Conover Company / Oakwood Solutions, LLC
Privacy Policy

The Conover Company / Oakwood Solutions, LLC (“Conover Company”) has created this Privacy Policy to demonstrate our commitment to the privacy of our users. The Privacy Policy describes how Conover Company collects, uses, and discloses information collected through your use of this website, located at https://www.conovercompany.com/ (“Site”) and services including, but not limited to, Conover Online, ConoverU, Conover Resources for Soft Skills, and Conover Resources for Life Skills (collectively, “Services”). By accessing or using the Site and Services, you acknowledge and agree that you have read, understand, and agree to be bound by the Privacy Policy.

I. Collection of Information

We collect “Personal Information” and “Non-Personal Information.” For the purpose of this Privacy Policy, Personal Information means any information relating to an identified or identifiable individual that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in any context, such as your name, email address, phone number, mailing address, and credit card information. Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, IP Addresses, referring/exit pages and URLs, platform types, preferences you submit, and preferences that are generated based on that data you submit. We obtain Personal Information and Non-Personal Information from various sources as described below.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the service or if we are legally required to collect it.

The Conover Company’s use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

A. Information You Provide Us

Registration and Online Purchases
Access to our Services requires prior purchase and end user registration. When ordering or registering on our Site, you may be required to submit the following types of Personal Information to Conover Company: your name, email address, phone number, credit card information, and information about your organization, as well as, the names and email addresses of your individual users.

Customer Support
We may collect information through your communications with our customer support team or other communications that you may send us and their contents. For inquiries and questions, we collect the inquiry or question, together with the name, email address, phone number, and mailing address, and any other information voluntarily submitted to us through a contact form or email. We use this information to respond to such inquiries and questions.

Surveys
From time to time, we provide users opportunities to voluntarily provide feedback or participate in surveys. Conover Company collects information requested in the survey questions and uses that information to evaluate, support, maintain and improve products and services; develop new products and services; conduct research; and for other purposes as specified in the survey.

B. Information Automatically Collected

Application and System Logs
When you use our Services, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, type of computer/device, operating system, and internet service provider. We use this information for support purposes and to monitor the health of our Services, identify problems, improve service, detect unauthorized access and fraudulent activity, prevent and respond to security incidents, and appropriately scale computing resources.

Web Analytics
Conover Company may use third party web trend analytical services, including Google Analytics, to collect visitor information such as IP addresses, browser types, referring pages, pages visited, and time spent on a particular site. While these analytical services collect and report information on an anonymous basis, they may use cookies to gather web trend information. The information gathered may enable Conover Company to link information with application and system Log Data. Conover Company uses this information for system administration and to identify problems, improve service, detect unauthorized access and fraudulent activity, prevent and respond to security incidents, appropriately scale computing resources and otherwise support and deliver the Services.

Google, as a third-party vendor, uses cookies to serve ads on our Site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our Site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

Cookies and Similar Technologies
Like many websites, we also use cookies to store user preferences, make the Site more user-friendly, and collect information about site usage and performance. Cookies are small data files that a site or its service provider transfers to your computer’s hard drive through your browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. Sending a cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when utilizing our Services, both on an individual and aggregate basis. We use cookies to help us remember and process the items in your shopping cart; understand your preferences based on pervious or current site activity, which enables us to provide you with improved services; and compile aggregate data about site traffic and site interaction to offer better site experiences and tools in the future.

Conover Company may use both persistent and session cookies. Persistent cookies remain on your computer after you close your session and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. Session cookies expire when you close your browser.

You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please note that if you delete, or choose not to accept, cookies from the Site or Services, you may not be able to utilize the features of the Site or Services to their fullest potential.

Do Not Track
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

C. Children’s Privacy

The Site and Services are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13 or allow anyone under the age of 13 to sign up for our Services. If we learn that we have gathered personal information from anyone under the age of 13 without consent of a parent, guardian, or their educational institution, we will delete that information as soon as possible. If an educational institution with children under the age of 13 uses our Services, the educational institution may also provide us with Personal Information about its students. We use student information to provide the Services to the educational institution and its students, consistent with this Privacy Policy.

II. How We May Use Information

We may use the Personal Information we obtain about you to:

• create and manage your account, provide our Services, process payments, and respond to your inquiries;
• communicate with you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
• aggregate your Personal Information for analytical purposes;
• operate, evaluate, and improve our business;
• better service you in responding to your customer service requests;
• ensure the security of our Services;
• enforce our agreements related to our Services and our other legal rights; and
• comply with applicable legal requirements, industry standards and our policies.

III. How We Share Information

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We may disclose the Personal Information we collect about you as described below or otherwise disclosed to you at the time the data is collected.

A. Service Providers

We engage certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, and database storage and management. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.

B. Compliance with Laws and Law Enforcement

Conover Company cooperates with government and law enforcement officials or private parties to enforce and comply with applicable federal, state, and local law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to:

• investigate, respond to, and defend against claims;
• for legal process (including subpoenas or court orders);
• to protect Conover Company against liability;
• to protect the security and safety of individuals, data, assets, and systems;
• to investigate or address actual or suspected fraud or other illegal activities; and
• to exercise its legal rights, including enforcement of the Terms of Service.

C. Business Transfers

Conover Company may sell, transfer or otherwise share some or all of its assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy, subject to the provisions of this Privacy Policy. The acquiring company or party will adhere to and follow all the confidentiality terms identified in this Privacy Policy.

D. Other Third Parties

We may share Personal Information with our headquarters and affiliates, and business partners to whom it is reasonably necessary or desirable for us to disclose your data for the purposes described in this Privacy Policy.

Conover Company may make certain Non-Personal Information available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and functionality available through the Services. We also allow third-party behavioral tracking.

E. Third-Party Links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. However, we are not responsible for the privacy practices used by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and our Services. This Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Site or via our Services. To the extent you access or use the services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

F. FERPA Requests

FERPA provides students with privacy rights and protection for educational personally identifiable information collected and processed on behalf of educational institutions receiving government funding from the U.S. Department of Education. FERPA provides students with rights to obtain from these educational institutions access to their educational records, as well as correction and amendment of their educational records. To the extent that data collected by Conover constitutes education records, Conover complies with FERPA requests received through the educational institutions using our Services.

IV. How We Protect Information

Conover Company cares about safeguarding the confidentiality of your Personal Information. We utilize administrative and electronic measures designed to appropriately protect your Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of any Personal Information in our possession. 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. 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. All transactions are processed through a gateway provider and are not stored or processed on our servers.

However, no security measures are perfect or impenetrable. We cannot guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards, subject to requirements under applicable law to ensure or warrant information security. By using our Services, you acknowledge that you understand and agree to assume these risks.

In the event of any breach of security, confidentiality, or integrity of your unencrypted electronically stored Personal Information, we will make any legally-required disclosures to you via email or conspicuous posting on our Site in the most expedient time possible and without unreasonable delay, consistent with the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system, and any other disclosures that may be required under applicable law. We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally 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.

We also take measures to delete your Personal Information or to store it in a form that does not permit identifying you when this information is no longer necessary for our processing purposes, unless we are required by law to keep this information for a longer period. When determining the retention period of your Personal Information, we consider various criteria, such as the type of products and services requested by or provided to you; the nature and length of our relationship with you; possible re-enrollment with our Services; the impact on the Services we provide to you if we delete some information from or about you; mandatory retention periods provided by law; and the statute of limitations.

V. Your Rights and Choices

A. Communications

You may opt out of receiving marketing communications and other commercial emails from us. To opt out, please follow the unsubscribe instructions provided in any of the communications or by sending your request to us by email at sales@conovercompany.com. Please be aware that, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Services.

B. Right to Personal Information

You have the right to request access and receive information about the Personal Information we maintain about you; to update and correct inaccuracies in your Personal Information; to have the information blocked, anonymized or deleted, as appropriate; or to exercise your right to data portability to transfer your Personal Information to another company.

C. Processing of Personal Information

Where required by law, we obtain your consent for the processing of certain Personal Information collected by cookies or similar technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

D. Exercising Your Rights

To update your preferences, ask us to remove your information from our mailing lists, delete your account, or submit a request to exercise your rights to your Personal Information, please contact us as specified in the “Contact Us” section below.

When we receive a verified request to delete your Personal Information, we will delete your Personal Information. Our ability to delete your Personal Information may be limited in some circumstances by local law requirements.

Your rights may be limited in some circumstances by local law requirements.

VI. Changes to Our Privacy Policy

This Privacy Policy may be updated from time to time for any reason; each version will apply to information collected while it was in place. We will notify you of any modifications to our Privacy Policy by posting the new Privacy Policy on our Site and indicating the date of the latest revision. You are advised to consult this Privacy Policy regularly for any changes.

If the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Service after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of this Privacy Policy.
VII. Contact Us

If you have any questions or comments regarding this Privacy Policy, or if you would like to exercise your rights to your Personal Information, you may contact us using the information below.

4 Brookwood Court
Appleton, WI 54914
United States
sales@conovercompany.com

Effective Date: June 30, 2020