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Elearning Experts (en) - Política de Privacidad y Puerto Seguro 05-ago-2017 | 95%
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0 Terms and Conditions Terms and Conditions
1 Note Updated Service Agreement and Terms of Service for 2017 Note Updated Service Agreement and Terms of Service for 2017
2 Elearning Experts Service Agreement – January 2017 Elearning Experts Service Agreement – January 2017
3 Elearning Experts Terms of Service for Moodle Clients – January 2017 Elearning Experts Terms of Service for Moodle Clients – January 2017
4
5 Subscription-Agreement – USA Via Totara Partner – May 2013 Subscription-Agreement – USA Via Totara Partner – May 2013
6 Elearning Experts Universal Terms of Service for TotaraLMS Clients – January 2017 Elearning Experts Universal Terms of Service for TotaraLMS Clients – January 2017
7 TotaraLMS Security FAQs 2017 TotaraLMS Security FAQs 2017
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9 Elearning Experts – Support FAQ July 2013 Elearning Experts – Support FAQ July 2013
10 Service Provider Security Questions Service Provider Security Questions
11 Legal Legal
12 Moodle is open source software provided freely under the GNU General Public License. Moodle™ is a registered trademark of the Moodle Trust. Elearning Experts LLC is an authorized Moodle™ Partner . But don’t confuse us with Moodle Pty Ltd., or the Moodle Trust. Moodle is open source software provided freely under the GNU General Public License. Moodle™ is a registered trademark of the Moodle Trust. Elearning Experts LLC is an authorized Moodle™ Partner . But don’t confuse us with Moodle Pty Ltd., or the Moodle Trust.
13 Privacy Policy Privacy Policy
14 We self-certify compliance with : We self-certify compliance with
15 Policy
16 Established January 21, 2012
17 Updated April 1, 2016
18 I. PURPOSE
19 Elearning Experts LLC complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Elearning Experts 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 Elearning Experts LLC’s certification, please visit http://www.export.gov/safeharbor/
20 II. SCOPE
21 This Policy applies to all current clients of Elearning Experts LLC and any of its US and non-US subsidiaries and divisions (collectively, Elearning Experts LLC “services”.)
22 III. DEFINITIONS
23 “Agent”, means any third party that processes, collects, or uses Personal Information pursuant to the instructions of, and solely for the benefit of, Elearning Experts LLC, or to which Elearning Experts LLC discloses Personal Information for use on its behalf.
24 “Personal Information”, means information that can directly or indirectly lead to the identification of a living person, such as an individual’s name, e-mail, or other identifying characteristic. Personal information does not include information that has been made anonymous, encoded or otherwise stripped of its identifiers, or information that is publicly available, unless combined with other non-public personal information.
25 IV. SEVEN PRINCIPALS OF SAFE HARBOR
26 1. NOTICE
27 The following is our disclosure of how Elearning Experts LLC collects and uses personal information; any third parties to which we may disclose that information; how you can access your information and restrict our use of it; and how to contact us with any questions or complaints about how we use your information.
28 Any personal information sent to us by our clients is used exclusively for the purposes and services for which we contracted. We do not share, transmit, rent or sell that information to any other parties.
29 We may collect personal information such as name, title, firm, address, e-mail address, and survey results from individuals who have requested information from us or expressed interest in our products and services. You may provide this information to us electronically, over the Internet, or physically. Your personal information will be used by Elearning Experts LLC exclusively for the purpose of providing and improving service to you, or informing you of additional products and services which we think will be of interest to you.
30 Other information gathered through this site is purely statistical, such as what Web pages are visited most often. This information is useful to Elearning Experts LLC, and enables us not only to improve and upgrade our services but also to refine our product lines and marketing. This information is anonymous in nature.
31 We do not collect sensitive information (e.g., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual).
32 2. CHOICE
33 If you request information from us, you will be given the choice at that time to opt out of receiving future communications from us on information, products, or services that may be of interest to you.
34 If you have provided us with your personal information in the past, and you do not wish to receive further communications of information, products, or services from us, you can opt out, by sending and email to: privacy@elearningexperts.net.
35 If you provide personal information to us as part of a service we provide to you or your organization, we do not share, transmit, rent or sell that information to any third parties.
36 3. ONWARD TRANSFER
37 Elearning Experts LLC only shares personal information with other companies or individuals outside of Elearning Experts LLC in the following limited circumstances:
38 We Have Your Consent. We require opt-in consent for the sharing of any sensitive personal information.We provide such information to offices, subcontractors or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures.We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; or (d) protect against imminent harm to the rights, property or safety of Elearning Experts LLC, its users or the public as required or permitted by law.
39 4. SECURITY
40 Elearning Experts LLC employs considerable precautions within the company — including physical, electronic, and procedural safeguards — designed to secure the privacy of all personal information we retain, and protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction.
41 Elearning Experts LLC does not require or store any personal information from clients other than email address, name, phone numbers, fax numbers, business address, and contact name.
42 Cookies. When you visit Elearning Experts LLC, we may send one or more cookies (a small file containing a string of characters) to your computer that uniquely identifies your browser. We use cookies to improve the quality of our service. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or indicate when a cookie is being sent. However, some Elearning Experts LLC features and services may not function properly if your cookies are disabled.
43 Log Information. When you use Elearning Experts LLC services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
44 User Communications. When you send e-mail or other communication to Elearning Experts LLC, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
45 Other Sites. This Privacy Policy applies to all Web sites and services that are owned and operated by Elearning Experts LLC. We do not exercise control over the site links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.
46 Restricted Access. We restrict access to personal information to Elearning Experts LLC employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution if they fail to meet these obligations.
47 5. ACCESS OF RECORDS
48 Upon an individual’s request, Elearning Experts LLC will offer clients reasonable access to their Personal Information and will afford clients a reasonable opportunity to correct, amend, or delete inaccurate information. If a client would like to access Personal Information maintained by the Elearning Experts LLC, the client should send an email to: privacy@elearningexperts.net.
49 For security purposes, the individual may need to provide the Elearning Experts LLC with various pieces of Personal Information to process the request. Elearning Experts LLC may limit or deny access to Personal Information where providing such access would be unreasonably burdensome or expensive under the circumstances or as otherwise permitted by the Safe Harbor Principles.
50 6. DATA INTEGRITY
51 Elearning Experts LLC utilizes tools to help ensure that the personal information we have is accurate, complete, current and relevant for the purposes for which it is to be used.
52 Elearning Experts LLC will take reasonable measures to ensure that Personal information is relevant for its intended use, reliable for its intended use, accurate, complete, and current.
53 7. ENFORCEMENT
54 Elearning Experts LLC is responsible for verifying that our Privacy Policy is accurate, comprehensive, prominently displayed, completely implemented, accessible, and in compliance with the safe harbor principles. The company is also responsible for employee training related to the Privacy Policy and periodic review to make sure the proper procedures and protections are in place.
55 If you have questions or complaints regarding handling of personal information, please send an email to: privacy@elearningexperts.net.
56 Any complaints or disputes that are not satisfactorily resolved by the Safe Harbor Compliance Committee can be referred to the European Data Protection Authorities for investigation and resolution.
57 Elearning Experts LLC reserves the right to update and revise this Privacy Policy at any time. You can determine if this Privacy Policy has been revised since your last visit by referring to the “Effective Date of Current Policy” date at the top of this page. Your use of our Site constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms the EU-US Privacy Shield
58 Policy
59 Established April 1, 2017
60 Updated August 4, 2017
61 Elearning Experts Privacy Shield Statement
62 V20170804
63 Elearning Experts LLC (“Elearning Experts LLC”) has adopted this Privacy Shield Policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that Elearning Experts LLC obtains from Customers.
64 Elearning Experts LLC complies with the US-EU Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Elearning Experts LLC has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov .
65 All Elearning Experts LLC employees who handle Personal Data from Europe or any other area are required to comply with the Principles stated in this Policy.
66 Capitalized terms are defined in Section 14 of this Policy.
67
68 I. SCOPE
69 This Policy applies to the processing of Customer Personal Data that Elearning Experts LLC receives in the United States concerning Customers who reside in Europe. Elearning Experts LLC provides online training software services to businesses.
70 This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
71
72 II. RESPONSIBILITIES AND MANAGEMENT
73 Elearning Experts LLC has designated an internal team to oversee its information security program, including its compliance with the Privacy Shield program. The internal team shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to privacy@elearningexperts.net .
74 Elearning Experts LLC will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Elearning Experts LLC personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Elearning Experts LLC has undertaken to protect Personal Data.
75
76 III. RENEWAL / VERIFICATION
77 Elearning Experts LLC will renew its Privacy Shield certification annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
78 Prior to the re-certification, Elearning Experts LLC will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, Elearning Experts LLC will undertake the following:
79 Review this Privacy Shield policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Customer Personal Data
80 Ensure that the publicly posted privacy policy informs Customers of Elearning Experts LLC’s participation in the Privacy Shield program and where to obtain a copy of additional information (e.g., a copy of this Policy)
81 Ensure that this Policy continues to comply with the Privacy Shield principles
82 Confirm that Customers are made aware of the process for addressing complaints and any independent dispute resolution process (Elearning Experts LLC may do so through its publicly posted website, Customer contract, or both)
83 Review its processes and procedures for training Employees about Elearning Experts LLC’s participation in the Privacy Shield program and the appropriate handling of Customer Personal Data
84
85 IV. COLLECTION AND USE OF PERSONAL DATA
86 Elearning Experts LLC provides various solutions to its Customers, which are predominantly business and educational institution customers, although individual consumers are not restricted from purchasing such products. Elearning Experts LLC may collect Personal Data from Customers when they purchase our products, visit our website, request information from us, or otherwise communicate with us.
87 The Personal Data that we collect may vary based on the Customer’s interaction with our website and request for our services. As a general matter, Elearning Experts LLC collects the following types of Personal Data from its Customers: contact information, including, a contact person’s name, work email address, work mailing address, work telephone number, title, and company name.
88 When Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.
89 For certain products, Elearning Experts LLC serves as a service provider to its Customers. In our capacity as a service provider, we will receive, store, and/or process Personal Data owned and/or controlled by our Customers, including information about their employees, clients, customers, agents, or other individuals. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of each particular Customer. The information that we collect from our Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Customer, and as otherwise requested by the Customer.
90 Elearning Experts LLC uses Personal Data that it collects directly from its Customers and Customers’ customers indirectly in its role as a service provider for the following business purposes, without limitation: (1) maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to a Customer); (2) satisfying governmental reporting, tax, and other requirements (e.g., import/export); (3) storing and processing data, including Personal Data, in computer databases and servers located in the United States; (4) verifying identity (e.g., for online access to accounts); (5) as requested by the Customer; (6) for other business-related purposes permitted or required under applicable local law and regulation; and (7) as otherwise required by law.
91
92 V. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
93 Except as otherwise provided herein, Elearning Experts LLC discloses Personal Data only to Third Parties who reasonably need to know such data. Such recipients must agree to abide by confidentiality obligations. Examples of Third Parties that may receive personal information include analysts or consultants that have been contracted on behalf of your employer (the Customer with which we are contracted) and will only be provided with advance written notice. All Third Parties receiving personal information must have a written confidentiality agreement in place between Customer and Third Party and Elearning Experts LLC and Third Party that meets or exceeds Privacy Shield standards.
94 Elearning Experts LLC may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Elearning Experts LLC may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Elearning Experts LLC and they must either: (1) comply with the Privacy Shield principles or another mechanism permitted by the applicable European data protection law(s) for transfers and processing of Personal Data; or (2) agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy. Elearning Experts LLC also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure.
95 Elearning Experts LLC may be forced to disclose an individual’s personal information when compelled by a request made by a recognized public authority or where required to meet national security and or law enforcement requirements.
96 In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Elearning Experts LLC is potentially liable. Elearning Experts LLC’s liability under this agreement will be governed by the contract in place between Customer and Elearning Experts LLC.
97
98 VI. SENSITIVE DATA
99 Elearning Experts LLC does not collect Sensitive Data from its Customers.
100
101 VII. DATA INTEGRITY AND SECURITY
102 Elearning Experts LLC uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Elearning Experts LLC has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, access to Elearning Experts LLC’s electronic information systems requires user authentication via password or similar means. Elearning Experts LLC also employs access restrictions, limiting the scope of employees who have access to Customer Personal Data. Further, Elearning Experts LLC uses secure encryption technology to protect certain categories of personal data.
103 Despite these precautions, no data security safeguards guarantee 100% security all of the time.
104
105 VIII. NOTIFICATION
106 Elearning Experts LLC notifies Customers about its adherence to the Privacy Shield ( https://www.privacyshield.gov/ ) principles through its publicly posted website privacy policy, available at http://elearningexperts.net/terms .
107
108 IX. ACCESSING PERSONAL DATA
109 Elearning Experts LLC personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
110
111 X. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
112
113 Right to Access. As a user of the Elearning Experts LLC tool, you have the right to access your data at any time. Data subjects have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Elearning Experts LLC collected the Personal Data. Data Subjects may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law. Upon reasonable request and as required by the Privacy Shield principles, Elearning Experts LLC allows Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Note that personal data is removed from our systems permanently upon closure of Customer accounts, and in those cases, personal information is no longer accessible or editable.
114 Customers may edit their Personal Data by contacting Elearning Experts LLC by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Customers should submit a written request to the Elearning Experts LLC corporate office.
115 Requests for Personal Data . Elearning Experts LLC will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Elearning Experts LLC receives a request for access to his/her Personal Data from a Customer’s customer, then, unless otherwise required under law or by contract with such Customer, Elearning Experts LLC will refer such Data Subject to Customer.
116 Satisfying Requests for Access, Modifications, and Corrections. Elearning Experts LLC will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
117 Limiting Use of Personal Data. You may request limitations on the use of your personal data specified in this agreement by contacting us at privacy@elearningexperts.net .
118 XI. CHANGES TO THIS POLICY
119 This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our website, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
120
121 XII. QUESTIONS OR COMPLAINTS
122 Customers may contact Elearning Experts LLC with questions or complaints concerning this Policy at the following address privacy@elearningexperts.net .
123
124 XIII. ENFORCEMENT AND DISPUTE RESOLUTION
125 Customers with questions or concerns about the use of their Personal Data should contact us at privacy@elearningexperts.net . If a Customer’s question or concern cannot be satisfied through this process, Customers may bring a complaint before the BBB EU Online Privacy Shield. Information about how to file a complaint before the BBB EU Privacy Shield program can be found at: http://www.bbb.org/EU-privacy-shield/bbb-eu-safe-harbor-dispute-resolution/ .
126 In compliance with the Privacy Shield Principles, Elearning Experts LLC commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact privacy@elearningexperts.net .
127 As part of this agreement, Elearning Experts LLC subjects itself to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
128
129 XIV. DEFINITIONS
130 Capitalized terms in this Privacy Policy have the following meanings:
131 “Customer” means a prospective, current, or former partner (distributor or reseller), vendor, supplier, customer, or client of Elearning Experts LLC. The term also shall include any individual agent, employee, representative, customer, or client of an Elearning Experts LLC Customer where Elearning Experts LLC has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.
132 “Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
133 “Employee” means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Elearning Experts LLC or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.
134 “Europe” or “European” refers to a country in the European Economic Area.
135 “Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, email address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term “person” includes both a natural person and a legal entity, regardless of the form of the legal entity.
136 “Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
137 . “Third Party” means any individual or entity that is neither Elearning Experts LLC nor an Elearning Experts LLC employee, agent, contractor, or representative.
138 Elearning Experts LLC Elearning Experts LLC
139 8918 George Washington Memorial Hwy 8918 George Washington Memorial Hwy
140 Yorktown, Virginia 23690 Yorktown, Virginia 23690
141 privacy@elearningexperts.net privacy@elearningexperts.net
142 888.928.3848 888.928.3848