Safe Passage International, Inc. is known as the ‘Controller’ of the personal data provided to us.
Why we need your data: We need to collect this information to provide you with access to our-line training courses and materials.
What we do not collect: We do not collect sensitive information such as medical details.
What we store: We store your personal information carefully. You have consented to provide this information to us but can withdraw your consent at anytime by getting in touch with us at email@example.com.
What we do with your data: We retain personal information only for as long as necessary to carry out these functions. If you notify us that you no longer wish to be listed in our database we will delete your information as soon as possible.
How we use your data: We use your information to provide access to our on-line training courses and materials. We may use your information to contact you about our products and services.
What we do not share: We do not share your information with anyone unless required by our contract with your employer, by law, or is necessary to make our on-line training courses and materials run properly.
What we sell: We do not sell your information to anyone. All the personal information we process is located on our servers in the United States.
What are your rights: You have the right to see the information we hold on you and/or require your data to be deleted by making a request in writing to the e-mail below. If at any point you believe the information we process on you is incorrect you can request to have it corrected. If you wish to raise a complaint on how we have handled your personal data, you can contact us and we will investigate the matter.
What you can adjust: You can adjust certain information in the User Configuration section of application.
What you can request: You can request access to your information or ask us to delete it by contacting us.
If you agree with the above, please access our website and on-line training courses. If you do not agree or would like further information please contact us at firstname.lastname@example.org.
Safe Passage International, Inc. provides on-line training programs and services for the critical infrastructure, transportation, and ports and borders industries.
EU-US Privacy Shield Compliance
SWISS-US Privacy Shield Compliance
General Data Protection Regulation (Regulation (EU) 2016/6791)
This privacy notice is intended to be part of overall compliance with the GDPR requirements of the European Union as set forth in Regulation (EU) 2016/6791 regarding the use, retention, and transfer of personal information. To learn more about the GDPR visit https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ENG
Our Internet web server automatically recognizes the domain names and e-mail addresses of visitors to our web site. We may but will not necessarily collect the domain names and the e-mail addresses. We also may collect some or all of the information volunteered by visitors to our web site, such as survey and demographic information and/or site registrations. The personal information we might collect include:
- First and last name
- Company name and address
- E-mail address and contact number
- Communications – your communications with us, including e-mails and website enquiries
We use "cookies" to save certain visitor information, for example to manage our web site or to expedite future visits. Any information that we do collect is intended primarily for our use in improving our products and services and in informing our customers and other visitors about our products, services and upcoming events. If we do communicate with you, we may do so by e-mail, telephone and/or postal service.
For training courses we offer on-line, we also will be collecting information appropriate to the taking of the course, including student registration information, training progress, and testing results. If training is being taken at the request of another party, such as an employer, we also will provide progress and testing reports to the other party. Details of the information that we will collect and report for on-line training will be provided with the course syllabus or course registration form.
We maintain physical, electronic, and procedural safeguards to protect your information related to the taking of courses. These include:
- Server encryptions
- SSL Certificates
- Physically secured servers
- Antivirus and Firewall
- Regular backups
- Encrypted passwords
Access to this information is restricted to employees with a need to know and to those who need the information to perform their jobs.
We may from time to time include links to the web sites of other organizations that we believe may be useful to our visitors. We of course are not responsible for any of the content of or the privacy practices used in any of those linked sites.
For the purchase of any of our products and services that we make available for on-line purchase, the security protection that we will be using will be a recognized standard to ensure that unauthorized parties cannot access any payment or other information you send us.
We will perform credit card verification by a secure network and will purge credit card information once orders are processed. Those security measures will be automatic; you will not need to do anything special to initiate them. You merely need to follow the ordering procedure, and our security process will take over, encrypting the confidential information you supply us.
We use a third-party analytics service to collect information on our website. We do not control this third-party’s tracking technologies. If you have questions about this analytics service, please contact them directly at https://www.hubspot.com/.
If you do not want to receive e-mail or other communications from us in the future, except in response to your specific inquiries, please let us know by e-mailing, calling or writing to us at our addresses as provided below. In order to "opt out" of any of the above, please specify the form(s) of communication from which you wish to be excluded.
Accountability for Onward Transfer
Please note we do not sell, license, exchange, or otherwise disclose personal information to persons or organizations outside of Safe Passage International.
Please be aware that Safe Passage may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Safe Passage International is liable for appropriate onward transfers of personal data to third parties.
Safe Passage International has taken reasonable steps to protect personal, organizational and training information and data from loss, misuse and unauthorized access, disclosure, alteration or destruction. Safe Passage International and its service providers have put in place appropriate physical, electronic and administrative procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Safe Passage International cannot guarantee that information and data will be absolutely safe from intrusion during transmission, while stored on our system, or when otherwise in our care.
If you correspond with us by e-mail or using Web forms like a “contact us” feature on our web site, you should be aware that your transmission might not be secure. A third party could view the personal information you send while it is in transit by such means.
Data Integrity and Purpose Limitation
Safe Passage International shall only process personal, organizational and training information and data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual or organization. To the extent necessary for those purposes, Safe Passage International shall take reasonable steps to ensure that personal, organizational website and training data is accurate, complete, current and reliable for its intended use.
We will only retain personal data for as long as necessary. If we are requested to delete your personal information it will be removed as soon as possible, and always within 90 days. However, if a contractual or regulatory obligation requires us to retain your personal information for a specific period of time we will let you know.
Safe Passage International recognizes an individual’s right to access to their personal information to correct, amend or delete inaccurate information. There are two ways to gain access to your personal information
ONLINE TRAINING COURSES
Using your account information, log into the Training Management System (TMS) to (1) update your user profile, (2) review training records, and (3) review training progress. If there is any information you believe to be inaccurate, please contact Safe Passage International to have it amended. Please use the contact information provided in the Dispute Resolution section of this policy.
ALL OTHER MATERIALS
There is no automated mechanism to view information you provided on our public facing website. If you wish to view any information you provided, please contact Safe Passage International and we will provide an electronic copy of the information for your review. If you believe any other information you provided via our public facing website is inaccurate, please contact Safe Passage International to have it amended. Please use the contact information provided in the Dispute Resolution section of this policy.
If you would to submit a Subject Access Request (SAR), please do so using the contact information in the Dispute Resolution section of this policy. You will receive a response within 30 calendar days.
Recourse, Enforcement and Liability
Safe Passage International, Inc.
333 Metro Park
Rochester, New York 14623
Tel: +1 585 292 4910
Fax: +1 585 292 4911
Safe Passage International has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
The U.S. Federal Trade Commission (FTC) has enforcement authority with jurisdiction over Safe Passage International’s compliance with the Privacy Shield. Under certain limited conditions, EU individuals may invoke binding arbitration before the Privacy Shield Panel.
May 25, 2018