Effective October 9, 2019
WHO WE ARE
INFORMATION WE MAY COLLECT FROM YOU
Information You Provide to Us
Using our Services
We collect certain technical information (“Technical Information”) to help us operate and provide our Services to you. We collect this Technical Information when you use our Services, including:
• Information about the device(s) you use to access our Services, including MAC address, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, and device identifiers;
• Information about your visits to the Websites we provide, including the full URL clickstream to, through and from these Websites (including date and time);
• Information we need and use to facilitate your use of our Services (including to provide access to third party websites and services), such as URL requests, destination IP addresses, or device configuration details;
• Pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
We may supplement Technical Information we collect from you with information collected by third parties. Third parties may include advertising partners or other providers that help us understand our users and provide better service to our users.
Personally Identifiable Information
Some of the information we collect through your use of our Services or communications with us, such as your name, address, phone number, email address, credit card number, practice area, name of your college, graduation year, employer name, CPA examination date, or certification number may personally identify you. We will treat this information as “Personally Identifiable Information.” We will also treat as Personally Identifiable Information any non-identifiable information that is combined with Personally Identifiable Information.
Aggregate or Anonymized Information
We may combine Technical Information or non-Personally Identifiable Information about your use of our Services with similar information we obtain from other users for use in an aggregate or anonymous manner.
Other Collection of Information
Our Services may also, from time to time, contain links to and from social media platforms such as Facebook, Twitter, LinkedIn, Instagram, and YouTube. You may choose to connect to us through a social media platform or log in to your account through your social media account, and when you do, we may collect additional Personally Identifiable Information from you, such as your screen names, profile picture, contact information, likes, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect Personally Identifiable Information from you. We do not have control over the collection, use and sharing practices of social media platforms and encourage you to review their usage and disclosure policies and practices, including the data security practices, before using the social media platforms.
Third parties may also collect information about you, including tracking your browsing history, when you use our Services. We do not have control over these third party collection practices and advises you to adjust the setting of your browsers or install plug-ins and add-ins to minimize these third party collection.
We will not ask for or request sensitive information such as government identifiers, medical information, or financial information (other than for payment for our Services). Please do not provide this information to us through emails, feedback forms or in any other way.
HOW YOUR INFORMATION MAY BE USED
We may use any information we collect to:
• Allow us to operate our Services, including administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
• Manage your access to our Services;
• Send you information that allows you to use our Services;
• Notify you about your accounts, courses, and registrations, including information related to their expiration, renewal and subscription;
• Comply with laws and regulations;
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection;
• Notify you about changes to our Services;
• Allow you to participate in interactive features through our Services;
• Maintain the security of our Services;
• In any other way we may describe when you provide the information;
• For any other purpose with your consent.
We may use your information, including Personally Identifiable Information, to:
• Provide you with information about goods or services that may interest you;
• Send you emails about updates, information, or alerts regarding our Services.
We may use Technical Information or non-Personally Identifiable Information to:
• Improve our Services and present content in the best way for you and for your device(s);
• Serve advertisements on through our Services;
• Measure or understand the effectiveness of advertising we serve to you and other customers like you, and to deliver relevant advertising to you and other customers like you.
HOW YOUR INFORMATION MAY BE SHARED
We will not sell your Personally Identifiable Information or share your Personally Identifiable Information with third parties for the third party's own direct marketing purposes. Please note that if you click on or otherwise interact with an advertisement through our Services, however, the advertiser may assume that you meet its target criteria, even though we have not shared your Personally Identifiable Information.
We may share information, including Personally Identifiable Information, with our service providers and agents to the extent reasonably necessary to provide you with our Services. For example, we use a third party platform for email and cannot communicate with you without disclosing your email address to our third party email provider. These third parties use any information we share only to support us and our efforts to provide our Services.
We may share any information, including Personally Identifiable Information with:
• Our subsidiaries and affiliates
• Our service providers and sub-contractors to the extent reasonably necessary to enable us provide our Services;
• A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our users is among the assets transferred;
• A third party with whom we must legally share information about you;
• You, upon your request;
• Other third parties with your express consent;
We may also disclose your Personally Identifiable Information:
• To comply with any court order, law or legal process, including to respond to any government or regulatory request;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Surgent, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• For any other purpose disclosed by us when you provide the information.
We may share non-Personally Identifiable Information, aggregate or anonymous data:
• With analytics, search engine, or other service providers that help us improve our Services;
• To advertisers and advertising networks to select and serve relevant advertisement.
In the event that we receive a request from a governmental entity to provide it with your Personally Identifiable Information, we will take reasonable attempts to notify you of such request, to the extent possible.
COOKIES AND WEB BEACONS
• Flash Cookies. Certain features of our Services may use local stored objects called flash cookies to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse Flash cookies, please note that some parts of our Services may be inaccessible or not function properly.
• Web Beacons. Our Website and e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us to, for example, count users who have visited those pages or opened an e-mail and for other related website statistics.
You may have the opportunity to receive certain communications from us related to our Services. If you provide us with your email address in order to receive communications, you can opt out at any time by using the unsubscribe links at the bottom of our emails.
Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.
Certain websites you visit may provide options regarding advertisements you receive. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info.
Some Browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Services do not currently change the way they operate based upon detection of a Do Not Track or similar signal.
Please note that we cannot control how third party websites or online services you visit through our Services respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.
SECURING YOUR INFORMATION
The security of your information is important to us. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee against access to your Personally Identifiable Information by unauthorized third parties. The security of your data transmitted to or through our Services is at your own risk. Once we have received your information, we will use appropriate and necessary administrative, technical and physical controls to prevent unauthorized access to it.
Our Services are not directed toward children under 13 years of age nor do we knowingly collect information from children under 13. If you are under 13 years of age, you are not permitted to submit any personally identifiable information to us.
LINKS TO THIRD PARTY SITES
Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check the policies applicable to a website you access via our Services before you submit any personal data to such website.
If you are a California resident, you may contact email@example.com to request certain information regarding how we share Personally Identifiable Information to third parties for their direct marketing purposes.
Our Services are operated from the United States. If you are located anywhere outside of the United States, please be aware that any information we collect, including but not limited to, Personally Identifiable Information, may be transferred to, processed in and stored in the United States.
Information may also be accessed from other locations in compliances with the US Safe Harbor requirements of the EU data protection laws. Please be aware that the data protection laws in the United States may differ from those of the country you reside in, and that your information, including your Personally Identifiable Information may be subject to access requests from governments, courts, or law enforcement in accordance to the laws of the United States. By using our Services or providing us with any information, you consent to our collection, transfer, processing and storage of your information in the United States.