VeraSafe Privacy Training Portal Privacy Notice

Last Updated: October 4, 2016

Scope of this Notice

This privacy notice (hereinafter, the “Notice”) addresses data subjects whose personal data (“PII”) Advanced Partnerships LLC (“us”, “we,” “our,” or “VeraSafe”) may receive or otherwise process in our hosted learning management platform, the “Platform”. This Notice does not apply to the VeraSafe publicly accessible website, the employees of VeraSafe, or to any PII we collect outside of the Platform.

With respect to the PII processed in the Platform, VeraSafe is a data processor. The organization or natural person who is licensed by VeraSafe to use the Platform is the data controller.

EU-U.S. Privacy Shield Framework

Advanced Partnerships LLC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the processing of personal data (“PII”). Advanced Partnerships LLC has certified that it adheres to all applicable provisions of the Privacy Shield Framework, including the Privacy Principles, the Supplemental Principles, and Annex 1 of the Framework. To learn more about the Privacy Shield program, and to view Advanced Partnerships LLC’s certification, please visit https://www.privacyshield.gov/list.

U.S.-Swiss Safe Harbor Framework

Advanced Partnerships LLC complies with the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of PII from Switzerland. Advanced Partnerships LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Advanced Partnerships LLC’s certification, please visit http://www.export.gov/safeharbor/.

Confidentiality

Except as described by this Notice, we maintain the PII processed in the Platform in confidence.

Categories of PII

The Platform is designed to process the basic contact information and basic professional information (such as job title or position) of trainees and training administrators. However, the Platform has user-customizable fields, which allow training administrators to process any category of PII.

Collection of PII

Training administrators typically submit the PII of trainees to the Platform. We also automatically collect your IP address when you participate in training modules or otherwise access the Platform.

Purposes of Use

We collect and use PII for the purposes of providing the Platform and its features to our licensees at their instruction, processing PII on behalf of licensees, providing aggregate information regarding our Platform to prospective licensees, and conducting related tasks for legitimate business purposes.

We process the PII of trainees on the basis of the need for a licensee to comply with a legal obligation to which it is subject, or alternatively, on the basis of the legitimate interests pursued by a licensee, such as the need for a licensee to provide its employees with data protection and cybersecurity training and awareness material.

Disclosure

We may disclose your PII:

  • to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders; or
  • if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; or
  • to our vendors, if necessary, in order to provide you with service as further described in the section below.

If we must disclose your PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PII will maintain the privacy or security of your PII.

Onward Transfer to Data Processors

We may use third party vendors to perform certain services on our behalf, such as those:

  • hosting the Platform;
  • delivering emails sent from the Platform; and
  • maintaining, enhancing, or adding to the functionality of the Platform.

We may share your PII with these third party vendors solely to enable them to perform their respective services for us. We require that those third party vendors maintain at least the same level of data protection that we maintain for such data. VeraSafe remains liable for the protection of your PII that we transfer to our subprocessors. Please note that some of our vendors process your data outside of the United States.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about our Platform users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

Data Integrity & Security

VeraSafe employs technical, administrative, and physical measures that are reasonably designed to help protect PII that we process from loss, unauthorized access, disclosure, alteration, destruction, or other processing.

Data Retention

PII that is processed in the Platform is retained for as long as is necessary for us to perform our obligations under the contract entered into between the licensee and us. When such contract expires or is otherwise terminated, all PII controlled by that licensee, and processed within the Platform, will be deleted from the Platform within 90 days. Please note that we keep backup copies of our databases as part of our disaster recovery/business continuity plans, and it may not be reasonably possible to delete data from such backups.

Access, Review & Opting Out

If you are a data subject of PII that was submitted to the Platform by a licensee and wish to exercise your rights with regards to such PII, please contact the licensee that provided your PII to us.

Privacy of Children

The Platform is not directed at, nor intended for use by, children under the age of 13 and children under the age of 13 are prohibited from using the Platform. If you believe that PII pertaining to your under-13-year-old child has been submitted to the Platform, and you would like to exercise your rights with regards to such PII, please contact the licensee who submitted the PII to the Platform.

Changes to This Notice

We may update this Notice from time to time by posting a new version on this web page. When we make a material change to the Notice, we will update the Last Updated date above to reflect the effective date of the most recent version of the Notice.

Contact & Dispute Resolution Process

If you have a complaint, dispute, or question regarding this Notice or our processing of your data, please write to our privacy officer by email at privacy_notice@verasafe.com or by postal mail at:

Attn: Privacy Officer, Advanced Partnerships LLC
22 Essex Way, #8203
Essex, VT 05451
USA

You may also contact us by phone at our customer support number 1-888-376-1079 (or if calling from outside the U.S., dial +1-617-398-7067).

We will respond to your inquiries within 30 days of receipt.

Dispute Resolution under the EU-U.S. Privacy Shield and U.S.-Swiss Safe Harbor Frameworks

If a complaint or dispute cannot be resolved through VeraSafe’s internal process, VeraSafe has agreed to cooperate with the EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner and to participate in the dispute resolution procedures of the panel established by the EU data protection authorities and the Federal Data Protection and Information Commissioner, respectively.

Binding Arbitration

If your dispute or compliant cannot be resolved by VeraSafe, nor by the panel established by the EU Data Protection authorities (or the Federal Data Protection and Information Commissioner, if applicable) or through the Department of Commerce, you may have the right to require that VeraSafe enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.

Regulatory Oversight

Advanced Partnerships LLC is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Privacy Notice
VeraSafe Privacy Training 1.4