Adaptive Learning
Privacy Policy

Vitalyst, LLC values the privacy of those who provide private personal information to the Company. This policy summarizes what personally identifiable information we may collect, and how we might use this information. This policy also describes other important topics relating to information privacy. Residents of the E.U., Switzerland  and the U.K. should refer to the Privacy Shield section below.

Information Collection
Internal Information Sources (Customer Inquiries)
Vitalyst, LLC only will collect personally identifiable information (such as name, title, company name, address, telephone number, or e-mail address) that is voluntarily provided through our website or e-mail correspondence. We will collect general information (such as the type of browser used, the files requested, and the domain name and country which requests information) to improve our Web site and better meet customer needs.

Use of Information
Before we collect any personally identifiable information, we will provide an explanation for the possible use of the data. The information supplied will be used by Vitalyst, LLC to respond to inquiries, supply requested information on Vitalyst, LLC products and services, or track inquiries placed with Vitalyst, LLC. Authorized third parties may be utilized by Vitalyst, LLC to collect, track and process such information. If you have submitted personal information to Vitalyst, LLC electronically and would like it removed or modified, please contact us at We will use reasonable efforts to comply with your request.

External Information Sources (Customer Data)
Your privacy is critically important to us. It is Vitalyst’s policy to respect your privacy and comply with any applicable laws and regulations regarding any personal information we may collect from you in the course of providing support or training services.

During the course of providing support or training services, we may ask for personal information which may include, but is not limited to, one or more of the following:

  • Name
  • Email Address
  • Telephone Number

We only collect and use your personal information for the purpose of providing services to you and do not share or sell your personal information to any third parties.
If you have any questions or concerns about the data collected from you while utilizing our services, please contact us at so that we can address your concerns.

Internal Information Sources (Employee Data)
Vitalyst, LLC is the sole owner of the information collected from its employees and applicants for employment. Vitalyst, LLC will not sell or share this information with third parties in ways different from what is disclosed in this privacy policy statement. Vitalyst, LLC only collects personal data that is relevant and necessary for legitimate human resources business functions. Personal information collected by Vitalyst, LLC from employees and applicants for employment is maintained at its corporate offices. Among other things, Vitalyst, LLC collects and maintains personal information on current and former employees for legitimate corporate business purposes, such as processing payroll, collecting resumes to fill vacant positions, and maintaining accurate benefits records.

Vitalyst, LLC does not request or gather any information regarding political opinions, religion, philosophy, union membership, or sexual preferences. To the extent Vitalyst, LLC maintains information on an individual’s medical health or ethnicity (as legally required of U.S. employees and US applicants for employment), consistent with this policy, Vitalyst, LLC will not disclose such information to third parties.

Vitalyst is frequently hired or contracted by Microsoft to provide components of the Adaptive Learning product, customer service support or other assistance (collectively, the ” Contracted Services”) on behalf of Microsoft Corporation (“Microsoft”).  In such cases, Vitalyst must abide by Microsoft’s data Privacy Policy and is not permitted to use personal data it receives from you or from Microsoft in the course of delivering those Contracted Services for any other purpose other than delivering those Contracted Services.  If Vitalyst is performing Contracted Services for you, please review the Microsoft Privacy Policy in detail at:

Vitalyst, LLC is committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorized access and destruction. Vitalyst, LLC takes all reasonable precautions to safeguard the confidentiality of personally identifiable information.

Other Important Information
The Vitalyst, LLC Web site may contain links to other sites. We do not endorse or otherwise accept responsibility for the content or privacy policies of those sites. Additionally, some of our Web pages may contain “cookies,” which are data that may be sent to your Web browser and stored on your computer. This allows our server to “recognize” you when you visit our Web site in the future and enables you to view protected content without requiring an additional login, password, or re-registration. Most Web browsers can be configured to not accept cookies, or to notify you if a cookie is sent to you.

EU, UK, and Swiss Personal Data; Privacy Shield
This section applies to personal data collected from or about data subjects in the European Union, the United Kingdom or Switzerland. If you are located in the European Economic Area or in Switzerland, then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”), and the following additional information is applicable to you.

When you communicate with us on behalf of your employer, such as by accessing our website or using our helpdesk or online training services, we collect personal data about you.  Vitalyst, LLC is a processor of your personal data, and your employer is the controller of your personal data. 

In the event of any conflict(s) between the terms of this Privacy Policy and the terms of your employer’s contract with us, the terms of the contract with your employer control with respect to the subject matter in conflict.

If you wish to contact us about our processing of your personal data, you can contact us at: Vitalyst, LLC, One Bala Plaza, Suite 434, Bala Cynwyd, PA 19004 or at

Lawful Basis
You hereby consent to the processing of your personal data as described in this Privacy Policy, including the transfer, use, and storage of your personal data in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country.  You may withdraw your consent at any time by following the instructions in the Accessing/Updating/Deleting Your Personal Information section below, but this will not affect the lawfulness of processing based on consent before its withdrawal.  However, if you withdraw your consent or decline to provide personal data to us, you may be unable to use the services.  You have the right to file a complaint relating to the processing of personal data with a supervisory authority.

Categories of Personal Data
We may collect the following from or about data subjects:

  • Name (first and last);
  • Business email address;
  • Business phone number;
  • HTTP header information, including IP address;
  • Information about your use of our services; and
  • Any information included in files or emails provided to us.

Use and Disclosure of Personal Data
We process personal data to provide, secure, and improve our helpdesk, training, and related services for the benefit of the data controller.  This processing is in accordance with the data controller’s instructions, including in our contract with the data controller.  We remain liable in cases of onward transfer of personal data received under Privacy Shield to third parties (subprocessors). Additionally, we may use and disclose personal data in order to comply with the GDPR or applicable law, such as to respond to a data subject’s rights requests or in response to lawful requests from public authorities, including national security or law enforcement requirements.

Also, with your employer’s consent, we disclose personal data to subprocessors to assist in providing the services and to help us manage our customer relationships. Subprocessors that we may share personal Data with are as follows:

Knowledge Accelerators (Partner) – Contact Information for the purpose of identification and authentication

Salesforce (Vendor) – Contact Information for the purpose of facilitating and continuing contact

Accessing/Updating/Deleting Your Personal Information
If you would like to delete, update, or access the personal data we have collected from you, you should send an email to [].  Additionally, if your personal data is subject to the GDPR, you may have certain additional rights, including the right of restriction of processing of personal data, and the right to object to the processing of personal data.  Please send an e-mail to [] for more information.

Privacy Shield Notice
We are a participant in European Union (“EU”)–United States (“US”) Privacy Shield and Switzerland (“Swiss”)–United States (“US”) Privacy Shield (together, “Privacy Shield”). We comply with the Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries, the United Kingdom, and Switzerland. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between this Privacy Policy and these Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

The types of data we are collecting under Privacy Shield, the purposes for which each such type of data is being collected and used, and the types of third parties to which we may disclose such information (and the purposes of such disclosure) are set forth in this Privacy Policy.

You have rights, as set forth in this Privacy Policy, to access, edit and have deleted your personal data. The choices and means offered you for limiting use and disclosure of your personal data are set forth in this Privacy Policy.

In compliance with the Privacy Shield Principles, we commit to work to resolve complaints about your privacy and our collection or use of your personal data. European Union or Swiss data subjects with inquiries or complaints regarding this Privacy Policy should first contact us at:

Vitalyst, LLC
One Bala Plaza
Suite 434
Bala Cynwyd, PA 19004

We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to the American Arbitration Association. If you do not receive a response to your complaint from us within forty-five (45) days, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint.

Please note that if your complaint is not resolved through the above channels, you may have the right, under certain limited conditions, to invoke binding arbitration before the Privacy Shield Panel to be created by the US Department of Commerce and the European Commission.

We are subject to the investigatory and enforcement powers of the United States Federal Trade Commission (“FTC”) with respect to our compliance with Privacy Shield.

Copyright Notice and Terms of Use
Permission to use Documents (such as service or product information, press releases, case studies, webinars, fact sheets and FAQs) from this server is granted, provided that the Vitalyst, LLC copyright notice appears in all copies, (2) use of such Documents from this server is for informational and noncommercial or personal use only and will not be copied or posted on any network computer or broadcast in any media, and (3) no modifications of any Documents are made.

Use for any other purpose is expressly prohibited by law, and may result in severe civil and criminal penalties. Violators will be prosecuted to the maximum extent possible.

All information on this server is provided on an as-is basis. Vitalyst, LLC makes no warranties, express or implied, as to the accuracy and correctness of the information. In no event shall Vitalyst, LLC be liable for any damages whatsoever resulting from the use of this information.

Vitalyst and the Vitalyst logo are trademarks of and Vitalyst, LLC is a registered trademark of Vitalyst, LLC. All other products are trademarks and registered trademarks of their respective companies.

Vitalyst, LLC reserves the right to modify this privacy policy at any time. We will promptly reflect any such modifications in these web pages.

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