for as long as you continue to do business with us. Thereafter, we may
retain Assessment responses and other data in non-personally-identifiable format for as long as the information is needed for our research, statistical analysis,
product development, or other commercial purposes.
HOW WE PROTECT YOUR PERSONAL INFORMATION
Our Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Site as safe as possible.
We use regular Malware Scanning.
Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your Personal Information. No method of transmission over the Internet, or method of electronic storage, is fully secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We use “cookies” and other tracking technologies. Cookies are small files that a website or its service provider transfers to your computer’s
hard drive through your Web browser (if you allow) that enables the website’s or service provider’s systems to recognize your browser and capture and remember certain information.
- to collect session data and other session information.
- to process orders and to store order and shopping cart information.
- to store and hash usernames and passwords so that you do not have to re-enter this information each time you log in.
- to better understand your website experience and to ensure that we are optimizing the functionality of our Site and survey interfaces.
- to compile aggregate data about our Site traffic and Site interaction and analyze information that does not contain Personal Information for trends and statistics so that we can offer better website experiences and tools in the future.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, some of the features that make your website experience more efficient may not function properly.
Some session cookies must be accepted to use the secured areas of our Site.
We may also use trusted third-party services that track this information on our behalf. Our Site includes videos hosted by YouTube and Wistia. YouTube will set cookies if you watch these videos.
By using our Site, you agree that we can place these types of cookies on your device.
To protect your privacy, we have adopted the Privacy Shield Principles.
HANDLING OF DO-NOT-TRACK SIGNALS
We honor Do-Not-Track (DNT) signals and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place.
It’s also important to note that we do not allow third-party behavioral tracking.
Where we collect Personal Information on the web, we intend to post a purpose statement that explains why Personal Information will be collected and whether we plan to share such Personal Information outside of Midlife Crossroads or those working on Midlife Crossroads’ behalf. We do not intend to transfer Personal Information without your consent to third parties who are not bound to act on Midlife Crossroads’ behalf unless such transfer is legally required.
For surveys, we will collect Personal Information as requested by you or your employer in order to conduct services and produce reports. Typical demographics may include, but are not limited to, name, age, gender, role, and tenure. We will also use anonymized and aggregated survey response data for research and statistical purposes. Your Personal Information will not be included in such uses. Survey response data that includes Personal Information may be stored by Midlife Crossroads for up to ten years in order to provide longitudinal services requested by our customers and for statistical research purposes.
Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our Sites is acquired by another company, information about our users may be among the transferred assets.
We may disclose Personal Information to business partners and subcontractors, as necessary in connection with the performance of requested services or solutions, or as otherwise appropriate in connection with a legitimate business need. We may also disclose Personal Information where required or permitted by law, or where we believe that such disclosures are appropriate in connection with a law enforcement request.
Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online – for example on message boards, web logs, through email, or in chat areas – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
If you have provided Personal Information to us and wish to limit our use and disclosure of that data, you can contact us.
THIRD-PARTY SERVICES/ONWARD TRANSFER
We shall not intentionally disclose or transfer (and shall take reasonable steps to protect the confidentiality and security, and to prevent the unauthorized or accidental disclosure of) your Personal Information to third-parties (i.e., persons or entities that are not affiliates of Midlife Crossroads), whether for such third-parties’ marketing purposes or otherwise, subject only to the following four exceptions:
- We may disclose your Personal Information to third-parties in the event that such disclosure is required by the laws, rules, or regulations of any nation, state, or another applicable jurisdiction.
- We may disclose your Personal Information to third-parties as appropriate for Midlife Crossroads to make transmissions or deliveries to you.
- We may disclose your Personal Information if, in connection with submitting the information, you consent to such disclosure.
- We may disclose your Personal Information in response to inquiries by bona fide rights owners in connection with allegations of infringement of copyright or other proprietary rights arising from information you have posted on WhatsNext.com or otherwise provided to Midlife Crossroads.
LINKS TO THIRD-PARTY WEBSITES
Occasionally, at our discretion, we may include or offer third-party products or services on our Site. These third-party websites have separate and independent Privacy Policies. We therefore cannot control and have no responsibility or liability for the content and activities of these linked websites, which may differ from those of our Site. We encourage you to review and understand the Privacy Policies on these websites before providing any information to them. Furthermore, we seek to protect the integrity of our Site and welcome any feedback about these third-party websites.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users: https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our Site.
We have implemented the following:
Demographics and Interests Reporting
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Site.
You can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CalOPPA)
According to CalOPPA, we agree to the following:
Users can visit our Site anonymously.
You may choose whether or not to provide Personal Information to us. The notice we intend to provide where we collect Personal Information on the Web should help you to make this choice. If you choose not to provide the Personal Information we request, you can still visit most of our Site, but you may be unable to access certain services that involve our interaction with you.
Wherever your Personal Information may be held within Midlife Crossroads or on its behalf, we intend to take reasonable and appropriate steps to protect the Personal Information that you share with us from unauthorized access or disclosure. We use third-party auditors to verify the security of our systems.
Any Personal Information we may collect will be used solely for its requested purpose.
We exercise reasonable efforts to keep your Personal Information accurate. However, we need your help in making sure that your Personal Information is correct in our systems. Where we collect Personal Information from you on our Site, it is our goal to provide a means for you to update or correct that Personal Information. If for any reason your Personal Information is inaccessible, you may contact us and we will make reasonable efforts to incorporate the changes in your Personal Information that we hold as soon as practicable.
COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)
When it comes to the collection of Personal Information from children under the age of 13 years old, COPPA puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
WhatsNext.com is not structured to attract children. Accordingly, we do not specifically market to children under the age of 13 years old nor do we intend to collect Personal Information from anyone we know to be under 13 years of age.
FAIR INFORMATION PRACTICES PRINCIPLES
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices Principles we will take the following responsive action, should a data breach occur:
We will notify you via email within 7 business days.
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- send information, respond to inquiries, and/or other requests or questions.
- process orders and to send information and updates pertaining to orders.
- send you additional information related to your product and/or service.
- market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CAN-SPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or Site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
We are committed to privacy and are actively utilizing current industry initiatives to preserve individual privacy rights on the Internet. Protecting your privacy online is an evolving area, and Midlife Crossroads’ website WhatsNext.com is constantly evolving to meet these demands.
Midlife Crossroads has established procedures for periodically verifying implementation of and compliance with the Privacy Shield Principles. Midlife Crossroads conducts an annual self-assessment of its Personal Information Practices to verify that the attestations and assertions that it makes about its Privacy Practices are true and that its Privacy Practices have been implemented as represented.
In the context of an onward transfer, a Privacy Shield Organization has responsibility for the processing of Personal Information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield Organization shall remain liable under the principles of the Privacy Shield if its agent processes such Personal Information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your Personal Information. E.U. and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact Midlife Crossroads at the information provided in the “Contact Us” section below.
Midlife Crossroads has further committed to refer unresolved Privacy Shield Complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit JAMS for more information or to file a complaint. The services of JAMS are provided to you at no cost.
Midlife Crossroads commits to cooperating with E.U. data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the E.U. and Switzerland in the context of the employment relationship.
Under certain conditions, EU Citizens may invoke binding arbitration by a Privacy Shield Panel, as outlined in Annex I of the Privacy Shield Framework. More information is available at www.privacyshield.gov.
COMPLAINTS AND DISPUTES
If you are not satisfied with our response and have a complaint about our Privacy Practices, you can contact your local Data Protection Authority.
Midlife Crossroads is subject to the investigatory and enforcement powers of the United States Federal Trade Commission and other regulatory agencies. In some circumstances, an individual having a dispute with Midlife Crossroads may invoke binding arbitration through the Privacy Shield Panel in accordance with the Privacy Shield Framework guidance published here.
Except as otherwise set forth under the “Privacy Shield” section above for Personal Information originating in the E.U. or Switzerland, if our efforts to resolve your complaint through Midlife Crossroads’ internal dispute resolution mechanisms are unsatisfactory, you agree to first attempt to settle in good faith the dispute through mediation administered by JAMS, under its International Mediation Rules, which are accessible on the JAMS website at http://www.jamsadr.com/international-mediation-rules/. The mediator may propose any appropriate remedy, such as publicity for findings of non-compliance, payment of compensation for losses incurred as a result of non-compliance, or cessation of processing of the Personal Information who has brought the complaint. The mediation will be held online and all documents and other correspondence will be transmitted through email.
If our efforts to resolve the dispute through mediation are unsuccessful, you agree to binding arbitration administered by JAMS pursuant to its International Arbitration Rules, which are accessible on the JAMS website at http://www.jamsadr.com/international-arbitration-rules/. Judgment on the award rendered by the arbitrator may be entered into any court having jurisdiction over the matter. The arbitration will be held online and all documents and other correspondence will be transmitted through email.
We are committed to making our Site accessible to all users, and we have included several features designed to improve accessibility for users with disabilities. Some of these features are described below.
Images on our Site contain “alt tags” with descriptions of the image, which aid users who listen to the content of our Site by using a screen reader, rather than reading our Site.
Articles and other special publications that are made available on our Site are generally available in HTML. In some cases, we may publish a document using Adobe Portable Document Format (PDF). We welcome comments on how to improve our Site’s accessibility for users with disabilities.
If you use assistive technology and the format of any material on our Site interferes with your ability to access the information, please use the following point of contact for assistance. To enable us to respond in a manner most helpful to you, please indicate the nature of your accessibility problem, the preferred format in which to receive the material, the web address of the requested material, and your contact information.
If you have any comments or questions regarding our Accessibility Policy, please contact us.
By email: hello [at] whatsnext.com
By phone: +1-707-953-2254
By mail: Midlife Crossroads, LLC
PO Box 102847
Denver, CO 80250
United States of America
Please also read our Terms & Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our Site.
© 2018 Midlife Crossroads, LLC