Product Privacy Policy

Product Privacy Policy

ONLINE PRIVACY STATEMENT
Effective Date: February 1, 2024

Our Commitment to Your Privacy
Wilson Learning Corporation is committed to respecting your privacy. Providing a secure environment in which you can participate in online activities is important to us. This Policy discloses our privacy practices and expresses our commitment to keeping you informed of the information we collect and how it is used. We ask that you take time to read it carefully. We may update this Policy from time to time to reflect new uses, rules, regulations or technologies that impact your privacy. We recommend that Participants review our Policy on a routine basis to view any changes.

 Information Collection and Use
Wilson Learning provides online learning, assessments, and other services to the employees (‘Participants’) of client companies (‘Employers’). Personally identifiable information in the form of Participant names and email addresses is provided to us by Employers for registration purposes. Participants may request feedback from others (‘Respondents’) in the fulfillment of assessment services. Participants provide Respondent email addresses during the use of our site for assessment services only. All personally identifiable information is treated as confidential information and is not used for marketing purposes or divulged to any third parties.

Wilson Learning Corporation complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Wilson Learning Corporation has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Wilson Learning Corporation has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Notice
To use the online courses, assessments, and other services (the “Product”) on this website, we must obtain limited personally identifiable information (names and email addresses) for the Participant and Respondent. This information is used to direct the Participant and Respondent to register for access to the appropriate Product. The results of their participation may be used in aggregate reporting to the Employer. When used in aggregate reports, individual results are not identifiable to the Participant or Respondent.

Limited personal information is also used to provide information to the Employer about the Participant’s use of the Product. This information is limited to the Participant’s progress and performance in utilizing the Product. Wilson Learning prohibits the sharing of individual Participant assessment results with anyone other than the Participant without the prior active, informed consent from the Participant.

Choice
During the self-registration process, Participants may give their consent to Wilson Learning’s limited use of their personal data, or they may refuse to give consent. If they refuse to give consent, they will not be able to use the Product sites. If the Participant does not believe that he/she should be registered for these Products, they should contact their Employer. The Participant may also contact Wilson Learning at [email protected] and we will, in turn, contact the Employer.

If we are going to use a Participant’s or Respondent’s personally identifiable information in a manner different from that stated at the time of collection, we will notify users via e-mail. Users will have an opt-out choice as to whether or not we use their information in this different manner.

Accountability for Onward Transfer
Wilson Learning uses e-mail in the delivery of its online learning, assessment, and other services. We do not provide Participant or Respondent personally identifiable information to any third parties or use them for marketing purposes. We also use third party platforms to assist us in consummating our business relationship with our clients.  Depending on client needs, these platforms may be used to deliver digital and virtual training, collect and provide relevant development feedback to participants, and/or provide reinforcement materials and activities.  If this practice should change in the future we will update this policy to identify those third parties and provide individuals with opt-in or opt-out choice, as appropriate.  Pursuant to the EU-US Data Privacy Framework, the UK Extension to the EU-US DPF and the Swiss-US DPF, Wilson Learning remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

Security
Wilson Learning takes precautions to protect our Participants’ and Respondents’ information both online and off-line. Participant and Respondent information is stored on servers in a locked, secure environment. These servers are protected from hackers with firewalls and a variety of other security mechanisms and procedures. Only our employees who perform a specific job (for example, a customer service representative), or a designated Employer administrator have access to this information.

We use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see either the symbol of an unbroken key or closed lock (depending on your browser) on the bottom of your browser window.

All employees with access to the information have signed a non-disclosure agreement and have been trained on our security and privacy practices.

If you have any questions about the security at our website, please send an e-mail to [email protected].

Data Integrity and Purpose Limitation
Wilson Learning Corporation will use Personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Participant.

Access
In order to provide our Products to Participants, it is important that personal data be accurate. Participants and Respondents have the right to review and edit their own user profile online, which includes name, password and e-mail address. Individuals may also request the deletion of information that is deemed to have been processed in violation of the Data Privacy Framework Principles.  Participants and Respondents may also return to the online system to update assessment responses until such time the results are produced. In addition, Participants and Respondents may submit a request to review, correct, or delete their personal data, at [email protected]. Before updates are made through this means, appropriate validation of Participant or Respondent’s identity is made.

Recourse, Enforcement and Liability

In compliance with the EU-US Data Privacy Framework Principles,  Wilson Learning Corporation commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles.  European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact Wilson Learning Corporation, John Jutsum, Director, Information Systems, [email protected] 800-328-7937.

Wilson Learning Corporation will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the Principles contained in this Policy.

Wilson Learning Corporation has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers  for more information and to file a complaint. This service is provided free of charge to you.

Wilson Learning Corporation commits to cooperate with the EU data protection authorities (DPAs) with regard to human resources data transferred from the EU in the context of the employment relationship. Wilson Learning Corporation commits to cooperate and comply with the UK Information Commissioner’s Office (ICO) with regard to personal data received from the UK in reliance on the UK Extension to the EU-U.S. Data Privacy Frameworks. Wilson Learning Corporation commits to cooperate with the Swiss Federal Data Protection and Information Commissioner with regard to human resources data transferred from Switzerland to the US in the context of the employment relationship.

If your  DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

Wilson Learning Corporation is subject to the investigatory and enforcement powers of the US Federal Trade Commission.

Wilson Learning Corporation 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.

Notification of Changes
Any changes to our privacy policy will be posted to this privacy statement on our homepage and other places we deem appropriate. Our users will always be aware of what information we collect, how we use it, and under what circumstances we disclose it. We will use information in accordance with the privacy policy under which the information was collected.