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FRANKLINCOVEY CO. PRIVACY POLICY




INTRODUCTION



Franklin Covey respects your privacy and is committed to protecting your
personal data. This privacy notice describes how your personal data is
collected, handled, and stored to meet Franklin Covey's protection standards—and
to comply with the law.




PURPOSE OF THIS PRIVACY NOTICE



This privacy notice describes how Franklin Covey collects and processes your
personal data through your use of this website and the services on it, including
any data you may provide.

This website is not intended to be used by children; Franklin Covey does not
knowingly collect personally identifiable information from children.

It is important that you read this privacy notice, together with any other
privacy notice or fair-processing notice provided when personal data is
collected or processed, so that you are fully aware of how your data is used.
This privacy notice is supplemental to any other notice, and is not intended to
override.





CONTROLLER



Franklin Covey is comprised of several different legal entities, details of
which are available at https://www.FranklinCovey.com/About/global-offices.html.
This privacy notice is issued on behalf of Franklin Covey Co. Reference to
“Franklin Covey,” “we,” “us,” or “our” in this privacy notice implies Franklin
Covey Co., who is responsible for processing your data. Unless otherwise stated,
Franklin Covey Co. (Franklin Covey) is the controller of this website.

Franklin Covey's data-privacy manager will respond to questions regarding this
privacy notice. If you have any questions about this privacy notice, including
any requests to exercise your legal rights, please contact the data-privacy
manager using the details provided:





CONTACT INFORMATION



Legal Entity: Franklin Covey Co. Data Privacy Manager: Blaine Carter
Email Address: privacy@FranklinCovey.com
Postal Address: 2200 W. Parkway Blvd., Salt Lake City, UT 84119, United States

The contact for our EU representative:
Legal Entity: FRANKLIN COVEY LEADERSHIP LIMITED
Data Privacy Manager: Stephen Asker
Email Address: privacy@FranklinCoveyeurope.com
Postal Address: 10 Earlsfort Terrace, Dublin 2, Dublin, D02t380, Ireland

You have the right to file a complaint at any time with the Information
Commissioner's Office (ICO), the supervisory authority for data-protection
issues. However, we would appreciate the opportunity to resolve your concerns
before you approach the ICO, so please consider contacting us first.





CHANGES TO THE PRIVACY NOTICE AND REQUEST FOR CURRENT DATA



This privacy notice was last updated November 4, 2021.

It is important that the personal data we hold about you is accurate and
current. Please notify us of any changes to your personal information during
your relationship with us.





THIRD-PARTY LINKS



This website may include links to third-party websites, plug-ins, and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of any
website you visit.




2. DATA COLLECTION



Personal data or information means any information about an individual from
which that person can be identified. It does not include data where identity is
removed (anonymous data).
We may collect, use, store, and transfer a variety of personal data, including:
Identity data, including first name, last name, username, or similar identifier,
title, date of birth, or gender.
Contact data, including email address and telephone numbers.
Technical data, including Internet protocol (IP) address, your login data,
browser type and version, time zone and location, browser plug-in types and
versions, operating system and platform, and other technology on the devices you
use to access this website and our services.
Profile data, including your username and password, preferences, feedback, and
survey responses.
Usage data, including information on how you use our website and services.
We also collect, use, and share aggregated data, such as statistical or
demographic data, for any purpose. Aggregated data may be derived from your
personal data, but is not considered personal data by law, as this data does not
reveal your identity, either directly or indirectly. For example, we may
aggregate your usage data to calculate the percentage of users accessing a
specific website feature; however, if combining aggregated data with your
personal data directly or indirectly identifies you, we treat the combined data
as personal data, and subject to the terms of this privacy notice.





FAILURE TO PROVIDE PERSONAL DATA



Where collection of personal data is required by law or under the terms of a
contract with you or your employer on your behalf, failure on your part to
provide the requested data may impede the performance of the contract. You will
be notified if cancellation of the contracted service is necessary in such a
situation.




3. PERSONAL DATA COLLECTION




Data is collected through various methods, including:
Direction interaction, including personal identity and contact data entered to
complete a form, or in correspondence via post, phone, email, or otherwise.
Included is personal data provided when you:



 * Create an account or make a purchase on our website.
 * Subscribe to our service.
 * Provide feedback.


Automated technologies or interactions, including technical data about your
equipment, browsing actions, and patterns. Personal data is collected using
cookies, server logs, and other similar technologies. Collected information is
used to help diagnose problems with our server and administer our website, and
allows us to deliver content tailored to your interests. We may also receive
technical data about you when you visit other websites using our cookies.

Third parties or publicly available sources, including personal data (identity,
contact, and profile data) supplied by you or your employer to enable us to
provide services via our website.






4. USING YOUR PERSONAL DATA




Use of your personal data is limited by law. Most commonly, personal data is
used:



 * To allow us to fulfil a contract entered into with you or your employer.
 * Where it is necessary for our legitimate interests (or those of a third
   party) if your interests and fundamental rights do not override those
   interests.
 * To comply with legal or regulatory obligations. To learn more, click
   https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en
 * Generally speaking, we do not rely on your consent as a legal basis to
   process your personal data, except in sending direct-marketing communications
   via email or text message. You may withdraw consent to receive these
   marketing messages at any time by contacting us at privacy@FranklinCovey.com.
 * Your personal data may be processed for more than one lawful ground,
   depending on the specific purpose for its use. Please contact us at
   privacy@FranklinCovey.com if you require additional information.






COOKIES



Your preferred browser can be set to refuse all or some browser cookies, or to
alert you when websites set or access cookies. If cookies are disabled or
refused, some parts of the website may be inaccessible or fail to function
properly.
The Franklin Covey application uses Cookies to authenticate users, review site
usage, performance monitoring and site security. Your personal information is
never shared or sold. Cookies are used to ensure the application works as
designed and to provide reports to the site administrator at your company to
gain analytics.




CHANGE OF PURPOSE



Personal data is collected and used for a specific purpose, unless we determine
its use for another reason as being compatible. Please contact us at
privacy@FranklinCovey.com to receive an explanation of how processing for
another purpose meets that criteria. If your personal data must be used for an
unrelated purpose, we will notify you and explain the legal basis that allows
its use. We may process your personal data without your knowledge or consent, in
compliance with the rules stated above, where required or permitted by law.




5. DISCLOSURE OF PERSONAL DATA




We may be required to share personal data with the parties listed below for the
purposes identified in the points provided in “4. Using Your Personal Data”
above.

Internal third parties as defined in the Glossary.

 * Third parties to whom we may choose to sell, transfer, or merge part of our
   business or assets. Alternatively, we may seek to acquire other businesses or
   merge with them. If a change to our business occurs, new owners may use
   personal data in the same manner as set out in this privacy notice.


We require all third parties to respect the security of your personal data and
treat it in accordance with the law. Third-party service providers are not
allowed to use your personal data for their own purposes. Use of personal data
is permitted only for specified purposes and must be in accordance with our
instructions.
We do not sell your personal information within the meaning of the California
Consumer Privacy Act (CCPA).







6. INTERNATIONAL TRANSFERS



We share your personal data within the Franklin Covey Group, requiring the
transfer of your data outside the European Economic Area (EEA). Additionally,
many of our external third parties are located outside the EEA, again requiring
the transfer of your personal data to allow processing.

Whenever your personal data is transferred outside of the European Economic
Area, we ensure a similar degree of protection is implemented using at least one
of the following safeguards:

Transfer is allowed only to countries sanctioned by the European Commission to
provide an adequate level of protection for personal data.



 * Where certain service providers are used, specific contracts provided by the
   European Commission may be used to ensure personal data will have the same
   protection as in Europe. For further details, see European Commission: Model
   Contracts for the transfer of personal data to third parties.


Please contact us at privacy@FranklinCovey.com if you require additional
information about our process for transferring your personal data outside the
EEA.






7. DATA SECURITY



Appropriate security measures are in place to prevent personal data from
accidental loss, misuse, alteration, or unauthorized disclosure. Additionally,
access to personal data is limited to those employees, agents, contractors, and
third parties who are authorized to process the data on our behalf, under
specific instruction and subject to a duty of confidentiality.
Procedures are in place to deal with any suspected personal data breach. You,
and if legally required, any applicable regulator, will be notified of a breach.




8. DATA RETENTION




Your personal data will be retained only as long as necessary to fulfill the
purpose(s) for which it was collected, including legal, accounting, or reporting
requirements.

To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm
from unauthorized use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal requirements.

Law requires that we keep basic information about our customers (including
contact, identity, and transaction data) for six years following the last use of
the website and/or services for liability and tax purposes.

In some circumstances, you may ask us to delete your data. Email your request to
privacy@FranklinCovey.com.

We may anonymize personal data (to remove any association with personal
identity) for research or statistical purposes, in which case the information
may be used for an indefinite period without further notice to you.




9. YOUR LEGAL RIGHTS




Under certain circumstances, you have rights relating to your personal data
under the General Data Protection Regulation (GDPR) as well as the California
Consumer Privacy Act (CCPA). Click on the following links to find out more about
these rights:
https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en
https://oag.ca.gov/privacy/ccpa

If you choose to exercise any of the rights contained in GDPR or CCPA, please
contact us at privacy@FranklinCovey.com or by calling 1-888-868-1776 in the
United States. These rights are subject to certain exceptions and exclusions,
and we may be unable to comply in full with your request.
California consumers may designate an authorized agent to exercise their rights
on their behalf. If you would like to use an authorized agent registered with
the California Secretary of State to exercise these rights, we may request
evidence that you have provided such agent with power of attorney or that the
agent otherwise has valid written authority to submit requests on your behalf.
We will not discriminate against you if you choose to exercise your rights.





FEES



You are not required to pay a fee to access your personal data (or to exercise
any of your other rights). However, we may charge a reasonable fee if your
request is clearly unfounded, repetitive, or excessive. Alternatively, we may
refuse to comply with your request in these circumstances.




REQUEST FOR SPECIFIC INFORMATION



We may request specific information from you to help us confirm your identity
and ensure your right to access your personal data (or to exercise any of your
other rights). This security measure ensures that personal data is not disclosed
to an unauthorized person. We may also contact you to ask for additional
information to speed up our response.




RESPONSE TIME



We try to respond to all legitimate requests within one month. Occasionally, it
may take us longer if your request is particularly complex. In this case, we
will notify you and keep you informed.




10. GLOSSARY




Legitimate Interest means the interest of our business in conducting and
managing our business to enable us to give you the best service/product and the
best and most secure experience. We make sure we consider and balance any
potential impact on you (either positive or negative) and your rights before we
process your personal data for our legitimate interests. We do not use your
personal data for activities where our interests are overridden by the impact on
you unless we have your consent or are otherwise required or permitted to by
law. You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect to specific activities
by contacting us at privacy@FranklinCovey.com.

Performance of Contract means processing your data where necessary for the
performance of a contract to which you are a party, or to take steps at your
request before entering into such a contract.

Comply With a Legal or Regulatory Obligation means processing your personal data
where necessary for compliance with a legal or regulatory obligation.

Internal Third Parties are other companies in the Franklin Covey Group acting as
joint controllers or processors, and who are based in countries around the
world. A list of internal third parties is available here:
https://www.FranklinCovey.com/About/global-offices.html, and provides IT and
system-administration services.


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