Privacy Policy
Franklin Covey Co. Privacy Policy
This privacy notice describes how your personal data (also known as personal information) is collected, used, handled, stored and disclosed.
Purpose of This Privacy Notice
This privacy notice describes how Franklin Covey collects and processes your personal data including through your use of this website and the services on it and 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, terms or agreement with you, 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. 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
The contact for our Australian representative:
Legal Entity: Franklin Covey Pty Ltd
Email Address: privacy@franklincovey.com
Postal Address: GPO Box 2769, Brisbane QLD 4001
You have the right to file a complaint at any time with applicable privacy authorities such as the United Kingdom Information Commissioner’s Office (ICO) or the Office of the Australian Information Commissioner (OAIC) (each of which are the supervisory authority for data-protection issues in their respective jurisdictions). However, we would appreciate the opportunity to resolve your concerns, so please consider contacting us first.
Changes to the Privacy Notice and Request for Current Data
This privacy notice was last updated 6/18/24. Any changes we may make to our privacy notice will be posted on this website or, where appropriate, we may communicate the changes to you by email or other means.
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.
Data Collection
Personal data or information means any information or an opinion about an identified individual or from which a person can be identified. It does not include data where identifying information is removed (anonymous data).
We may collect, use, store, disclose and transfer a variety of personal data, including:
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. If you do not provide your personal data to us or it is incomplete or inaccurate, we may be unable to provide you with the product or services you are seeking.
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, chat or otherwise. Included is personal data provided when you:
Automated technologies or interactions, including technical data about your equipment, browsing actions, and patterns. Personal data is collected using cookies, server logs, chat bots 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.
Using Your Personal Data
Use of your personal data is limited by law. Most commonly, personal data is used:
Using Your Personal Data
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 as permitted by applicable law. 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 (unless prohibited by law from doing so) and explain the legal basis that allows its use (or obtain your consent if required by applicable law).
We may process your personal data without your knowledge or consent, in compliance with the rules stated above, where required or permitted by law.
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:
We do not sell your personal information within the meaning of the California Consumer Privacy Act (CCPA).
International Transfers
We share your personal data within the Franklin Covey Group, requiring the transfer of your data outside the European Economic Area (EEA) and Australia (see here for a list of our global offices where your personal data may be accessible from: https://www.franklincovey.com/about/global-offices). Additionally, many of our external third parties are located outside the EEA or Australia, again requiring the transfer of your personal data to allow processing for example to countries like the United States of America and Ireland.
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:
Please contact us at privacy@FranklinCovey.com if you require additional information about our process for transferring your personal data outside the EEA.
Data Security
Security measures are in place designed 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 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.
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 or de-identify 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.
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) and Australian Privacy Act 1998 (Cth)(Privacy Act) and Australian Privacy Principles as set out in Schedule 1 of the Privacy Act (APPs). 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, CCPA, or Privacy Act, 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.
You can exercise the following rights at any time. Please contact our data protection officer, which contact details you can find at the top. Please note, these rights are subject to certain exceptions and exclusions and we may not be able to comply, in full, with any request you make. In such circumstances we will explain to you.
– Information about or access to your stored data and their processing (Art. 15 GDPR and Privacy Act APP 12)
– Correction of incorrect personal data (Art. 16 GDPR and Privacy Act APP 13)
– Erasure of your stored data (Art. 17 GDPR)
– Restriction of data processing if we are not yet allowed to delete your data due to legal obligations (Art. 18 GDPR)
– Objection to the processing of your data by us (Art. 21 GDPR)
– Data portability if you have consented to data processing or have concluded a contract with us (Art. 20 GDPR)
If you have given us your consent, you can revoke it at any time with future effect.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or the Australian Office of the Information Commissioner (OAIC) (https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us). We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance.
Your right to object
If the GDPR applies, at any time you have the right, for reasons that arise from your particular situation, to object against the processing of your personal data, which is based on Art. 6 Para. 1 lit. f GDPR (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Art. 4 No. 4 GDPR. If you file an objection, we will no longer process your personal data, unless we can demonstrate compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
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
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,and provides IT and system-administration services.