BEST PRACTICE NETWORKS, INC.(BPN) PRIVACY POLICY NOTE: If you are under the age of 18, this policy should be read by both you and your parent(s)/legal guardian(s). If you are under the age of 13, you must have your parents permission to use this site or any sites operated by Best Practice Networks. Do not give any personal information such as email addresses, phone numbers, etc. without permission from a parent or legal guardian. Our Commitment to You Protecting your privacy and earning your trust are of utmost importance to Best Practice Networks (BPN). Accordingly, we believe that visitors to our site should be informed of our practices with regard to use and disclosure of their personal information (that is, information that identifies a particular individual or that can be linked to an identified individual) and of the choices they have with regard to use of their personal information. This statement discloses the Best Practice Networks Web site privacy practices as well as our data security practices. We do not sell, trade, rent, or give away your personal information to third parties or partners except under the circumstances described below. Our privacy policies may undergo changes, so please check this privacy policy statement from time to time. Information we Collect and How it is Used We collect personal information to create a more personalized experience for you, to help us understand our customers better, to process your orders, to improve your experience at our site, and to enable you to participate in various communications and marketing programs that we or our partners may offer on or through our site. When you supply personal information on a BPN site, you share that information only with BPN and its agents and subcontractors, unless you are notified otherwise as described below. Registration and Business Communications In order to access certain parts and functionality of BPN, you must be a registered user. Our registration form may require certain contact information such as your name, e-mail address, zip code, and country. We will use your contact information to contact you as appropriate in connection with the provision of services through our site, as further described below. We may also use that information to send you information about our company and to send you promotional material or other information from our partners unless you exercise choice not to receive this information. We may ask for other information that we would use to give you a more personalized experience with BPN. Whenever information is optional, we will tell you, so you can decide whether to provide it. Please note: Even if you decline all newsletters and all promotional and other optional correspondence, BPN reserves the right to e-mail you correspondence essential to conducting business with BPN (e.g., technical updates, service changes, billing statements, company contact changes, product revisions, new products, site functionality changes, etc.). In addition, if you are a current student, you will continue to exchange correspondence with your instructor, which is essential to your learning experience, until your program or class ends. For example, your instructor may provide you with information about updated schedules, changed or canceled classes, resource links, study tips, site changes, and other information necessary to provide you with the most complete learning experience possible. It is not possible to opt out of receiving communications from your instructor while you are a student. BPN may keep a record of any personal correspondence with you, such as e-mails, instant messages, other written correspondence, or telephone conversations. Sometimes we will ask you for feedback on our services and products. We may keep your feedback/responses for our records. We may also use comments for marketing purposes. In such an event, your personally identifiable information will be kept confidential. Purchases From Us If you buy products or services through our e-commerce engine, we will require that you give us information such as your address, phone number, credit card number, and expiration date. We must have this information to fill your order. We may share this information with others working on our behalf, such as credit card processors or order-fulfillment contractors, as necessary to fill the order, but these parties will be authorized to use the information only for that purpose. When you buy services or products from us, we also record information about your buying behavior and your buying history, which we may use to offer other product or services we think will interest you, unless you have chosen not to receive promotional mailings. Other Purchases Through our Site or From our Partners In some cases we may act as a marketing or sales agent for a third party, taking orders on our site on their behalf. In that case, we will gather information about you on behalf of the third party and will send the information to the third party for processing the order. In other instances (such as co-branded pages), we may host other parties on our site who will market their products directly to our users. In such cases, it is the third party, not BPN, who is gathering the information. In both cases, we cannot control the third party's use of that information. Such third-party marketing pages on our site will be clearly identified. We will endeavor to ensure that the third parties provide you with information about their privacy practices, for example, by a link or statement on the page where the order information is gathered. BPN's privacy policy does not cover the privacy practices of those businesses. Finally, we may provide links to pages operated by other parties, where those parties market goods or services. These third-party pages likewise are not covered by this privacy policy. You should consult those parties' privacy policy, if any, to learn about their data practices. If you are ever in doubt as to who is collecting information from you, look for a link to a privacy policy on the screen where the information is collected. If the page does not contain a link to this policy, then you are providing data to someone else and this policy does not apply. Advertisements We may include third-party advertisements on our site. These might include advertisements targeted to you, based on personal information you give us or information we've been tracking automatically. We do not allow advertisers to have access to individual account information. Instead, third parties provide us with advertisements and identify their desired audience, which we research from our database. We may then serve advertisements to pages you view based on your demographic information, interests, preferences, and online behaviors. These advertisements may be in the form of banner ads, links, or buttons, for example. Advertising is an integral part of our site, and it is not possible to opt out of viewing such advertisements. In addition, we may send advertisements or special offers via e-mail. You will only receive these if your registration information indicates you do not object to receiving them, or if you have agreed to receive or requested particular offers. We may provide advertising space on our site to third-party ad-serving agencies who will decide on behalf of their advertiser clients what advertisements to display on our site. Commonly these agencies will place a cookie on your computer to keep track of what advertisements you have already seen, and to track your browsing behavior both within our site and on other sites to which they serve ads. Typically this information is used in an attempt to provide you with advertisements that will interest you and to avoid monotonous repetition of the same advertisements. We require assurances from any such agencies that this information is collected on an anonymous basis, that is to say that the click-stream information is not to be linked to any personally identifying information. Otherwise, we do not control the practices of these ad serving agencies or third parties with respect to the information they gather via cookies. This policy does not apply to information gathered by these agencies. Links to Other Web Sites This site contains links to other sites. BPN is not responsible for the privacy practices or the content of other Web sites. You should consult the privacy policy, if any, appearing on the linked site to learn about their data practices. Employer-Sponsored Training If your employer is paying for, sponsoring, or reimbursing you for training through BPN, your employer has rights to all information concerning your usage of this account. As requested, BPN will provide employers with information about employee Web site usage, attendance in classes, access to learning resources, and other features of the site. This includes, but is not limited to, frequency of use, amount of time spent in the course site, forum postings, and chat room attendance. We do not place any restrictions on, and cannot control, the employer's use of this information, and this policy does not apply to this information. You should consult your employer if you wish to know what policies, if any, the employer will apply to its use and disclosure of this information. Third-Party or Partner Products or Services Please see the sections "Other purchases through our site or from our partners" and "Advertisements" to learn how your personal information may be shared with, or collected directly by, third parties in those situations. Chats/Forums/Newsgroups/Listbots BPN makes or may make chat rooms, forums, message boards, news groups, and listbots available to students. Please remember that any information you disclose in these areas becomes public information, and you should use caution when deciding to disclose any personally identifiable information. Also, note that if you join a listbot, other students may have access to your e-mail address. Hosted Training If BPN "hosts" outside companies who want to run their own training and meetings over our site, or if another software vendor wants to train people on their software but needs a "host" so that they can distribute it to users, this privacy policy does not apply to information you share with those companies or their representatives. We do not control the data practices of those third parties. You should consult the third parties' privacy policy, if any, to learn about their data practices. Statistical and other aggregate data We may provide statistical data on our customers to advertisers, partners, vendors, and third parties. This statistical data consists of aggregate or anonymous data only; it does not contain any personally identifiable information. Legal and Other Extraordinary Disclosures Our privacy assurances are not absolute and sometimes must give way to other important obligations or privileges. For example, BPN may disclose your information if necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with our site or property rights, your rights, or others' rights. Similarly, BPN will disclose information required by law or regulation, or by any regulatory or licensing agency, or to comply with a legal process served on BPN or its Web sites, and we may voluntarily cooperate with investigations by government agencies and provide information to them if requested without receiving compulsory legal process. We may also disclose your personal information in the good faith belief that we must act under exigent circumstances to protect the personal safety of users of BPN, its Web sites, or the public. Changing Personal Information and Preferences If at any time you would no longer like to receive updates, promotions, or product information from BPN and its affiliates, please contact us at withdraw@bpn.net. Please type withdraw or unsubscribe in the subject line of the email. Withdraw requests may take several days to process through our system. You may also change your contact information online through your online account at any time. Child Privacy Policy and Parental Consent Statement General Compliance The safety of children using BPN is our top priority. Our policies comply with the Children's Online Privacy Protection Act of 1998, for the protection of children's online privacy. BPN does not: Collect online contact information from children under the age of 13 without prior parental notification and consent. Parents or guardians are provided an opportunity to prevent use of the information and the child's participation in the related activity. Without prior parental consent, online information will only be used to respond directly to a child's request and will not be used for other purposes. Collect personally identifiable offline contact information of a child under age 13 without prior parental consent. Distribute to third parties any personally identifiable information relating to a child under age 13 without prior parental consent. Give children under age 13 the ability to publicly post or otherwise distribute personally identifiable contact information without prior parental consent. Entice any child by the prospect of a special game, prize, or other activity, to divulge more information than is needed to participate in the activity. Policies for Children Under the Age of 13 Parents and guardians are encouraged to spend time online with their children and to participate together in online activities. No information should be submitted or posted through our services by any student or visitor under 13 years of age without the consent of his or her parent or guardian. BPN does not provide any personally identifiable information, regardless of its source, to any third party for any purpose concerning our students or visitors under 13 years of age. Registered students are given a unique username and password. Parents should register their child for any courses through BPN. In the event a visitor under the age of 13 registers with us, he or she is required to provide the e-mail address of a parent or guardian so that we can send that parent or guardian an email alerting them to the registration. In order for the child to use the service for which the child is registered, the parent or guardian must validate the registration, as described in the alerting e-mail. In the alerting email, we will inform the parent what we intend to do with the information the child has provided, and we will inform the parent how to review or delete the information. We will not retain a child's email address without a parent's or legal guardian's permission. We do not allow students or visitors under 13 years of age to be listed in any student or visitor directory or to receive direct marketing communications or to be sent third-party offers. Parents' Right to Review or Delete Information Parents may review the information a child has submitted by sending a written request to: Attn: COPPA - Information Request Best Practice Networks Inc. 3475 Lenox Road, Suite 400 Atlanta, GA 30326 Please be sure to include the name and address of your child, your child's username and password and any other information that will allow us to verify that the request is from the parent of the child whose information is being requested. Parents reserve the right to request their child's information be deleted at any time and can also instruct us not to collect any more personal information from their child. Written requests should be sent to: Attn: COPPA - Delete Request Best Practice Networks Inc. 3475 Lenox Road, Suite 400 Atlanta, GA 30326 Questions regarding our privacy policy may be emailed to coursesupport@bpn.net or call us at 800.303.9070. BPN will abide by the student privacy guidelines set forth by the Family Educational Rights and Privacy Act (FERPA). The following persons have access to student records: Executive Director and administrative team Professional staff of the school (teachers) Appropriate administrative support staff members Other professionals who have a legitimate educational or legal interest in student records as designated by the Executive Director. BPN will provide an academic report to the student's primary school of record, legal guardian upon completion of their online course(s), or at any time upon the request of the primary school and/or student's legal guardian. No member of the BPN staff is authorized to release student information without the written request of the student's legal guardian or without the approval of the BPN director. The names of BPN students, their images, and their course work will not be published on our Web site without student and guardian written consent. All BPN students are provided a unique password that will allow them to access their online courses. It is the responsibility of the student to keep his/her password in confidence. For more information regarding federal policies, click on the following links. Children's Online Privacy Protection Act of 1998 (COPPA) Children's Advertising Review Unit (CARU) Family Educational Rights and Privacy Act (FERPA) How Best Practice Networks Protects the Security of Personal Information User Names and Passwords At BPN we take security seriously. Your account information and profile are password-protected in an effort to ensure that only you and your management have access to your personal information. You can check or change your account information and profile by logging onto your account. To protect yourself: Do not give anyone your password, not even a BPN employee. If your password has been compromised, you should change your password immediately. When you have finished using BPN, sign out of your account and close your browser window. Until you have done so, your password may still be active and others may be able to access your personal information. Financial Information/Safe Shopping Information At BPN we are committed to protecting the privacy and security of your credit card and financial account information. We do not sell, trade, rent, or give away your financial or credit card information except as indicated in this policy in connection with fulfilling transactions you initiate. When you enter credit card information on our Web site, we transmit the information in encrypted format, using industry-standard secure socket layer (SSL) encryption. Guarantee Details (1) Under the Fair Credit Billing Act, your bank cannot hold you liable for more than $50.00 of fraudulent charges. BPN will cover this liability for you only if the unauthorized use of your credit card resulted through no fault of your own from purchases made at BPN while using the secure server. (2) In the event of unauthorized use of your credit card, you must notify your credit card provider in accordance with its reporting rules and procedures. Cookies A "cookie" is data that is sent to your browser from a Web server and stored on the hard drive of your computer. Our site uses cookies to recognize you and track your progress within a course. Session IDs Session IDs allow BPN to identify a particular user to customize the user's learning experience. The session ID also allows us to track student progress within a course. Session IDs expire upon logging out of the BPN system and closing your Internet browser. Contacting the Webmaster If you have any questions about this privacy statement, the practices of this site, or your dealings with this Web site, please contact: Attn: Webmaster Best Practice Networks Inc. 6365 Collins Avenue, Suite 3608 Miami, Florida 33141 webmaster@bpn.net