TRACOM Policy on Data and Privacy
Effective Date: 9 June 2017
TRACOM participates in and has certified its compliance with the EU-U.S. Privacy Shield framework and the Swiss-U.S. Privacy Shield Framework. TRACOM is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield framework, to the framework's applicable principles. To learn more about the Privacy Shield framework, visit the U.S. Department of Commerce's Privacy Shield List [https://www.privacyshield.gov/]
TRACOM is responsible for the processing of personal data it receives, under each Privacy Shield framework, and subsequently transfers to a third party acting as an agent on its behalf. TRACOM complies with the Privacy Shield principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield frameworks, TRACOM is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, TRACOM may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
TRACOM delivers assessment and training services to our clients. In the course of delivering these services, we gather personal data on or about individuals. Personal data includes, but is not limited to names, email addresses, security responses, survey responses and optional demographic responses. Sensitive personal data gathered includes an optional Ethnicity question (United States respondents only). We use personal data to authenticate authorized access to our websites and to process the survey data gathered into Learner Reports, used by the Learners in group and individual training and coaching sessions.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We regularly analyze survey and demographic responses, including ethnicity responses, and the results are used by TRACOM to update and validate our surveys and are occasionally published, in summary form only, in research reports designed for general circulation. Individuals are never identified in these reports. Specific organizations are identified only if we receive prior written approval from the organization.
Personal data collected about or from an individual is considered confidential by TRACOM. Only authorized personnel (TRACOM Program Administrators and Facilitators, client Program Administrators and Facilitators) have access to personal data. However, once individual Learner Reports have been delivered to the Learners, Program Administrators, or third party Facilitators, these materials are no longer within the control of TRACOM.
The security of your personal data is important to TRACOM. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. When you enter personal data, we encrypt the transmission of that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
Upon request TRACOM will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by emailing our Customer Support team at email@example.com. We will respond to your request within 7 days.
TRACOM acknowledges that you have the right to access your personal information. TRACOM has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the TRACOM Client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
We will retain your personal data for as long as your account is active, unless its removal is governed by a corporate master agreement. We will retain and use your personal data as necessary, to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you are the subject of one of our multi-rater surveys, we will ask you to invite people to participate as your Raters. We will ask you for their names and email addresses. We will automatically send your Raters a one-time email inviting them to visit the site and optionally, send them periodic reminders. TRACOM stores this information for the sole purpose of sending these emails and measuring the progress of your Raters in responding to the survey. Your Raters may contact us at firstname.lastname@example.org to request that we remove this information from our database.
If you believe that one of your colleagues has provided us with your personal information and you would like to request that it be removed from our database, please contact us at email@example.com.
In the event of an asset sale, merger, consolidation, restructuring, reorganization, liquidation or other similar transaction involving TRACOM, we may transfer some or all personal data to the successor company. You will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
We may disclose personal data when we believe such disclosure is required by law, such as to comply with a subpoena, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, or to any other third party with your prior consent.
We may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.
The TRACOM Corporation
6675 South Kenton Street, Suite 118
Centennial, Colorado, USA 80111