Last Updated: June 18, 2020

Chronus LLC and its affiliates (“we” or “our”) partner with companies and organizations (collectively “Organizations”) to provide mentoring software on the Chronus mentoring platform (the “Services”) to individual users (“you”) at the instruction of their Organizations.

At Chronus, we value your privacy. This Privacy Notice (“Notice”) sets out how your personal information may be collected or used by us in order to provide the Services. We recognize that privacy is an ongoing responsibility, and as such, we may update this Notice from time to time as we undertake new privacy practices.

The Services may include links, integrations or references to non-Chronus websites, services, materials, or entities (collectively “Third-Party Services”). This Privacy Notice does not apply to Third-Party Services. Third-Party Services are subject to their own privacy policies and you are encouraged to review such policies prior to use of any Third-Party Services.

Role of Chronus: With respect to the Services, Chronus is a “data processor” or “service provider” under applicable privacy laws. This means that when you use our Services, we are processing (using) your personal information at the instruction of your Organization, who determines the means and purposes of processing your personal information as the “data controller” or “business”. This Notice sets out our standard privacy practices for the Services. As the “data controller”, your Organization may instruct us to treat your personal information differently than described in this general Notice. Please reach out to your Organization for more information.

How we Process your Personal Information: We collect your personal information from your Organization or directly from you. In order to provide the Services to you, we generally collect personal identifiers (such as your name, email and IP address) along with any additional personal information requested by your Organization or voluntarily provided by you or your Organization. We may also “passively” collect your personal information using various technologies, such as cookies, web beacons, and navigational data collection (clickstream, log files, server logs, etc.). We will only process your personal information for the purposes of providing you with the Services (including for the purposes of building, improving and securing our Services), or as otherwise instructed by you, your Organization or as required by applicable law.

We do not sell your personal information to anyone and only share it with those third parties who are facilitating the provision and support of the Services on our behalf (“subprocessor(s)”) or as otherwise requested by you. We require our subprocessors to comply with all laws applicable to the security and processing of your personal information. We may also disclose your personal information to governmental agencies and other third parties when required to do so by law. Unless otherwise instructed by your Organization, we (including our subprocessors) may process your personal information globally. Similarly, we (including our subprocessors) may transfer your personal information from the EEA to another country outside the EEA. We will comply with all applicable law relating to the processing and international transfer of personal information.

Security and Data Retention: To help protect the privacy of your personal information, we maintain appropriate and industry standard physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your personal information. Where required by applicable law, we keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain your personal information depends on the purposes for which we collected and used your personal information and/or the laws applicable to your personal information.

COPPA Requirements: We do not direct or knowingly advertise the Services to individuals under the age of thirteen.

Data Subject Requests, Questions and Complaints: You may have additional “data subject rights” under applicable laws (such rights may include, but are not limited to, the right to access and rectify your personal information, the right to request additional details about how we use your information, the right to request that we delete, make portable or stop processing your personal information, the right to contact your data protection supervisory authority and the right not to receive discriminatory treatment from us based on your election to to exercise your applicable data subject rights). Your Organization is responsible for exercising these rights (should they apply). Please contact your Organization if you wish to learn more.

If you have any other questions or concerns related to how your Organization is processing your personal information, please contact your Organization. If you have questions or concerns related to how we at Chronus process your personal information, please contact us at: legal@chronus.com