WORKPLACE LEARNING SYSTEM (WLS) PRIVACY STATEMENT
The protection of personal data is highly important to Workplace Learning System (WLS). This Privacy Statement serves to inform visitors to the website of WLS (“User(s)”) about the processing of personal data (hereinafter also “Data”) that takes place on the websites of WLS subject to the applicable data protection laws, in particular Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”).
Workplace Learning System may be reached by email at info@workplacelearningsystem.com or by mail at:
Workplace Learning System
206 College Street, Suite 236
Pineville, NC 28134
1. Controller of data processing
WLS is the controller of the lawful processing of Users’ personal data.
2. Data processed and purposes of processing
2.1 Usage data
When the WLS website (www.safety-culture-training.com) is accessed, the servers automatically store certain data of the accessing system. This includes the type of browser used, the browser version, the operating system used, the website from which the WLS website was accessed, the controlled subpages of the WLS website, the date and time of access, the internet protocol address (IP address), the internet service provider and data comparable with the above list.
WLS uses this data to make the websites available, to detect and remove possibly occurring technical problems and to prevent and, if need be, prosecute any abuse of the WLS website and/or servers. WLS also uses this data in anonymized form, i.e. without being able to identify the user, for statistical purposes and in order to improve the website. The legal basis for processing personal usage data is Article 6(1), first subparagraph, point (f) GDPR.
2.2 Use of cookies
The WLS website uses cookies (“Cookies”) to distinguish you from other users of the website. Cookies are small text files that are stored on the User’s data carrier and exchange certain settings and data with the system of WLS via the browser. A cookie normally contains the name of the domain from which the cookie data are sent and information on the age of the cookie and an alphanumerical identifier. Cookies enable WLS to design the website attractively to the User and also facilitate use by, for example, storing certain input such that it need not be entered repeatedly. The information stored in the cookies is not used to identify the User and is not combined with other personal data stored about the User. The legal basis for processing personal data is Article 6(1), first subparagraph, point (f) GDPR.
These Cookies help us to provide you with a good experience when you browse our websites and also allow us to improve our sites. By continuing to browse the sites, or by submitting any forms on our sites, you are agreeing to our use of Cookies.
We use the following types of Cookies:
Strictly necessary Cookies. These are Cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website and to customize your account profile.
Analytical/performance Cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our websites when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.
Functionality Cookies. These Cookies are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting Cookies. These Cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Users may deactivate or restrict the transfer of cookies by changing the settings on the internet browser. Cookies already stored may be erased at any time. This may also be done by automatic means. Should cookies for the websites of ELS be deactivated, it may be the case that not all functions of the websites can be fully used.
2.3 Google Analytics
The websites of WLS also use functions of the web analysis service Google Analytics provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”). Google Analytics likewise uses cookies. The information generated by the cookie about the use of this website is as a rule transmitted to a Google server in the USA where it is stored.
The websites of WLS use Google Analytics with the additional component “anonymize IP”. This means that the IP address of the User collected by the Google Analytics cookie will be shortened by Google beforehand within Member States of the European Union or in other signatory states of the Treaty on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.
Google uses the information generated by the Google Analytics cookie on behalf of WLS in order to evaluate the use of the website, prepare reports on the website activities and to provide WLS with additional services associated with the use of the website and the internet. The IP address transmitted by the browser of the accessing system as part of Google Analytics will not be combined with other Google data. More detailed information on the conditions of use and data protection is available at http://www.google.com/analytics/terms/de.html or at http://www.google.com/intl/de/analytics/privacyoverview.html. The legal basis for processing personal data by using cookies is Article 6(1), first subparagraph, point (f) GDPR.
The User can prevent Google from collecting the data generated by the cookie and pertaining to the use of the website or from processing this data by downloading and installing the browser plugin available via the following link: https://tools.google.com/dlpage/gaoptout?hl=en . WLS does however point out that in this case not all functions of the website may be fully used. The User may also prevent data being collected by Google Analytics by clicking on the following link. In this case an opt-out cookie is set that prevents User data being collected upon future visits to the websites of ELS: Google Analytics deaktivieren. Users may also deactivate or restrict the transfer of cookies by changing the settings on the browser. Cookies already stored may be erased at any time. This may also be done by automatic means. Should cookies for this website be deactivated, certain website functions may no longer be usable. Should Users only wish to accept cookies from WLS but not cookies from the service providers and partners of WLS, they may select the “block cookies from third party providers” (or similar) settings on their browsers.
2.4 Further web analysis tools
The following plug-ins are available on this website: Facebook, LinkedIn, Vimeo, YouTube, Twitter, Google+. If you click on a plug-in, you will be directed to WLS’s company page on the applicable social media site. For example, if you click on the Facebook plug-in, you will be directed to WLS’s Facebook page. Please understand that WLS does not control, and this policy does not apply to, these third party sites. We recommend that you read the privacy policies on any external site you visit.
The WLS website also uses Sumo, an analytics tool that tracks clicks/touches, mouse movement, scroll, keystroke, and other meta data. You may opt out of this tracking by visiting https://www.sumologic.com/privacy-statement/ .
2.5 Data transferred in the course of making contact
There are multiple areas on our website that allow you to request printed and/or digital information from WLS. If you request any of this information, then we will ask for your name, email address, and/or mailing address. If you request printed material, we will use your personal data to mail the materials to you. If you request digital information, we will use your personal data to email the materials to you. WLS does not share this personal information with anyone who is not necessary to the information request. The legal basis for processing the data outlined above, depending on the content of the respective contact-making, is Article 6(1) subparagraph 1 point (b) respectively (f) GDPR.
2.6 Newsletter
WLS’s websites provide Users with the option to subscribe to a newsletter and to consent to the processing of personal data necessary for this. In order to register for the newsletter you must provide an e-mail address. Additional information such as your organization and job title can be provided on a voluntary basis. These data are exclusively used in order to send the newsletter and are not transferred to third parties. The date and time of registration and the e-mail verification are also collected at registration. These data are exclusively processed for the purpose of identifying the possible abuse of an e-mail address. We will not send email newsletters unless you specifically “opt-in” by checking the “create new account” box under the contact form. You may opt out of these communications at any time by either emailing info@workplacelearningsystem.com or clicking the unsubscribe link in any email. The legal basis for processing the data outlined above is Article 6(1) subparagraph 1 point (a) GDPR. The User has the right to withdraw his consent at any time without prejudice to the lawfulness of the processing carried out based on the consent prior to his withdrawal.
3. Transfer of data to external parties
WLS receives assistance from outside service providers for certain technical data analysis, processing or storage processes (e.g. to obtain aggregated, non-personal statistics from databases or for the storage of backup copies). These service providers are carefully selected and meet high data protection and data security standards. They are obligated to maintain strict confidentiality and process personal data only when commissioned to do so by WLS and according to WLS’s instructions. The legal basis for the involvement of such service providers is Article 28 GDPR.
Except in the cases set out in this Privacy Statement, WLS only transfers data to third parties without the User’s explicit consent if so obliged by law or by administrative or judicial directive.
4. Place of data processing
The WLS website is hosted by EPIC of Wisconsin, Inc., 300 S. 6th Ave., West Bend, WI 53095 U.S.A. EPIC maintains the Data collected through WLS’s website (including Cookies) on its servers located in the United States. Access to the Data is limited to employees of ELS and EPIC. Pursuant to Article 46 GDPR, WLS and EPIC have entered into standard data protection clauses to provide appropriate safeguards regarding the transfer of Data outside the EU.
5. Storage period
Usage data will be stored for so long as it is required for the described purposes or until a User has revoked consent, provided statutory provisions do not stipulate a longer retention period.
6. Rights of the Users
Users requesting detailed information on the processing of personal data concerning them may contact WLS at any time. They may also ask to receive in structured, commonly used and machine-readable format the data which they have provided to WLS or for such data to be transferred to a third party. Should the Users establish that the data stored about them is incorrect or incomplete, they may at any time require the immediate rectification or completion of such data. Subject to the preconditions set out in Articles 17 and 18 GDPR, the User may also require the erasure or restriction of processing of personal data. Users also have the right to lodge a complaint with the competent supervisory authority for WLS.
7. Contact information
The User may contact WLS at any time regarding questions concerning WLS’s processing of personal data and the exercise of rights to which the User is entitled against such processing. To do so it is sufficient to contact info@workplacelearningsystem.com or the address listed in the opening paragraph of this Privacy Notice.
Updated May 25, 2018
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