This Privacy Notice applies to the WorkRamp Learning Cloud training portal, available online and via mobile application (the “Portal”). It describes how WorkRamp, Inc. (“WorkRamp”, “we”, “us”) collects, stores, uses and discloses the following categories of personal data:
We process such Customer Data on behalf of and under the instruction of the respective Customer, in accordance with our Data Processing Addendum. Accordingly, this Privacy Notice (which describes WorkRamp’s own privacy and data processing practices as we process data independently) does not apply to such processing done on our Customers’ behalf.
Specifically, this Privacy Notice describes our practices regarding:
If you are a User or Prospect (“you”), please read this Privacy Notice carefully and make sure that you fully understand it. You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our “Service Providers” (defined below under Section 5), please avoid any interaction with us including visiting our Sites or using our Services. If you are a User of the Services on behalf of any of our Customers, we suggest that you contact the respective Customer and your account administrator with any questions related to their privacy and data-handling practices.
When we use the term “personal data” or “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Types of personal data collected. WorkRamp collects and generates the following types of personal data:
For the purposes of the California Consumer Privacy Act (“CCPA“), in the last twelve (12) months, we have collected the following categories of personal information: Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Customer Records Information and Geolocation Information. We do not use or disclose sensitive personal information as defined in the CCPA.
Categories of sources from which personal data is collected. We collect personal data from the following sources:
We use personal data for the following purposes, in reliance on the following lawful bases for processing:
| Purpose | Lawful basis for processing |
| To facilitate, operate, enhance, and provide our Services. |
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| To provide our Customers and Users with assistance and support, to test and monitor the Services, or diagnose or fix bugs or other issues. |
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| To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localized and personalized experiences. |
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| To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. |
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| To facilitate, sponsor and offer certain events, contests and promotions. |
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| To gain a better understanding on how individuals use and interact with our Services, which content they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using the Services, so we may continue improving our products, offerings and the overall performance of our Services, including the use of Artificial Intelligence and Machine Learning capabilities for the purpose of optimization. |
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| To contact our Customers, Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them. |
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| To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity. |
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| To authenticate the identity of our Users and allow them to access and use the Services.
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we and our Service Providers may use to provide and improve our respective services, or for any other purpose. |
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| To enforce our Terms, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties. |
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| To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards. |
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If you reside or are using the Services in a territory governed by privacy laws under which “Consent” is the only or most appropriate lawful basis for the processing of personal data, your acceptance of our Terms and this Privacy Notice will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Notice, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at support@workramp.com.
We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States and the European Union as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, WorkRamp is committed to protecting personal data in accordance with this Privacy Notice and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
Please note that where WorkRamp processes personal data on behalf of a Customer, such personal data may only be processed in accordance with, and in the locations as agreed in our Data Processing Addendum and in any other commercial agreements with such Customer.
WorkRamp, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce and will be further liable in cases of onward transfers of your personal data to third parties (including our Service Providers).
WorkRamp, Inc. has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF.
WorkRamp, Inc. has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF.
If there is any conflict between the terms in this policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern for personal data transferred under the DPF. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
We retain User and Prospect Data for as long as we deem it reasonably necessary to establish, maintain and expand upon our relationship with you and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to maintain evidence of our relationship, should any legal issues arise following your discontinuance of our Services).
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 any other applicable legal requirements.
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it, or if that is not possible due to technical reasons (e.g. storage in archival back-up systems), securely store the personal data and isolate it from further processing until deletion is possible.
We retain Customer Data in accordance with our Customers’ instructions, provided through the Data Processing Addendum they enter into with WorkRamp or other commercial agreement we have with them. If you have any questions regarding the retention of Customer Data, please contact the respective administrator managing your account.
We disclose personal data in the following ways:
Service Providers: We engage third-party companies and individuals to perform services on our behalf or that are complementary to our Services, in order to support our business. Such service providers include website hosting and server co-location services, communications and content delivery networks (CDNs), data security services, website chat, call and video conference providers, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have limited access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data for restricted purposes as determined in our agreements with them.
Partnerships: We engage selected business partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our Customers, Users and Prospects. In such instances, we may disclose relevant contact, business and usage details with the respective partner, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any of our partners, please note that any aspect of that engagement which is not directly related to the Services and directed by WorkRamp is beyond the scope of WorkRamp’s Terms and this Privacy Notice and may therefore be covered by the partner’s terms and privacy notice instead.
Event Sponsors: If you attend an event or webinar organized by us or a conference in which we are also in attendance, or if you download or access a related asset on our Sites, webinar or other activity involving third-party sponsors or presenters, we may disclose your personal data to them. You may consent to such disclosure via the registration form or by allowing your attendee badge to be scanned at a sponsor booth, depending on the jurisdiction and the applicable law. In these circumstances, your personal data will be subject to the sponsor’s privacy policies. If you do not wish for your personal data to be disclosed, you may choose not to opt in via event/webinar registration, elect not to have your badge scanned, or you can opt out in accordance with Section 9 below.
Business Customers & Account Administrators: Our Customers have access to any personal data we process on their behalf in our capacity as a “processor” (under the EU GDPR or UK GDPR) or a “service provider” (under the CCPA and other similar laws). Accordingly, account administrators and others authorized by our Customer have access to personal data associated with the WorkRamp account(s) controlled by them.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data in response to a subpoena, search warrant or court order (or a similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Protecting Rights and Safety: We may disclose personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of WorkRamp, any of our Users, Prospects or Customers, or any members of the general public.
WorkRamp Affiliated Companies: We may disclose personal data for the purposes described in this Privacy Notice. Additionally, should WorkRamp or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition, or purchase of substantially all or part of its assets, personal data may be disclosed or transferred to the parties involved in such an event. We may disclose personal data to a third-party during negotiation of, in connection with, or as an asset in, such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.
Additional Disclosure: For the avoidance of doubt, we may disclose personal data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer or disclose non-personal and non-identifiable data at our sole discretion and without the need for further approval.
For the purposes of the CCPA, in the past twelve (12) months, we may have disclosed Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Customer Records Information; and Geolocation Information to the third parties listed above.
We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may disclose non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Portal. We may use this type of cookie and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.
While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
Google Analytics. We use Google Analytics – a web analytics tool which helps us understand Users’ behavior on our Sites, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of Google Analytics is available at: www.google.com/policies/privacy/partners/. Further information about your option to opt-out of Google Analytics is available at: https://tools.google.com/dlpage/gaoptout.
HubSpot. We also use HubSpot – an analytics and marketing tool to help us provide Users with relevant content and in order to improve the Site. Data is collected through cookies as well as information you provide to us. For more information about HubSpot services please visit: https://knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser.
Please note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
We engage in service and promotional communications, through e-mail and notifications.
Service Communications: We may contact you with service-related information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. You may be able to control your communications and notifications by following the instructions included in the communications sent to you (if any). Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through marketing campaigns on our Sites and Portal.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to support@workramp.com, or by following the “unsubscribe”, “stop”, “opt-out” or “update your e-mail preferences” instructions contained in the promotional communications you receive.
In order to protect your personal data that we hold, we use industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 5 above. Please contact us if you have any additional questions.
Individuals have rights concerning their personal data. Please contact us by e-mail at support@workramp.com if you wish to exercise your privacy rights under applicable law, including the EU GDPR, UK GDPR, the Swiss Federal Act on Data Protection (FADP), the CCPA, the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA) and other similar US State Laws, if applicable.
Such rights may include the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with us, to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) – each to the extent applicable under the relevant laws applicable to you. You may also have a right to lodge a complaint with a competent data protection authority, such as the supervisory authority in the EU Member State of your habitual residence, place of work, or of the alleged GDPR infringement, the UK’s Information Commissioner’s Office, or your State’s Attorney General (as applicable).
You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.
Please note that when you ask us to exercise any of your privacy rights, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure of personal data related to others, and to obtain further information that will allow us to better understand the nature and scope of the data subject to your request. If your request relates to personal data contained in Customer Data (i.e., personal data we process on our Customer’s behalf as its “data processor” or “service provider;” detailed further in Section 10 below), please note that such Customer exclusively determines how this data may be processed, as well as if and how your request should be handled. We therefore advise that you submit your request directly to the relevant Customer. Where feasible and reasonable, we may share such requests directed to us to the relevant Customer.
We may redact from the data we make available to you any personal data or confidential information related to others.
In compliance with the EU-U.S. DPF, the UK Extension of the EU-U.S. DPP, and the Swiss-U.S. DPF Principles, we commit to resolving complaints about our collection and/or use of your personal information. EEA, UK and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework compliance should submit inquiries to support@workramp.com. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit JAMS for more information and/or to file a complaint.
Please note that under certain conditions (as described under the DPF Principles that WorkRamp, Inc. adheres to), you can invoke a binding arbitration by delivering a notice to us via support@workramp.com. Please also note that WorkRamp, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA typically distinguish between two main roles for parties processing personal data: the “data controller” (or “business” under the CCPA), who determines the purposes and means of processing; and the “data processor” (or “service provider” under the CCPA), who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
WorkRamp is the “data controller” of User and Prospect Data. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Notice. In such instances, our Service Providers processing such data on our behalf will assume the role of “data processor”.
WorkRamp is the “data processor” of Customer Data and processes it on behalf of the Customer (who is the “data controller” of such data); and our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data. WorkRamp processes Customer Data strictly in accordance with our Customers’ reasonable instructions and as further stipulated in the Data Processing Addendum entered with WorkRamp and other commercial agreements with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the processing of Customer Data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
Updates and Amendments: We may update and amend this Privacy Notice from time to time by posting an amended version on our Services. We will provide prior notice if we believe any substantial or material changes are made via any of the communication means available to us or via the Services. By continuing to access or use the Portal, you agree to be bound by the revised Privacy Notice. If you do not agree to the modifications, your sole remedy is to terminate use of the Portal.
Requirements under US State Privacy Laws: This Notice describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 4) and deletion (Section 9) practices. We have also included information about how we may process your information (in Sections 2 through 7), which includes for “business purposes” under the CCPA/Virginia Consumer Data Protection Act (VCDPA)/Colorado Privacy Act (CPA) and other similar state laws, as applicable. We do not sell your personal information for the intents and purposes of the CCPA. We do share and disclose personal information to third parties or allow them to collect personal information from our Services as described in Sections 5 and 6 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you integrate the Services of third parties with our Services, or direct us to disclose your personal information to third parties, or as otherwise described in Section 5 above. If you have any questions or would like to exercise your rights under the CCPA, you can contact us by email to support@workramp.com.
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Notice applies only to our Services.
Children: Our Services are not designed to attract children under the age of 13. Children between the ages of 13 and 18 may only use the Portal with parental consent and in accordance with WorkRamp’s Terms. We do not knowingly collect personal data from children and do not wish to do so. If we learn that we have collected personal data from a child under the age of 13, we will promptly delete it. If you are a parent or guardian and believe we have collected personal data from your child under the age of 13, please contact us at support@workramp.com or call us at 888-336-8797 and we will take the necessary steps to delete their personal data from our systems.
Contacting Us: If you have any comments or questions regarding this Privacy Notice, or if you have any concerns regarding your personal data held with us, please contact us via support@workramp.com.
Last Revised: May 22, 2024