Product Privacy Policy

ONLINE PRIVACY STATEMENT
Effective Date: February 1, 2022

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. Privacy Shield Framework, and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union, the United Kingdom and/or Switzerland to the United States in reliance on Privacy Shield. Wilson Learning Corporation has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is a conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.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 helpdesk@wilsonlearning.com 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 Privacy Shield, 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 helpdesk@wilsonlearning.com.

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 Privacy Shield 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 helpdesk@wilsonlearning.com. 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, and Swiss-US Privacy Shield Principles, Wilson Learning Corporation commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union, United Kingdom, or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Wilson Learning Corporation at:

Kate Dennison
8000 West 78th St., Suite 200, Edina, MN 55439
orders@wilsonlearning.com
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 has further committed to refer unresolved privacy complaints under the EU-US, United Kingdom, and Swiss-US Privacy Shield Principles to an independent resolution mechanism, the BBB EU PRIVACY SHIELD. 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/bbb-eu-privacy-shield-consumers/ProcessForConsumers for more information and to file a complaint.

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 Privacy Shield. 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 Privacy Shield 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 Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction  

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.