Cookie Policy

ELB Learning, our Service Providers, and Brand Partners may use implement common information-gathering tools such as cookies, web beacons, pixels, and other similar tracking technologies (collectively, “Cookies”) to automatically collect information as you navigate the ELB Websites and use the ELB Solutions and/or when you interact with emails sent by or on our behalf.

While Cookies themselves typically do not contain information that directly identifies you, they store data related to your browsing habits and device that is considered pseudonymous. Despite being pseudonymous, such data is treated as personal data under data privacy laws because it can be used in combination with other information to potentially identify you. Accordingly, ELB Learning’s use of this data is subject to our Privacy Policy and this Cookie Policy should be read together with our Privacy Policy and our Website Terms of Use.

TYPES OF COOKIES

Below we describe different forms of Cookie technologies and the categories assigned under privacy laws based on their functionality.

1. Technical Forms. There are the various technologies used to store or gather information in your web browser, including those described below. Each type serves unique functions and is managed differently:

• Cookies. Text files that a website sends to your computer’s browser that can be used to recognize you as a website user or to provide personalized content.
• Pixel Tags / Web Beacons / Clear GIFs. Images (often transparent) placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and are often used in combination with Cookies.
• Flash Cookies or Locally Shared Objects (Flash LSOs). Messages used in Adobe Flash that are sent from a Web server to a Web browser and are then stored as a data file in the browser. Flash cookies behave like conventional cookies by personalizing the user’s experience, but they can hold much more data than conventional Cookies. Flash LSOs may stay installed on a drive after ordinary Cookies are deleted.

2. Privacy Law Use Categorization. These categories help understand how each type of cookie impacts your privacy and how they are used on our site:

• Essential Cookies. These cookies are necessary for the website to function correctly. They enable basic functions like page navigation and access to secure areas. Without these cookies, the website cannot perform optimally. On ELB Websites, essential cookies are used for tasks like authenticating user sessions after login, maintaining consistent page loads and navigation across the site, ensuring consistent and quick page load times, and supporting secure online payment by integrating third-party payment gateways.
• Performance Cookies. Performance cookies gather anonymous data on how users interact with the website. They help identify which pages are visited most often, and whether users encounter errors. This data aids us in improving the ELB Websites’ performance and user experience by performing activities such as monitoring which sections of the site receive the most traffic, identifying common navigation paths to streamline user journeys, and determining errors encountered on certain pages.
• Functionality Cookies. Functionality cookies remember the choices you make on the website, such as language preferences or regions, and provide enhanced features. They are also used to remember login details and other customizations to provide a personalized experience such as remembering your preferred language and tailoring content suggestions based on previously viewed resources.
• Advertising Cookies. Advertising cookies are used to deliver ads more relevant to you and your interests and may be tailored to your interest based on your browsing, across time, of the ELB Websites or Solutions and elsewhere on the Internet, which may include use of data from cross-device usage, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”). They are also used to limit the number of times you see an ad and help measure the effectiveness of advertising campaigns. On ELB Websites, advertising cookies are used for tasks like, displaying ads for ELB Solutions you may find relevant based on your previous browsing activity, measuring the effectiveness of our advertising campaigns, helping determine the best platforms for placing our advertisements.
• Analytics Cookies. Analytics cookies help website owners measure how users interact with website content, providing insights to enhance the overall experience. They typically collect aggregated data that doesn't directly identify individuals. On ELB Websites, analytics cookies are used for tasks like understanding user demographics and preferences, monitoring user engagement with different pages and resources, identifying user journeys and drop-off points to improve website navigation.

PERSONAL DATA COLLECTED VIA COOKIES

Personal data that may be collected automatically may include:

• Service Use. Information about your use of the ELB Websites or Solutions, which may include a history of the pages you viewed, content you searched for, functionality you used and third-party sites or services you accessed.

• IP Address. A unique number known as an Internet protocol (IP) address. We may obtain your general (imprecise) geolocation, information related to your Internet Service Provider and information about privacy promoting systems you may be using (e.g., if you are on a VPN or using a proxy server) from your IP Address. IP Addresses are assigned and reassigned by Internet Service Providers and companies regularly.
• Device Identified Information (“DII”). Data that is linked to a particular browser or device. DII may include, but is not limited to, unique identifiers associated with browsers or devices, such as:
  • Cookie IDs: A unique combination of characters that identifies Cookies assigned to your device/system but otherwise usually hold no intrinsic meaning beyond this. 
  • Mobile Advertising IDs or MAIDs: Apple assigns an “ID for Advertising” (IDFA) to each iOS device, and Google assigns an “Advertising ID” to all Android devices. These pseudonymous IDs can be used to deliver ads and for advertising analytics in mobile applications.
  • Statistical Identifiers: Statistical IDs are generated by using information about your computer or device including, operating system, user-agent string, IP Address, installed fonts, and similar information. This information makes your computer or device distinct enough for our systems to determine within a reasonable probability that they are encountering the same computer or device over time, including in environments where Cookies are not supported.
• Internet Log Data. In addition to your IP Address, this data may include your Web request, IP address, browser type, browser language, configuration settings, operating system, Internet/mobile provider referring/exit pages and URLs, number of clicks/pages viewed, pseudonymous IDs such as Cookies, service specific information such as Service Use, Event Data, and data relating to malfunctions or problems that may occur when you use ELB Websites or Solutions; and
• Event Data. Data related to ads you see (advertiser ID, campaign ID), where and when you see the ad (date/time stamp, URL), and how you react to the ads you see (click, hover, convert, etc.). This data may be associated with pseudonymous IDs such as DII and other pseudonymous data such as Internet Log Data.

COOKIE DATA RETENTION

The retention period of data collected by Cookies depends on the type of cookie used and its purpose. Cookies are classified by duration as “session cookies” or “permanent cookies.” In this case, “permanent” means that a specific expiration date (unrelated to the duration of the applicable session) is assigned. All ELB Learning “permanent” Cookies expire within 24 months. 

YOUR TRACKING CHOICES

Regular Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove these technologies, some parts of the ELB Websites or Solutions.

Analytics Cookies set by Google can be managed via a Browser Add-on (Google Analytics Opt-out Browser Add-on). Analytics Cookies set by Microsoft (i.e., Bing Ads) can be managed via the Microsoft Personal Data Dashboard. 

Many advertisers and service providers that perform advertising-related services for us and participate in voluntary programs that provide tools to opt-out of such interest-based advertising such as:

• Digital Advertising Alliance’s (“DAA”). DAA’s tools provides a centralized way to opt-out of Interest-Based Advertising from participating companies when those Cookies are placed on your web browser (DAA WebChoices Tool) and your mobile device via a downloadable application (DAA AppChoices Tool) 
• Network Advertising Initiative (“NAI”). NAI also provides a centralized way to opt-out of Interest-Based Advertising from its members when Cookies are placed on your browser, instructions to opt-out of cross-app advertising on your mobile device, and instructions to control the privacy settings on your TV streaming devices (NAI Choices Tools).
• European Interactive Digital Advertising Alliance (“EDAA”). EDAA tools provides a centralized way to opt-out of Interest-Based Advertising from participating Europe-based companies when those Cookies are placed on your web browser (EDAA YourAdChoices Tool).
• Google Ads Preferences. You can control how Google uses Cookies to tailor ads through the Google Ads Settings page (Google Ads Settings).
• Microsoft Ads Preferences. Microsoft provides tools to manage Cookies across Microsoft Services like Bing and Outlook as well as on third-party websites and apps using Microsoft advertising (Microsoft Advertising Personalization Settings). 

Please be aware that, even if you opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected, participating members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your browser-based opt-out may not, or may no longer, be effective.

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit; such signals may prevent third parties from collecting information about your online activities over time and across different websites. California law requires us to disclose how the ELB Websites respond to these kinds of “Do Not Track” signals. Like many websites, the ELB Websites currently are not designed to respond to “Do Not Track” signals from visitors’ browsers. To learn more about “Do Not Track” you may wish to visit this site.‍

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