Last Revised: 8/18/15
Holden LLC d/b/a International (“Holden,” “us,” “we,” “our”) understands that your privacy is important to you, and is committed to protecting the privacy of those who use our website. This Privacy Statement explains how we collect, use and protect website users’ information.
The TRUSTe certification covers our collection, use and disclosure of information we collect through our website: www.holdenintl.com and our Services: Efox.holdenintl.com and Elearn.holdenintl.com. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Holden LLC.
In order to view our relationship with TRUSTe please visit the validation page visible by clicking on the TRUSTe seal. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request
Holden complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Holden has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Holden's certification, please visit http://www.export.gov/safeharbor/
USING THIS WEBSITE OR SUBMITTING PERSONAL INFORMATION CONFIRMS YOUR CONSENT AND AGREEMENT TO TERMS OF THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY STATEMENT, PLEASE DO NOT USE THIS WEBSITE OR SUBMIT PERSONAL INFORMATION.
Changes to Privacy Statement
Holden may change this Privacy Statement at any time. Each time you visit this website, you should check the date of this Privacy Statement (which appears above) and review any changes that have been made since your last visit to the website. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. You agree that your continued access and use of this website will bind you to any new terms of this Privacy Statement.
What personal information do we collect and how do we collect it?
How do we use the personal information?
Holden may use your personal information to respond to your requests for information, provide newsletters, alerts, send webinar invitations, and improve the services we provide to you and others. We may also contact you to seek feedback on our services or for marketing or other research purposes. Your personal information may also be used to protect our rights or property and that of our other users.
Newsletters, Alerts and Webinar Invitations
By subscribing for recurring Holden newsletters, alerts and webinar invitations, you agree to receive on occasion other correspondence from Holden related to the newsletters, alerts and webinar invitations that you consented to receive during the registration for the subscription. In addition, we may contact you regarding your account status. You will be contacted by email or otherwise only by Holden or its agents. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at firstname.lastname@example.org.
How can I change, delete, or stop use of my personal information?
At any time you may request that we discontinue sending your emails or other communications generated in response to your subscription to newsletters, alerts, webinar invitations. Additionally, you may request that we correct, update, and/or delete any personal information that you submit to website by emailing us at email@example.com or by contacting us by postal mail at the contact information listed below. We will respond to your request within a reasonable timeframe. However, if personal information is required for use of certain areas of the site, you may lose and no longer have access to those areas and the associated services if you request Holden to delete your personal information.
We and our marketing partners , affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
Cookies are small pieces of data stored on a user’s web browser. These pieces of data do not contain and are not linked to personal information, but allow us to identify repeat users of our website and track the interests of our users to enhance their experience on our website.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We do not link this automatically collected data to other information we collect about you.
We use Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here ). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Is personal information shared with third parties?
We will share your personal information with third parties only in the ways that are described in this privacy statement.
Holden shall not intentionally disclose or transfer your personal information to unrelated third parties. Holden may use third party vendors or contractors to provide services related to the website and to you such as offering customer service and contacting you if you have opted in to receive marketing information. Any such vendors or contractors shall be contractually required to maintain the privacy of personal information in accordance with applicable law.
If Holden is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.
How long is personal information retained?
Holden retains personal information for so long as it is necessary to serve the purposes described in this Privacy Statement, or for such other period as required by applicable law.
How is personal information protected?
Holden uses generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration, or destruction. Despite our efforts to protect your personal information, there is always some risk that an unauthorized person may illegally gain access to systems, or that transmission of your personal information over the internet may be intercepted. Therefore, we cannot guarantee that unauthorized persons will not obtain access to your personal information.
The Holden website may host various publically available or user restricted blogs, forums, and other social media applications or services that allow you to share content with other users (“collectively, “Forums”). Any personal information or other information that you contribute or share on any Forum can be read, collected and used by other users of that Forum over whom Holden has little or no control. Therefore, Holden is not responsible for any user’s or third party’s use, misuse or misappropriation of any personal information or other information that you contribute or share on any Forum.
Links to third party websites
Social media widgets
Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Children’s privacy protection
Holden understands the importance of protecting children’s privacy, especially in the online world. This website is not designed for or intentionally targeted at children 13 years of age or younger, and Holden does not intentionally collect or maintain information about anyone under this age.
Notice to California Residents
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Holden to third parties for the third parties’ direct marketing purposes. This request for information applies only to Holden’s activities within the State of California. To make such a request, please send an email to email@example.com or write us at the address below.
Holden collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Holden has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Holden’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Holden will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Questions about the Privacy Statement
If you have any questions about our Privacy Statement, please send an email to firstname.lastname@example.org or write us at the following address:
Director of Operations
135 South LaSalle St. Suite 2800
Chicago, IL 60603