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Privacy.

To guarantee the privacy of our client’s users, we maintain the following guidelines with regard to privacy.

Starting points

The conditions on privacy, security and personal information in the ICT Office conditions, module General and module 4 Application service provision, software as a service and computerservice, deposited at the Chamber of Commerce on the 14th of january 2009 under the number 30174840, apply to the personal data processing by TrainTool for the benefit of the purchaser. Notwithstanding what has therein been decided, both parties agree to the following:

  1. TrainTool acts as processor in the sense of the law of protection of personal information (Wbp). Therefore, the responsibility for these personal data that are processed by use of a service provided by TrainTool lies with the purchaser.
  2. TrainTool takes fitting technical and organisational measures to protect the issued personal data for the benefit of the purchaser against loss or any form of unauthorized processing.
  3. TrainTool provides the purchaser its full cooperation to (i) give the purchaser’s users of TrainTool’s provided service insight into their personal data, (ii) let the purchaser’s users of TrainTools’ provided service delete or correct personal data, and/or (iii) show the purchaser’s users of TrainTool’s provided service that personal data have been deleted or corrected if they are incorrect or, when the purchaser disagrees with the user’s standpoint, determine that the person involved regards his or her personal data as incorrect. TrainTool will not cooperate without having informed the purchaser on this matter.

Privacy Statement as service

We facilitate our purchasers by maintaining the following Privacy Statement as a basis, with the possibility to adapt it to the purchaser’s wishes.

Privacy Statement between purchaser and user, with TrainTool as processor

1. General

1.1 Purchaser is responsible for processing the users’ personal data. By using the TrainTool domain for online training and testing as user, and/or supporting an online training and tests, as well as monitoring those as Coach, Administrator or Content Developer, on behalf of the purchaser, personal data will be processed. This Privacy Statement describes how this works.

1.2 By agreeing to this privacy statement - and with it, the conditions for data processing - User gives explicit consent for this data processing. If User does not agree to this privacy statement, he or she is requested not to use the domain and notify the purchaser.

2. Definitions

2.1 Administrator: an Administrator has all the rights to, within the domain, (i) create, edit or delete Users (in every role), (ii) compose and view reports on Users within the domain.

2.2 Coach: a Coach has been assigned to one or several Participants by Administrator. Dependent on how Administrator has set it up, Coach is allowed and able to monitor (observe), give feedback and assess a user’s training and/or test.

2.3 Content Developer: a Content Developer is allowed to make, edit and delete trainings within the domain.

2.4 Participant: a Participant is enrolled within the domain to do an online training or test, and is allowed to use the domain.

2.5 Domain: The domain that has been made available for Purchaser by TrainTool for online training and testing. This domain can be recognised by the URL (domain.traintool.com) and the lay-out. All the users’ data and their trainings can be consulted (only) within this domain.

2.6 User: a User is linked to the domain and is able to log in with an e-mail address and password, that have to be unique to this domain. User has one of following roles as minimum and all of the following roles as maximum: Participant, Coach, Administrator and Content Developer.

2.7 Privacy statement: this privacy statement.

2.8 Purchaser: [to be entered] Contact person: [to be entered].

(Personal) data processing

3.1 Purchaser, mediated by TrainTool, collects personal data of User that has been issued by that particular User in the context of an online training or test as User, and/or support of an online training and test, as well as monitoring as Coach, Administrator or Content Developer. This collection occurs when, for example:

3.1.1 Administrator makes an account for User, which is only allowed for Administrator for the benefit of Purchaser, and authorises access to the domain for that particular User as Participant, Coach, Administrator and/or Content Developer;

3.1.2 User enrolls him or herself and/or participates in a training and/or test;

3.1.3 Participant shares camera recordings (by webcam or mobile camera) and/or audio recordings of an online training and/or test with his or her Coach or feedback group;

3.1.4 Participant asks his or her Coach or feedback group for feedback, or receives feedback from his or her coach or feedback group;

3.1.5 Participant asks his or her Coach for assessment, or receives assessment from his or her Coach;

3.1.6 Participant gives feedback to another Participant in his or her feedback group;

3.1.7 User asks TrainTool for support in using the domain;

3.1.8 Administrator of the domain asks for a report on the participation, progress and performance by the Participant concerning an online training and test.

3.2 The issued personal data that are processed by TrainTool, commissioned by Purchaser, (and are issued by oneself or concerning oneself by the Purchaser’s Administrator or other Users) are:

3.2.1 data that need to be issued to use the Domain as User in order to do an online training and/or test, which are: (a) first and last name, (b) e-mail address, (c) personal password, (d) name of employer and/or training bureau, as well as position and location of employer, (e) name of the training(s), corresponding feedback group, Coach, Administrator and Content Developer, (f) camera footage or audio recordings (of a training that has been undertaken and saved by User), (g) information about the participation, progress and performance of an online training and test, like (i) issued answers on training questions, (ii) time use, (iii) extent and manner of feedback given to peers, as well as (iv) feedback and assessment issued by Coach.

3.2.2 data that may be issued to use the Domain as user in order to do an online training and test by issuing these data actively within their own online profile, which are, (a) phone number and (b) photograph.

3.3 The issued personal data are only processed by TrainTool, commissioned by Purchaser, in order to execute its service on behalf of the Purchaser, being: developing, facilitating, maintaining and optimising an online training and test platform for the Participant’s skills, as well as supporting the Participant’s use of that platform. More specifically, a focus on the practicing of soft skills by Participant with feedback from Coach and other Participants from his or her feedback group as well as making the level of the Participant (on an individual, group, or corporate level or anonymised for the corporate sector) transparent through reports.

Optional: 3.4 TrainTool can also use the collected personal data to inform Users of a domain, on behalf of Purchaser, of TrainTool’s products, services and/or activities that might be interesting for the particular User. If the User objects to this, he or she can contact Purchaser or TrainTool on support@traintool.com.

Optional: 4. Report

4.1 Purchaser registered their data processing with the Data Protection Authority, under report number [FILL IN].

Optional: 5. Minors

5.1 The Domain has not been designed for minors (meaning persons younger than sixteen). Minors are only allowed to register as User with their parents’ or custodian’s consent. The parent or custodian is allowed in this case to edit or delete data issued to the Purchaser on the Domain.

6. Sharing by participants

6.1 Participant can, during participation in an online training and test within the Domain, decide to share the (intermediate) results of an online training and test, like camera footage of an online training and test that have been undertaken and saved by User, as well as answers to other quesions or exercises, with someone in his or her feedback group, Coach, Administrator or TrainTool for technical support. This issued information can be viewed by these third parties. Those who choose to share particular information, should be aware that that information can be used by the third party in other unknown ways. This is beyond TrainTool’s responsibilities.

6.2 Participant is able to view issued results of an online training and test of other Participants if another Participant has explicitly shared them in order to receive feedback. Participant will not use these results and any other connected information in any other way than to give feedback within the domain. Other usage within the Domain or outside of the Domain is not allowed.

7. Other transfer to third parties

7.1 Purchaser has enabled TrainTool as editor for the purposes explained in this Privacy Statement under 3.3 and 3.4, with whom Purchaser has agreed that TrainTool offers guarantees concerning technical and organisational security measures concerning the processing.

7.2 TrainTool uses cloudcomputing to execute its service to Purchaser, where it engages (sub)editors for the encrypted storage of personal data of Users on servers within the European Union, with whom an agreement was made. This agreement also offers enough guarantees for technical and organisational security measures concerning the processing.

7.3 TrainTool nor Purchaser will issue the Users’ personal data for other purposes, except when the User has agreed to this, when it is necessary for TrainTool’s execution of its service, like issuing data to an external Coach, on the basis of a legal regulation or in an emergency, as long as this is of importance for the User, according to the reasonable judgement of Purchaser.

8. Security

8.1 TrainTool has, on behalf of Purchaser, taken fitting technical and organisational measures to protect the Users’ issued and collected personal data against loss or unauthorized processing, including acces to the Domain via an individual login based on a unique e-mail address and password as well as via secured SSL connections. Despite the fact that TrainTool, on behalf of Purchaser, has taken and will take fitting security measures, there are risks linked to the processing of personal data on the internet, that are unfortunately inherent to internet use in social traffic.

9. Retention period

9.1 TrainTool does not retain the Users’ personal data within the Domain any longer than necessary for the execution of its service. The User’s personal data are deleted when TrainTool is ordered to do so by Purchaser, for example, after Participant’s employment with Purchaser has been ended. However, at maximum twelve months after [the first enrolment] for an online training or test, the User’s personal data are blocked and cannot be consulted by the particular Participant and his or her Coach, Administrator and/or Content Developer.

10. Inspection and correction

10.1 The User is allowed to view his or her collected personal data on the basis of the law of protection of personal information and, if necessary, to edit, add or delete them. In order to do so, one can consult his or her own profile within the Domain, as well as sending a request to Purchaser.

11. Cookies (general)

11.1 TrainTool uses ‘cookies’ in order to execute its service for Purchaser. Cookies are small text files that are saved by a computer if the Domain is visited. The cookie remembers what the User has filled in on the Domain for a next visit, like the chosen language, so that the content of the Domain can be specified to the specific User and therefore it is not necessary to fill in those personal data again.

11.2 TrainTool uses Google Analytics in order to execute its service for Purchaser. Google Analytics is a webanalysis service that is supplied by Google, Inc. (“Google”). Google Analytics also uses cookies to analyse how the Users use the Domain.

OPTIONAL 11.3 Purchaser has added the anonymise function to its Google Analytics configuration, resulting in the fact that no full IP addresses are sent to Google: the last octet of the IP address will be deleted, making tracking on an individual level technically impossible.

11.4 Google uses aforementioned information to track how Users use the Domain, to report on this to TrainTool and to offer other services concering internet use. Google is allowed to issue this information to third parties if Google is legally obliged to do so, or to the extent that these third parties process this information on behalf of Google. The information is transferred to and saved by Google on servers in the United States. Google states that it will comply to the privacy regulations that are applicable there, which it is responsible for. This means that there would be a fitting level of security for (personal) data processing.

OPTIONEEL 12. Social networks

12.1 There are buttons on the Domain to promote or share [websites, feedback, etc.] on social networks like LinkedIn, Facebook and Twitter (“Social networks”). These buttons function with pieces of code that originate from these social networks. Cookies are placed through these codes. TrainTool (and Purchaser) does not have influence on this. Users are requested to read the privacy statements of social networks (that can change frequently), to see what they do with the personal data that they process through these cookies.

12.2 The information that the social networks collect is transferred to and saved by the social networks on servers in the United States. The social networks state that they will comply to the privacy and cookie regulations that are applicable there. This means that there would be a fitting level of security for any personal data processing.

OPTIONAL 13. Links to third party websites

13.1 It is possible that the Purchaser’s Content Developer has placed links to websites of third parties that TrainTool has no insight in. When Users visit these websites, the privacy statements of these third parties apply. TrainTool (and Purchaser) are not responsible for the way Users’ personal data are used through these websites.

14. Edits

14.1 Purchaser is allowed to edit this Privacy statement. Therefore Users are recommended to check this Privacy Statement regularly. Continuous use of the Domain means that Users agree to the Purchaser’s edited Privacy Statement.

OPTIONAL 15. Contact

15.1 In the case of questions or notes concerning this Privacy Statement or any other aspect of our services, the Purchaser can be contacted via [to be filled in] or TrainTool via support@traintool.com.