Privacy Policy

Introduction

Oakwood Solutions, LLC, doing business as The Conover Company (“Conover,” “we,” “our,” or “us”), is dedicated to safeguarding the information we process and ensuring it is used solely to support our visitors, customers, and educational initiatives. Our commitment is guided by the following privacy principles:

• Transparency: We aim to ensure clear and transparent data processing practices.
• Accountability: We demonstrate our commitment to privacy through concrete actions.
• Integrity: We strive to maintain the completeness, consistency, and accuracy of the data entrusted to us.
• Security: We implement robust technical, administrative, and organizational measures to protect data in compliance with regulatory requirements.
• Confidentiality: We establish policies, procedures, and practices that limit access to data and protect against unauthorized access or disclosure.

This Privacy Policy (“Policy”) describes our privacy practices and governs the information collected and processed by our websites, products, and services (collectively, “Services”), which include:

• The Conover Company Website (www.conovercompany.com)
• Conover Online (online.conovercompany.com, ajrotc.conovercompany.com, pro.conovercompany.com)
• ConoverU (www.conoveru.com)
• Conover Resources for Soft Skills (www.conoversoftskills.com)
• Conover Resources for Life Skills (www.conoverlifeskills.com)

Contents:

1. Definitions
2. Information Collection & Usage
3. Disclosure of Information
4. Children’s Privacy
5. California Consumer Privacy Act (CCPA) Notice
6. Student Online Personal Protection Act (SOPPA) Notice
7. Your Rights and Choices
8. Other Important Information
9. Security of Your Personal Information
10. Changes to our Privacy Policy
11. Contact Information

1. Definitions

Personal Information: Information that can identify an individual, either alone or in combination with other data.

Processing: Any operation performed on personal data, such as collection, storage, use, transfer, etc.

Cookies: Small pieces of data stored on a user’s device.

2. Information Collection & Usage

The types of personal information we collect and how we use it depend on your relationship with us. The following sections of our Policy apply to all our activities.

A. Website Users

This section applies only to the use of personal information related to our own websites (e.g., conovercompany.com). It does not cover any products and websites we provide for our customers. Please visit the relevant sections for information on how we handle the personal information of our customers’ end users. You can generally visit our websites without logging in or identifying yourself.

Information We Collect

• Directly from You: We collect information you provide when registering for events, completing forms or surveys on our website, or giving us your business card. If you provide additional content through our site, we may link this information with your personal information if you are logged in.
• Indirectly from You: We collect information about the pages you visit and how you access and use our websites using cookies and third-party analytics tools. This information includes device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect geographical location, referring pages, pages visited, and time spent on a particular site. Learn more about our use of cookies in our Cookie Policy.
• Information from Third Parties: We receive information from affiliates or other third parties to enhance the website experience and promote our products and services. For example, we receive information from third parties about the performance of online marketing or email campaigns.

How We Use This Information

We use this information to provide and improve our website services, including:

• Analytics and Marketing: Analyzing usage information for sales, marketing purposes, and understanding trends about our visitors and their demographics. This helps us improve our websites and communicate with you, including for marketing purposes.
• Personalization: Using your information to personalize the pages, providing more contextually relevant information as you browse our websites. For example, if you have indicated your primary industry or job title, we may present content related to your role or industry.
• Communication: Using the contact details you provided to communicate with you and let you communicate with us and other Conover users. This is necessary to provide this service and ensure our services meet our high standards.

We retain website usage information for as long as necessary for the purposes described above. This period varies depending on the services and websites you use and how you interact with us. Account information is kept until you delete the account and for a limited period afterward. Where you provide information in forms, it is kept only as long as required.

Who We Share This Information With

• Third-Party Tools: We use third-party tools (e.g., Google Analytics, Facebook Business) to understand how our websites are used and ensure you see relevant ads and campaigns on other websites. These third parties will have access to some of your personal information.
• Vendors: We share information with our vendors, service providers, and other third parties for legal or business purposes.

B. End User of an Institution That Uses Our Products

This section applies to any products, services, and websites we provide for our customers. Keep in mind we do not track any data on any students or end users of our system.

Personal Information

We collect personal information that may identify you, either alone or in combination with other information, such as:

• First and last name
• Organization
• Email address
• Password
• Imported profile information from third-party websites if you choose to register and/or log in with credentials from these websites

We collect your personal information when:

• You create an account for or use our Services.
• An organization creates an account for you in our Services.
• You import information from third-party websites and sources.
• Others invite you to join our Services.
• An academic institution transfers information from student information systems or other institutional systems into our Services.

Service Usage Information

We collect information about how you use our Services, including:

• Data from our Services, such as assessments, skill-building activities, etc.
• Application and system logs
• Performance data, such as how you use certain features
• Interaction data, such as time spent on features and visit timestamps

Communications and Other Interactions with Us

We collect information from and about your communications and interactions with us, including:

• Contact information
• Message and email content

We collect this information when you:

• Request assistance from our help desk
• Provide feedback on our Services
• Sign up for and attend conferences or webinars
• Participate in surveys and contests
• Otherwise communicate or interact with us

Device Information

We gather and store device information each time you use our Services, including:

• Browser type and manufacturer
• Operating system
• Location information (e.g., country or state)
• IP address

Who We Share This Information With

• Within Conover: Your information is accessed only by those who need it to provide the products and services. For instance, our technical and client support teams may access your information for support and maintenance purposes.
• Outside Conover: We use vendors or sub processors (e.g., Amazon Web Services) to help us provide our products and services. Third-party tools, such as Google Analytics, also have access to some of your personal information. Learn more about Google Analytics and how we may share information. For more information about how Google collects and uses your data, visit the Google’s Privacy & Terms. We may also provide de-identified information to partners relating to the usage of products and services provided by our partners. Here is a list of our current subprocessors. We do not use any of this data for marketing purposes.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Note about student data. We do not share the student data with any 3rd Part-tools such as Google Analytics or Microsoft Clarity.

3. Disclosure of Information

We share or disclose information, including personal information, only as described in this Privacy Notice. We do not sell or rent personal information to third parties.

Third-Party Service Providers

We may share your personal information with authorized third-party service providers to provide you with our products. These providers are not permitted to use personal information for their own advertising or marketing purposes.

Google APIs

The Conover Company’s use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

As Required by Law

We may be required to disclose information to:

• Comply with legal or regulatory processes (e.g., judicial proceedings, court orders, government inquiries)
• Enforce the Conover Acceptable Use Policy and other applicable policies
• Respond to claims that content violates third-party rights
• Protect the rights, property, or personal safety of Conover, its employees, users, clients, and the public
• Facilitate a Change of Control. If Conover undergoes a merger, acquisition, or other transaction involving the sale or transfer of business assets, we may share information accordingly. Notice will be posted on our website if information is shared in this manner.

With Your Consent or at Your Direction

We may share information with your consent or at your specific direction.

De-Identified or Aggregate Use

We may share de-identified or aggregate information for any purpose without limitation, unless prohibited by applicable law.

4. Children’s Privacy (COPPA)

We do not knowingly collect any information from children under the age of 13 in the United States unless and until the relevant institution has provided consent and authorization for a student under 13 to use the products and services and for us to collect information from such student. Where a client institution instructs us to collect personal information from children under the age of 13, we collect, use, process and retain such information solely to provide the educational services on behalf of the client and for the purposes set forth in our agreement with the client. We collect only as much information as is necessary to provide the service and the client may access, delete, or withdraw consent for continued processing of the child’s information at any time. If you have any questions about reviewing, modifying, or deleting personal information of a child under the age of 13, please contact your educational institution directly.

If you believe we have collected personal information from a child under 13 without proper consent, please contact us at privacy@conovercompany.com to allow us to delete such information promptly.

5. California Consumer Privacy Act (CCPA) Notice

As a resident of California, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA). This notice provides you with information about your rights and our practices regarding your personal information.

1. Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.

2. Right to Delete: You have the right to request that we delete any personal information we have collected from you, subject to certain exceptions.

3. Right to Opt-Out: You have the right to direct us not to sell your personal information to third parties.

4. Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

To exercise any of these rights, please contact us at privacy@conovercompany. We will respond to your request within the time frame required by law.

6. Student Online Personal Protection Act (SOPPA) Notice

We are committed to protecting the privacy of students’ personal information in compliance with the Student Online Personal Protection Act (SOPPA). This notice outlines our practices regarding the collection, use, and protection of student data.

1. Data Collection: We may collect personal information from students for educational purposes, including but not limited to names, contact information, and academic records.

2. Data Use: The personal information we collect is used solely for educational purposes, such as improving student learning experiences, supporting educational programs, and communicating with students and parents.

3. Data Sharing: We do not sell or rent student personal information to third parties. We may share data with authorized service providers who assist us in fulfilling our educational obligations, subject to strict data protection agreements.

4. Data Security: We implement reasonable security measures to protect student data from unauthorized access, use, or disclosure.

5. Parental Rights: Parents and guardians have the right to review and request the correction of their child’s personal information. If you have any questions about reviewing, modifying, or deleting personal information of a child, please contact your educational institution directly.

7. Your Rights and Choices

Communications

You may opt out of receiving marketing communications and other commercial emails from us by following the unsubscribe instructions provided in the communications. However, you will continue to receive administrative messages regarding the Services.

Right to Personal Information

You have the right to request access to, update, correct, or delete the personal information we maintain about you. Where required by law, we obtain your consent for processing certain personal information.

Exercising Your Rights

To update your preferences, ask us to remove your information from our mailing lists, delete your account, or submit a request to exercise your rights to your personal information, please contact us as specified in the “Contact Us” section below or via our help desk within the Service.

8. Other Important Information

Student Data Privacy Agreements

When providing our products to certain US academic institutions, we may sign a state-level Student Data Privacy Agreement (“SDPA”) with a Local Educational Agency (“LEA”).

Third-Party Websites

Our products may contain links to third-party websites or services. Your information may be collected by these separate entities, and the terms of this Privacy Notice do not apply to these outside websites. Please review the privacy policies of third-party websites for their data collection practices.

9. Security of Your Personal Information

We take appropriate measures to protect the confidentiality of your personal information against unauthorized access, alteration, disclosure, or destruction. Our site is regularly scanned for security vulnerabilities. However, no security measures are perfect, and we cannot guarantee absolute protection. In the event of a security breach, we will notify you promptly in accordance with legal requirements.

10. Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. Each version will apply to information collected while it was in place. We will notify you of any modifications by posting the new Privacy Policy on our site and indicating the latest revision date. If material changes affect your rights or obligations, we will notify you through email or a notification on the site.

11. Contact Information

If you have any questions or comments regarding this Privacy Policy, or if you would like to exercise your rights to your personal information, you may contact us at:

4 Brookwood Court Appleton, WI 54914 United States

Email: privacy@conovercompany.com