CPP Asia Pacific Privacy Policy

Version Date: 3 June 2014

This website is owned and operated by CPP Asia Pacific Pty Ltd (CPPAP, we, or us). We work diligently to protect the privacy, confidentiality and security of the Personal Information that we receive. This Privacy Policy describes the principles and practices that apply to the Personal Information (defined below) that we collect and hold from individuals online or offline (visitor or you), such as individuals who browse through our Site (defined below), register on the Site, use the services provided on the Site, interact with the Site, communicate with us through telephone, email, text or other means, participate in our interviews, surveys or promotions, or read or receive our newsletters.

This Privacy Policy is based on the following values:

  • We will take reasonable measures to protect the security of your Personal Information.

  • We will not disclose your Personal Information to third parties other than as described in this Privacy Policy.

  • In most circumstances, you will be able to view the Personal Information that we have about you, and to correct or modify it if it is inaccurate or incomplete.

Definitions

  1. In this Privacy Policy, the following terms are defined as set out in this section:

      1. Assessment means an instrument, questionnaire or series of tests that are completed by an Assessment Taker in view of the preparation of a Report or to provide information about, or to, an Assessment Taker, Customer or Test Administrator.

      2. Assessment Taker means an individual who takes, will take, or has taken, an Assessment.

      3. CPPAP Proprietary Methodology means CPPAP’s proprietary scoring methods and algorithms, together with the research, know-how and training that has been developed by, or for, CPPAP as pertaining to Products and Services licensed by CPPAP.

      4. Customer means an individual, business or other entity that purchases CPPAP’s Products or Services, including, without limitation: (a) an individual or business that purchases books or other materials sold by CPPAP; (b) an individual or business that purchases online Assessment services and Assessment Reports; (c) a Test Administrator (or employer of Test Administrator) who has a contractual relationship with CPPAP; and (d) an entity with which CPPAP has a contractual relationship to provide other Products or Services.

      5. Personal Information means any information, or an opinion about an identified individual, or an individual who is reasonably identifiable, whether that information is true or not and whether recorded in material form or not (except that, for New Zealand users, the word 'reasonably' is omitted from this definition). This includes, for example, name, email address, mailing address, telephone number, billing information, account information, and other information incidental to providing or receiving Products or Services. It also includes other information, such as IP address, device information or other Session Data that can reasonably be linked to an identified individual.

      6. Products or Services means the Products or Services promoted, sold or available for sale from the Site or through CPPAP personnel, such as the CPPAP online assessment centre (currently www.skillsone.com), the CPPAP MBTI® Form M Complete service, the iStartStrong service and the CPPAP books and materials.

      7. Report means an analysis of the scoring and responses provided in connection with an Assessment, that is either developed using the CPPAP Proprietary Methodology or is licensed by CPPAP, and which (i) a Test Administrator, using the CPPAP Proprietary Methodology, may interpret for an Assessment Taker during one or several feedback sessions or interpretation sessions; or (ii) a Customer may use in its business with the Assessment Taker.

      8. Session Data means, as applicable, usage information, such as IP address, unique identifier of an individual’s mobile device, the type of browser, type of operating system, referring URL, date, time and duration of a visitor’s visit, the number of visits to a Site, the pages viewed, order of pages viewed, time spent on a particular page, the number of cookies accumulated, bytes sent, bytes received, protocol version, user agent, method, URI stem, URI query, or MAC address.

      9. Site means any of the following websites (or any other websites that CPPAP may develop or have developed from time to time): www.cppasiapacific.com.

      10. Test Administrator means an individual who has been trained in the CPPAP Proprietary Methodology or otherwise qualified to review Assessments using the CPPAP Proprietary Methodology, and who administers Assessments to Assessment Takers, analyses the scores and Reports generated by CPPAP from these Assessments, interprets these scores and Reports using the CPPAP Proprietary Methodology, and, at the Test Administrator’s discretion, provides these scores and reports to Assessments Takers.

Consent

        1. By using the Site and/or submitting Personal Information to us, you consent to the practices described in this Privacy Policy and on the Site and agree that we may collect, use, disclose, store, transmit, or process such Personal Information in accordance with this Privacy Policy or as required by law.

        2. By providing your Personal Information to us, if you reside in Australia, you acknowledge and agree that:

            1. we may disclose your Personal Information (including for storage or processing) to recipients in other countries, including the United States, that may not have data protection laws that provide the same level of protection as those that exist in Australia;

            2. we will not be required to take reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to your Personal Information; and

            3. we will not be liable for any breaches of the Australian Privacy Principles by the recipient.

        3. By providing your Personal Information to us, if you reside in a country or territory (other than Australia) that restricts the transfer or disclosure of Personal Information out of that country or territory you agree that we may transfer or disclose your Personal Information (including for storage or processing) to recipients in other countries, including the United States, that may not have data protection laws that provide the same level of protection as those that exist in your country of residence.

        4. Children under 13 are not permitted to use the Site without their parents' or guardian’s consent. Should a child whom we know to be under 13 send Personal Information directly to us, we will use that information only to respond directly to that child to inform him/her that we must have parental consent before receiving his/her information. If we become aware that a child under 13 has provided us with Personal Information without the consent of the child’s parent or guardian, we will automatically remove such information from our files. If the parent or guardian of a minor becomes aware that his/her child has provided us with Personal Information without his/her consent, he/she should contact us as indicated in the Contact Us section (below).

        5. For New Zealand users, all references in the previous paragraph to a child under 13 are replaced by references to a child under 18.

Links to External Sites

  1. This Site may link to websites that are operated by third parties. These websites are not subject to this Privacy Policy. We recommend that you read the privacy statements that are posted on these third party websites to understand their procedures for collecting, using and disclosing Personal Information.

What Personal Information We Collect and How

  1. We collect only such Personal Information as is necessary to provide our Products or Services to you, inform you about our Products and Services, continue our research in the field, and improve our Site, Products or Services, and your experience interacting with CPPAP. In some cases, we ask questions to which the response is optional, and these questions are identified as such. You are free not to respond to these optional questions. If you do not respond to the optional questions, you may not be able to use all the features of the Site, Products and/or Services. We describe below the different ways in which we collect or obtain Personal Information.

  2. If you visit the Site – If you visit the Site, we automatically collect the related Session Data. Session Data is provided to us by your browser and through our log files, which record your activities while browsing our Site, such as when you click on a link. We may record some of this data in one or several cookies that we send to your browser.

  3. If you register or create an account – If you register or create an account on the Site, we require that you fill out a form to register as a purchaser or Customer (as applicable). We collect your name, contact information and other information, and may ask you for other optional information that helps us serve you better. If a potential Test Administrator creates an account, we collect additional information about the person’s practice, credentials and education, as necessary to assess the qualifications of the applicant to purchase Assessment services.

  4. If you purchase a Product or Service – If you purchase a Product or Service, we collect your contact information as necessary to fulfil the order (such as name, address, shipping information, email address or telephone number) and optional information if you provide it. If you purchase a Product or Service for delivery to, or use by, another person, we collect your Personal Information as the person initiating the purchase, as well as Personal Information about that other person (such as name, shipping address, telephone number or email address) as necessary to fulfil the order. By providing another person’s Personal Information, you represent that you have that person’s permission to do so.

  5. If you pay for a Product or Service online – When you make a purchase online, we do not collect payment information ourselves. Instead, you are redirected to our payment processor’s website, which collects directly your payment information. CPPAP only receives a notice of the receipt of the payment, a confirmation number (for verification purposes), the name and contact information of the recipient of the Product or Service, and the name and contact information of the cardholder if different from the name of the person receiving the Product or Service.

  6. If you pay for a Product or Service over the phone or by fax – If we take an order over the phone or by fax, we collect the payment information directly from the person placing the order, transfer it to the payment card processor, and, after receiving confirmation of the payment from the payment card processor, we retain this payment information in a secured location, with restricted access, and in accordance with our internal record retention policy.

  7. If you complete an Assessment – If an Assessment Taker completes an Assessment at the direction of a Customer (such as at the direction of an employer or Test Administrator), whether online or offline, we collect the Assessment Taker’s unique identifier, the name the Assessment Taker provides to us and in some cases, the Assessment Taker’s gender. The Assessment Taker also has the option to provide demographic information such as highest level of education attained or occupation. We collect the responses provided to the questions in the Assessment.

  8. If an Assessment Taker completes an Assessment on his or her own initiative (i.e., outside the scope of a relationship with a Customer) using our online service, we collect the Assessment Taker’s contact information, and in some cases, gender. The Assessment Taker also has the option to provide demographic information such as highest level of education attained or occupation. We collect the response provided to the questions in the Assessment. In this case, we know the identity of the Test Taker and that of the person who paid for the Assessment, if applicable.

  9. If you participate in a survey – If you choose to participate in one of our surveys, we may collect Personal Information such as your name, email address (to avoid duplicate responses), as well as any other Personal Information that you may provide in your survey responses.

  10. If you sign up to receive a CPPAP newsletter and/or other marketing collateral – If you sign up to receive a CPPAP newsletter and/or other marketing collateral , we may collect information on the open rate of the newsletter, and whether a specific individual has clicked on a link contained in a particular issue of our newsletter.

  11. If you are a Customer or other business contact – If you are a Customer or other business contact, or if you are an employee or agent of a Customer or business contact, we may collect your email address, telephone, contact information and correspondence in the regular course of our interaction with you.

  12. If you participate in our blogs or forums, or if you write to us – We may collect the Personal Information that you provide in your correspondence and communications with us, or through your participation in surveys, blogs and forums.

  13. If you interact with third parties regarding our Products or Services – We may receive Personal Information about you from third parties, such as from Customers, CPPAP distributors, Test Administrators, Test Administrators’ employers, websites where we advertise, business partners and service providers. Some of this information pertains to a specific individual; other information can only be linked to an access point or a device.

  14. If you become certified or qualified in our Products or Services – If you become certified or otherwise qualified in one or more of our Products or Services, we collect information regarding the details of your certification or qualification, such as your name, the instruments in which you are certified/qualified, the date of your certification/qualification, and the current status of your certification/qualification.

How we use personal information

    1. We use Personal Information in order to provide and enhance the Products or Services that we offer, as explained below:

        1. To facilitate the use of the Site – We may use the Session Data to ease navigation through the Site, to enhance navigation (such as to determine the language of the country where the visitor is located), keep track of the shopping cart or keep track of login name and password in order to avoid requesting identity information when the visitor moves from page to page, and in general, to enhance the quality of our Site and the content provided on the Site.

        2. In connection with Assessments – We use the responses to an Assessment to score the Assessment and prepare the related Report about the Assessment Taker. The Report is delivered to our Customer. We retain a copy of your responses and the related Report in accordance with our record retention policy.

        3. To provide our Products or Services – The Personal Information collected from purchase order forms is used to send orders to our Customers. The limited payment information that we receive from our payment processors is used to verify that a Product or Service has been paid for. If you purchase a Product or Service in relation to which we act as an agent for a third party, we will send the information you provide to us to that third party. The third parties for whom we act as agent are not subject to this Privacy Policy. We recommend that you read the privacy policies and statements that are posted on the relevant third parties' websites to understand their procedures for collecting, using, storing and disclosing Personal Information.

        4. For research purposes – We may use aggregated Session Data to better understand how our Site is navigated, how many visitors arrive at specific pages, which pages or content attract more viewers, the length and frequency of stays at our Site, the different types of searches of our Site content and databases, the types of browsers and computer operating systems that our visitors use, and the IP addresses from which visitors connect to our Site, in order to improve our Site and enhance our content.

        5. We may use IP addresses to gather broad demographic information – This information is not associated with any individual and is therefore anonymous. The IP addresses are then disposed of in accordance with our record retention policy.

        6. For maintenance purposes – We may use IP addresses and session data to diagnose problems with our server and to administer our Site.

        7. For marketing purposes – We may use email addresses or other contact information to send mailings, newsletters and other marketing collateral regarding product information and releases. We may use your telephone number to contact you for marketing purposes. We may use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of the communications that we send.

        8. For survey analysis – The information that we collect through our surveys (including surveys administered by our related companies and other publishers) is not used other than to garner survey results and statistical analysis.

To Whom We Disclose Personal Information

        1. From time to time, we may disclose Personal Information to someone other than the individual who provided this information, as follows:

            1. Assessments Reports – CPPAP provides its Customers with the information that they need to properly counsel or advise their clients, customers, and employees, as applicable. If you are taking an Assessment at the direction of one of our Customers, that Customer will receive from CPPAP a Report on the Assessment that you took, so that he or she may properly counsel or advise you or provide you with other services.

            2. The public – If you are or become certified or qualified as a Test Administrator for our Products or Services, we may share information regarding your certification, such as your name, the instruments in which you are certified/qualified, the date of your certification/qualification, its scope, and the current status of your certification/qualification, with the public, and you hereby authorise us to do so.

            3. Foreign distributors – CPPAP may provide its distributors in foreign markets (including in People’s Republic of China, Hong Kong, India, Philippines, Singapore, Taiwan and Thailand) ) with a list of Customers (including name and contact information) or prospective Customers residing in that distributor’s CPPAP-approved area of distribution. CPPAP will do so only when it reasonably believes that providing such information will permit it to improve the service to CPPAP Customers or prospective Customers in that distributor’s area, and only when the distributor’s use of such information is in accordance with CPPAP’s privacy policies in general.

            4. Publishers – CPPAP may provide information about you to the publisher of psychological instruments if you purchase those instruments from us or undertake certification or other training from us in relation to those instruments.

            5. CPPAP Sites – We may combine the information that we collect from different CPPAP Sites to supplement an individual’s profile, for example, to combine the records of different purchases or different activities made or conducted from different CPPAP Sites.

            6. Public forums – CPPAP may offer publicly accessible blogs or community forums. Any Personal Information that you provide on these blogs or forums may be read, collected and used by others who access them.

            7. Service providers – We may engage certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, shipment, order fulfilment, payment credit card processing, mass mailing, hosting and maintenance, database storage and management, business analytics, fraud prevention, direct marketing campaigns and survey administration. Some of those service providers may be located overseas (including in the United States or Asia).

            8. To defend or enforce our rights – CPPAP may use Personal Information to protect itself or to protect the Site, to respond to a breach of its terms and conditions, to prevent fraudulent activity, or where it is necessary to pursue available remedies. If a Customer neglects to pay amounts due and owing to CPPAP, CPPAP may send that CPPAP customer’s name, contact information, and account information to a third party service provider for collection of overdue payments.

            9. Co-marketing – We may collaborate with other companies to offer you additional products or services (eg, book publishers). We will share Personal Information that is necessary for these other companies to provide the products or services that you have requested. This Privacy Policy does not cover the use of your Personal Information by these companies. We encourage you to read a company’s privacy policy before requesting any of its products or services.

            10. Related companies – We may disclose any Personal Information we collect to our related companies or may store or process Personal Information using systems which are shared with our related companies. Our related companies may be located overseas, including in the United States.

            11. Merger, acquisition or bankruptcy – If any or all of the CPPAP assets are acquired by, or merged with those of another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all of our users’ Personal Information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing services to our users. If the recipient of the Personal Information has personal information practices that do not meet the substance of this Privacy Policy, you will be given the opportunity to exercise your rights with respect to your Personal Information.

            12. Law enforcement and litigation – Certain federal, state, local, overseas or other government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information: (i) if we believe in good faith that a law, regulation, rule or guideline requires it; (ii) to a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person; or (iii in other circumstances where we are permitted to do so by law.

            13. Aggregated data – Other than as stated above, if CPPAP provides a third party with Personal Information, it will be in the form of aggregated data and used for product development, research or statistical analysis. Aggregated data is created from records that are stripped of all personal identifiers, such as a combination of thousands of answers to survey questions and instrument responses.

Cookies and other tracking technologies

  1. A cookie is a small text file that a website sends to a visitor’s browser and that sends back information each time the visitor makes a request from the website. A cookie contains a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. Cookies can be accepted, rejected or identified by configuring your browser’s preferences. Pixel tags or clear gifs are tiny graphics with a unique identifier that are embedded invisibly on a webpage and are used to track a visitor’s movements on a website. We do not tie the information gathered by clear gifs to Personal Information. You can learn more about cookies by visiting www.allaboutcookies.org or http://networkadvertising.org.

  2. Cookies and pixel tags are used to help recognise a returning visitor, and to help customise the visitor’s online experience. Unless a visitor specifically informs us of his/her identity (eg, by registering with us), we will not know who the individual visitor is. The Site uses cookies as follows:

  3. Our third party advertising partners may employ pixel tags that help us better manage content on our Site by informing us what content is effective.

How We Retain Personal Information

  1. We retain scored item responses and the related Report associated with the user ID or transaction number that our Customers provided us in accordance with our internal record retention policy and for at least two (2) years from the date when an Assessment Taker undertook an Assessment. Thereafter, we retain the scored item responses and Report in an anonymised format for as long as the information is needed for our research, statistical analysis or product development.

  2. CPPAP will not be able to identify an individual from the records who is identified only with a transaction number provided by our Customer, because CPPAP does not have access to the information in the Customer’s custody that would allow identifying the individual who completed a particular Assessment.

How We Protect Personal Information

  1. Security – We follow generally accepted industry standards to protect Personal Information, during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect it from unauthorised access, loss, misuse, disclosure, alteration or destruction.

  2. Transit – When we need to transfer information out of our firewall, we use industry-standard technological means to protect Personal Information while in transit through the internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. However, no method of transmission over the Internet or method of electronic storage is fully secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we can never guarantee its absolute security.

  3. Identity theft – Identity theft and the practice currently known as 'phishing' are of great concern to us. For more information about protecting yourself from these practices, you can visit http://www.ftc.gov/bcp/edu/pubs/consumer/alerts/alt127.shtm. Please understand that you also have a responsibility in protecting your information. The only time when a CPPAP associate may contact you (via electronic communication, postal mail, telephone, etc.) about your credit card or payment information is in connection with a transaction that you have initiated. Otherwise, no one from CPPAP is permitted to contact anyone to request your credit card information, national identification number, or other identifier or sensitive information in a non-secure or unsolicited email or telephone communication.

Data Accuracy

  1. We will 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. Please notify us of changes to information that you have previously provided by contacting us as indicated in the Contact Us section (below).

Your rights

  1. Right of access, modification – In general, you have the right to access your Personal Information and to correct or update the Personal Information that you have provided to CPPAP. If you wish to do so, please contact us with proof of identity, as provided in the Contact Us section (below). You can expect a response to your request within 20 business days.

  2. If you are an Assessment Taker and you wish to have access to a copy of your responses to an Assessment or a copy of the Assessment Report that CPPAP prepared from the evaluation of your responses, please contact the Test Administrator who is managing your specific Assessment.

  3. If you wish to have access to the Assessment Report that CPPAP prepared about a third party, for example, if you paid for a third party to take an Assessment, please contact the Test Administrator who is managing the specific Assessment.

  4. Right of deletion – If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us with proof of identity, as provided in the Contact Us section (below). We will accommodate your request to the extent practicable, and to the extent that it does not otherwise conflict any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

  5. Right to opt-out of the use of your Personal Information – You may unsubscribe from receiving a newsletter by contacting us as set out in the Contact Us section (below) or clicking on the unsubscribe link provided in the newsletter.

  6. If you wish to opt-out of direct marketing communications you can always do so by contacting us as set out in the Contact Us section (below). In some cases, we may not be able to remove your Personal Information, in which case we will let you know this and explain why.

  7. Right to Block Cookies – You have the right to block cookies and pixel tags. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or prompt you before accepting a cookie from the Site that you visit. If you decide not to accept our cookies, you will be able to access those parts of our Site that are available to the general public, but you will not be able to access most of our Products or Services.

Complaints and Disputes

  1. If you have questions or complaints regarding our privacy policy or practices, you should first contact the Legal Department of CPPAP as indicated in the Contact Us section (below). We will respond to you within a reasonable period of time and will attempt to resolve all complaints promptly.

  2. If we are unable to satisfactorily resolve your concerns about the privacy or handling of your Personal Information, you can contact the Office of the Australian Information Commissioner (OAIC). To make a query concerning your privacy rights, or to lodge a complaint with the OAIC about how we have handled your personal information, you can contact the Commissioner's hotline on 1300 363 992. The OAIC has the power to investigate the matter and make a determination.

  3. In New Zealand, you can contact the Office of the Privacy Commissioner. To make a query concerning your privacy rights, or to lodge a complaint with the Privacy Commissioner about how we have handled your personal information, you can contact the Commissioner's enquiries line on 0800 803 909. The Commissioner has the power to investigate the matter and make a determination.

Changes to this Privacy Policy

We may from time to time change this Privacy Policy. If we make material changes, we will place a prominent notice on the Site or will send you a notice to the email address that you provided to us.

Contact us

If you have any questions or complaints about (i) this Privacy Policy, (ii) the collection, use, management, or disclosure of your Personal Information, or (iii) accessing or modifying your Personal Information please contact us as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them.

                          • By email:
                          • enquiries@cppasiapacific.com
                        •  

                          • By phone:
                          • (03) 9342 1300 (Australian customers)
                            0800 000 159 (New Zealand customers)
                            1800 1 611 0298 (Philippines customers)
                        •  

                          • By mail:
                          • Managing Director
                            CPP Asia Pacific Pty Ltd
                            Level 7, 369 Royal Parade (PO Box 810)
                            Parkville, Victoria, 3052 Australia