McKinsey & Company and its subsidiaries and affiliates (collectively, “McKinsey”, “us” or “we”) understands that your privacy is important to you. We may process your personal data and we are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person, collected in connection with McKinsey Academy.
Information we collect
McKinsey collects personal data when you register, access or use McKinsey Academy or McKinsey Academy Content (as such term is defined in the Terms), whether through a Site or Mobile Offering or otherwise, including in connection with your use of course content, submission of User Content (as such term is defined in the Terms) and participation in user posting areas (such as bulletin boards, discussion forums and surveys).
The personal data collected may consist of information that you provide, such as your name, e-mail address, and other User Account Information (as such term is defined in the Terms). In addition, McKinsey Academy may (a) receive personal data about you directly from your Sponsoring Organization (as such term is defined in the Terms) or third parties that you authorize to share with us; and (b) collect and/or create personal data related to your use of and participation in McKinsey Academy, including Participation Data (as such term is defined below).
We may also automatically collect information about the devices you use to interact with McKinsey Academy. The information we automatically collect may include IP address, device identifier, web browser and browsing, viewing or other usage information or data connected to your use of McKinsey Academy such as click stream data, HTTP protocol elements, and the status of cookies placed on your computer (as described below). We may also automatically collect information about how you use McKinsey Academy, such as what you have searched for, viewed and use. The information automatically collected may be associated with your personal data, and in some instances may itself constitute personal data.
Use of information
The personal data we collect may be used where McKinsey has a legitimate interest in or other legal basis for processing such information. In some situations, the collection or processing of personal data may be required for the operation of McKinsey Academy, including enabling you to access courses and McKinsey Academy Content. McKinsey uses your personal data to fulfill your requests for information, process your requests to participate in conferences and events, personalize content that you view or receive through McKinsey Academy, evaluate and improve our services, distribute newsletters and alerts to you, analyze McKinsey Academy performance and functioning, publish or process your User Content, prevent fraud, enforce the Terms, comply with all applicable laws and corporate reporting obligations, enforce and comply with McKinsey’s agreements, and accomplish other purposes you may initiate or request. We may keep any of your personal data on file and use it to contact you.
Sharing information with your Sponsoring Organization
If you are participating in McKinsey Academy with the facilitation of a Sponsoring Organization (as such term is defined in the Terms), at the request of your Sponsoring Organization we may provide your Sponsoring Organization information about your activities and performance in connection with McKinsey Academy, which may include grades, evaluation, performance, critiques and other progress, usage and engagement data and metrics with respect to particular McKinsey Academy courses or services, some of which may constitute your personal data (collectively, “Participation Data”). McKinsey shall not be responsible or liable for the use of such information by your Sponsoring Organization, and such use shall be subject to your Sponsoring Organization’s policies (including privacy policies) applicable to you.
Data recipients and international data transfers
Personal data collected or processed by McKinsey Academy may be transferred from time to time to McKinsey subsidiaries and affiliates and their personnel (including employees and contractors) across our global organization, as well as to third party service providers located throughout the world. Additionally, McKinsey Academy Content, as well as the Sites and Mobile Offerings, may be viewed, hosted and supported by McKinsey and its third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by McKinsey subsidiaries, affiliates, and third party service providers, including the transfer of your personal data to countries other than the one in which you reside. By using McKinsey Academy you voluntarily consent to such trans-border transfer and hosting of such information.
In addition, we may disclose information about you:
- If we are required to do so by law or legal process;
- To law enforcement authorities or other government officials;
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- If disclosure is necessary to protect the vital interests of a person;
- To enforce our Terms;
- To protect our property, services and legal rights;
- To prevent fraud against McKinsey, our subsidiaries and affiliates and business partners;
- To support auditing, compliance, and corporate governance functions; or
- To comply with any and all applicable laws.
In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business, we may disclose or transfer your personal data.
You should be aware that whenever you publicly disclose information, even to a limited group of recipients (for example, other users who are enrolled in the same McKinsey Academy course as you), that information could be collected and used by others. McKinsey is not responsible for any action or policies of any third parties, including other McKinsey Academy users, who collect information that users disclose to such third parties in connection with their use of McKinsey Academy.
Third-party websites and platforms
In connection with our Mobile Offerings, McKinsey may use third party service providers to analyze non-personally identifiable user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, McKinsey receives reports on some of our Mobile Offerings’ aggregate usage and browsing patterns, including information about the type of device used, content or features accessed, and other events occurring within the Mobile Offering. McKinsey also receives reports on certain errors occurring within Mobile Offerings. None of these third party service providers gathers information in a manner intended to identify any particular user personally.
Data retention policy
McKinsey Academy is not designed for or directed at children 13 years of age or younger, and McKinsey does not intentionally collect or maintain personal data about anyone under this age.
Where granted by local law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you. In certain circumstances, you may also request that we cease processing your personal data.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at firstname.lastname@example.org.
To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring you to provide or confirm your identity, including your User Account Information, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws or circumstances may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request; such as for example, where producing your information may reveal the identity of someone. Where you are participating in McKinsey Academy with the facilitation of your Sponsoring Organization, we may, including where required by applicable law or contract, notify your Sponsoring Organization of your request and coordinate with your Sponsoring Organization in responding to your request. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.
Your California privacy rights
Pursuant to California Civil Code Section 1798.83(c)(2), McKinsey does not share your personal data with third parties for those third parties’ direct marketing use.
Contact our privacy department
c/o Marc Metakis
55 East 52nd Street
New York, NY 10022