Privacy Policy

Glaser & Associates, Inc. ("Glaser," "we," "us," or "our") provides online training, educational content, coaching resources, and related services through our websites, learning platform, and related communications (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information about individuals who visit our websites, create accounts, purchase or access our Services, participate in courses or assessments, contact us, or otherwise interact with us.

We aim to use clear, direct language. This Policy is intended to help users understand what information we collect, why we collect it, how we use it, when we share it, and the rights and choices available to them under applicable law.

1. Scope of This Policy

This Policy applies to personal information we collect online and offline in connection with the Services, including information collected through our website, learning platform hosted on LearnWorlds, email communications, support channels, surveys, events, and other interactions related to the Services.

This Policy applies to:
• visitors to our website;
• individuals who create accounts, purchase, use, or otherwise access the Services;
• learners, participants, or customers whose access is arranged or sponsored by an employer, organization, coach, or other sponsor; and
• individuals who contact us, subscribe to communications, or otherwise interact with us in a business or professional capacity.
This Policy does not apply to third-party websites, applications, or services that we do not control, even if they are linked from our Services. Those third parties have their own terms and privacy policies, and we encourage you to review them.

2. Who Is Responsible for Your Information

Unless another notice states otherwise, Glaser & Associates, Inc., 1740 Craigmont Avenue, Eugene, OR 97405, is responsible for the personal information described in this Policy. Depending on the context, Glaser may act as a controller, business, or similar responsible party under applicable privacy laws.

If your access to the Services is provided through an employer, educational institution, or other sponsor, that sponsor may also independently determine how certain information is used and may be separately responsible for information it receives or directs us to process.
However, we will not provide your employer, institution or sponsor with your Personal Inputs (defined in clause 4.1) without your written consent. That said, for your additional peace of mind we recommend you avoid using the actual names of real persons within your Personal Inputs (use an initial or pseudonym).

3. Information We Collect

We collect personal information in three main ways: (1) information you provide directly, (2) information collected automatically when you use the Services, and (3) information received from third parties. The categories below describe the types of information we may collect, depending on how you interact with the Services.

4. Information You Provide Directly

  • Account and Profile Information. This may include your name, email address, telephone number, postal or ZIP code, country, profession, job title, organization, login credentials, and other profile or account details you choose to provide.
  • Course, Assessment, and Submission Information. We may collect the information you submit through the Services in connection with coursework, exercises, quizzes, assessments, reflections, assignments, or related learning activities. In this Policy, we refer to user-submitted responses and materials as "Personal Inputs." Personal Inputs may include written responses, uploaded files, comments, answers to exercises, and similar content submitted through the Services.
  • Communications and Support Information. We may collect information when you contact us, respond to surveys, subscribe to newsletters, request support, attend events, or otherwise communicate with us.
  • Payment and Transaction Information. If you purchase Services directly from us, payment and billing information may be collected and processed by third-party payment processors acting on our behalf. We generally do not store full payment card numbers ourselves, although we may receive limited transaction details such as payment status, billing name, billing address, and partial payment identifiers needed for recordkeeping and customer support.
  • Professional and Organization Information. If you use the Services in connection with your employer, organization, or sponsor, we may collect information relating to that relationship, such as your employer or sponsor name, enrollment details, role, and training program participation.
  • Sensitive Information You Choose to Provide. Some Personal Inputs or communications may contain information that is sensitive under applicable law, for example information relating to health, ethnicity, religious beliefs, employment matters, or other private matters. We ask users not to include sensitive personal information or unnecessary personal information about other individuals unless doing so is genuinely needed for the relevant exercise or service. For added privacy, we recommend using initials or pseudonyms instead of full names where practical.

5. Information Collected Automatically

When you visit, access, or use the Services, we and our service providers may automatically collect certain technical and usage information, including:
  • device and browser information, such as IP address, browser type and version, operating system, device identifiers, language settings, and similar technical information;
  • usage and log information, such as pages viewed, links clicked, time spent, dates and times of access, referring and exit URLs, error logs, and interaction with features or content;
  • course and platform interaction information, such as content viewed, course progress, completion status, lesson navigation, participation activity, assessment attempts, and similar usage patterns; and
  • cookie, pixel, local storage, or similar tracking information as described in Section 8 below.
We refer in this Policy to certain system-generated information about a user’s interactions with the Services over time as "Engagement Data." Engagement Data may include course progression or non-progression, participation levels, attempts, completion status, performance metrics, grading outputs, and system-generated feedback made available as part of the Services. Engagement Data does not include the underlying Personal Inputs themselves, although Personal Inputs may be used to generate outputs or scores reflected in Engagement Data.

6. Information from Third Parties

We may receive personal information from third parties, including:
  • our learning platform provider and related vendors that help host or deliver the Services;
  • payment processors and other transaction service providers;
  • analytics, communications, hosting, security, and customer support vendors;
  • employers, organizations, coaches, schools, or other sponsors that arrange or pay for access to the Services;
  • social sign-in or single sign-on providers, if you choose to use those features; and
  • publicly available sources or referral sources, where relevant to our business relationship with you.

7. How We Use Personal Information

We use personal information for legitimate business and service-delivery purposes, including to:
  • provide, operate, maintain, secure, troubleshoot, and improve the Services;
  • create, verify, administer, and support user accounts and enrollments;
  • deliver course content, assessments, exercises, webinars, progress tracking, coaching features, certifications, and related learning functions;
  • process payments, subscriptions, renewals, refunds, and related transactions;
  • communicate with you about your account, purchases, progress, technical issues, updates, support requests, and service-related notices;
  • send newsletters, promotional emails, event updates, or other marketing communications, subject to your choices and applicable law;
  • understand how users interact with the Services, including through analytics, service improvement, and product development;
  • administer surveys, feedback requests, research, and quality assurance activities;
  • protect the Services, our business, and our users from fraud, misuse, unauthorized access, security incidents, and other harmful activity;
  • comply with legal obligations, enforce our terms and policies, resolve disputes, and establish, exercise, or defend legal claims; and
  • carry out other purposes described to you at the time of collection or otherwise permitted by law.

8. AI-Assisted and Automated Tools

We may use automated tools, including AI-assisted tools, to support the operation and delivery of the Services. Depending on the feature used, these tools may help us administer coursework, generate feedback, assist with grading or scoring, support search and organization, personalize aspects of the user experience, or analyze engagement and service performance.

Unless we expressly tell you otherwise, we do not intend to use solely automated decision-making to make decisions that produce legal or similarly significant effects about individuals. Where human review is part of the process, automated tools are intended to support, not replace, human judgment. Users should avoid submitting unnecessary sensitive information or personal information about other individuals when completing open-text fields or exercises.

9. How We Share Personal Information

We do not sell personal information for money. We share personal information only as reasonably necessary to operate the Services, comply with law, protect rights and safety, support sponsored access arrangements, or as otherwise described in this Policy.

We may share personal information with the following categories of recipients:
  • Sponsors and sponsoring organizations. If your access to the Services is arranged, funded, or administered by an employer, organization, educational institution, coach, or other sponsor, we may share Engagement Data and related account or enrollment information with that sponsor to administer the sponsored relationship, measure participation, confirm completion, support reporting, or otherwise provide the sponsored Services. Unless we are legally required to do so, we do not share the full text of your Personal Inputs with your sponsor without your express written consent.
  • Service providers and processors. We share information with vendors and service providers that help us host, operate, secure, support, market, and improve the Services, such as learning platform providers, cloud hosting and infrastructure providers, payment processors, analytics providers, email and communications platforms, customer support tools, security vendors, and professional service providers. These parties are permitted to process personal information only as needed to perform services for us or on our behalf, subject to appropriate contractual or legal restrictions.
  • Affiliates and advisers. We may share information with our affiliates and with our legal, accounting, insurance, financing, audit, and other professional advisers where reasonably necessary for business operations, legal compliance, or corporate administration.
  • Legal and safety disclosures. We may disclose information where we believe in good faith that disclosure is necessary or appropriate to comply with law, regulation, subpoena, court order, or other legal process; to enforce our terms and policies; to detect, investigate, or prevent fraud, misuse, security issues, or illegal activity; to protect our rights, property, and safety or those of others; or to respond to emergencies.
  • Business transfers. We may disclose or transfer information in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar corporate transaction, subject to applicable confidentiality and notice requirements.

Some disclosures to advertising, analytics, or social media partners may be treated under certain US state privacy laws as "sharing" or use for targeted advertising when those tools are enabled. Where required by law, we will provide appropriate notice, choice, or consent mechanisms.

10. Sponsored Users / Employer-Sponsored Access

If your use of the Services is sponsored or arranged by an employer, school, organization, coach, or other sponsor, both this Policy and the sponsor’s own privacy practices may be relevant to you.

In those cases:
  • your account may be created, provisioned, or managed in coordination with the sponsor;
  • the sponsor may receive reports about your enrollment, participation, completion status, scores, performance metrics, certifications, or other Engagement Data, depending on the Services provided and the sponsor arrangement;
  • the sponsor will not receive or be able to access your Personal Inputs;
  • the sponsor may also provide information to us to administer the sponsored relationship; and
  • the sponsor may be independently responsible for the information it receives from us or provides to us.

If you have questions about how your sponsor uses information it receives, you should review the sponsor’s privacy notice or contact the sponsor directly.

11. Cookies and Tracking Technologies

We and our service providers may use cookies, pixels, tags, software development kits, local storage, and similar technologies to operate, secure, and improve the Services and to understand user engagement.

These technologies may be used for the following purposes:
  • Essential technologies, which are needed for login, authentication, security, session management, payment processing, load balancing, fraud prevention, or core platform functionality;
  • Functional technologies, which help remember your preferences, settings, or prior actions;
  • Analytics technologies, which help us understand how users interact with the Services, measure traffic and engagement, identify errors, and improve performance; and
  • Advertising or social media technologies, where used, to measure campaigns, support marketing, or enable certain social sharing or embedded content features.

Depending on your location, we may rely on consent for certain non-essential cookies or similar technologies, and we may provide cookie controls or consent tools where required by law. You can also adjust your browser or device settings to block or remove certain technologies, although doing so may affect the functionality of the Services.

If your browser sends an opt-out preference signal recognized under applicable law, or if a consent or preference management tool is available on the Services, we will honor those preferences to the extent required by law and technically feasible.

12. International Transfers

Glaser & Associates, Inc. is based in the United States, and our service providers may operate in the United States and other countries. As a result, personal information may be transferred to, stored in, or accessed from countries other than the country where you live, including countries that may not provide the same level of data protection as your home jurisdiction.

Where required by applicable law, we will take appropriate steps to protect personal information transferred internationally, which may include entering into standard contractual clauses or relying on other lawful transfer mechanisms recognized under applicable law.

13. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain business and financial records, comply with legal obligations, resolve disputes, protect the security and integrity of the Services, and enforce our agreements.

Retention periods may vary depending on the type of information and the context in which it was collected. For example:
  • account, enrollment, and course records may be retained while an account remains active and for a reasonable period afterward;
  • transaction and billing records may be retained for longer where needed for tax, accounting, audit, or legal compliance purposes;
  • communications and support records may be retained as reasonably necessary to respond to inquiries, improve support, and document service issues; and
  • technical logs, security records, and backup records may be retained for limited periods as needed to maintain security, system resilience, and continuity.

When personal information is no longer reasonably needed, we will delete, de-identify, anonymize, or securely dispose of it, unless a longer retention period is required or permitted by law.

14. Your Privacy Rights and Choices

Depending on where you live and subject to applicable law, you may have some or all of the following rights in relation to your personal information:
  • the right to know whether we process your personal information and to request access to it;
  • the right to request correction of inaccurate personal information;
  • the right to request deletion of personal information, subject to legal exceptions;
  • the right to request a portable copy of certain personal information;
  • the right to object to or restrict certain processing in some circumstances;
  • the right to withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing;
  • the right to opt out of targeted advertising, the sale or sharing of personal information as defined by applicable law, or certain profiling activities where those rights apply; and
  • the right not to receive discriminatory treatment for exercising your privacy rights.

  • To exercise privacy rights, please contact us using the contact details in Section 18. We may need to verify your identity before acting on your request. In some cases, we may ask for additional information reasonably necessary to confirm your identity or authority to make the request.
  • You may also opt out of marketing emails by using the unsubscribe link in those messages. Even if you opt out of marketing communications, we may still send service-related or transactional messages.
  • If you are an authorized agent making a request on behalf of another person, we may ask for proof of your authority and may also take steps to verify the identity of the individual concerned.

15. Additional Information for EEA, UK, and Swiss Users

If you are in the European Economic Area, the United Kingdom, or Switzerland, you may have additional rights under applicable data protection laws, including the right to object to certain processing, the right to request restriction of processing, and the right to lodge a complaint with your local supervisory authority.

Our legal bases for processing personal information generally include:
  • performance of a contract or steps taken at your request before entering into a contract;
  • our legitimate interests, such as operating and improving the Services, securing our systems, communicating with users, preventing fraud, and administering our business, provided those interests are not overridden by your rights;
  • compliance with legal obligations; and
  • your consent, where required by law, including for certain marketing or cookie-related activities.

If we ask for your consent, you may withdraw it at any time, although this will not affect prior processing that was lawful at the time.

16. Additional Information for US State Privacy Laws

  • Residents of certain US states, including California, Oregon, and other states with consumer privacy laws, may have additional rights under applicable law. The availability of these rights depends on your state of residence and our role in processing the information.
  • Subject to applicable law, you may have the right to request access, correction, deletion, portability, or information about the categories of personal information we collect, use, disclose, sell, or share. You may also have the right to opt out of targeted advertising, certain profiling, or the sale or sharing of personal information as those terms are defined by applicable law.
  • Appeals. If we deny your privacy request, you may appeal our decision by replying to our response or contacting us again using the contact details below and stating that you are submitting an appeal. We will review and respond to appeals within the time required by applicable law. If your appeal is denied, we will tell you about any further rights available to you, including how to contact the relevant regulator where required by law.

17. California Privacy Disclosures

  • This Section supplements the rest of this Policy for California residents. In the preceding 12 months, depending on your interactions with the Services, we may have collected the following categories of personal information: identifiers; customer records information; commercial information; payment-related information; internet or other electronic network activity information; geolocation data derived from IP address or device information; professional or employment-related information; education or training information; audio, electronic, or similar information contained in communications or submissions; inferences drawn from the information above; and sensitive personal information to the extent users choose to include it in Personal Inputs or communications or where limited account or verification information qualifies as sensitive personal information under California law.
  • We collect this information from the sources described in Section 4 and use and disclose it for the purposes described in Sections 5 through 9 and elsewhere in this Policy.
  • We do not sell personal information for money. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about consumers. We may disclose personal information to service providers, contractors, sponsors, advisers, government authorities, and other recipients described in Section 7. Where cookies or similar technologies are used for analytics, social media, or advertising purposes, those practices may be treated by California law as "sharing" or use for cross-context behavioral advertising. Where required, we will provide appropriate notice and the right to opt out.
  • California residents may request access to specific pieces of personal information, correction of inaccurate personal information, deletion of personal information, and information about our data practices. California residents may also use an authorized agent to submit certain requests on their behalf, subject to verification requirements. We will not discriminate against you for exercising privacy rights provided by law.

18. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. These measures may include encryption in transit, access controls, role-based permissions, vendor management, logging, monitoring, and security review practices appropriate to the nature of the information and the Services.

No method of transmission over the internet or method of electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us promptly if you believe your account or information has been compromised.

19. Children’s Privacy

Unless a particular program expressly states otherwise, the Services are generally intended for adults and older teens participating in educational or professional development activities. We do not knowingly collect personal information online from children under 13 without legally required consent and authorization.

If you believe that a child has provided personal information to us in a way that is not permitted by applicable law, please contact us so we can investigate and take appropriate action.

20. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, technologies, vendors, legal obligations, or data practices. When we do, we will post the updated version on the relevant website or platform and update the Effective Date above. Where required by law, we will provide additional notice or obtain consent for material changes.

21. Contact Us

If you have questions, requests, or complaints about this Privacy Policy or our privacy practices, please contact us at:

Glaser & Associates, Inc.
1740 Craigmont Avenue
Eugene, OR 97405

Email: info@theglasers.com