At Heuristic Solutions (“we”, “us”, “our”, or the “Company”), we are committed to protecting your privacy.
1. LEARNINGBUILDER PLATFORM
Heuristic Solutions operates the web based software, LearningBuilder, an online professional development platform designed to make it easy for individuals or programs to achieve the professional standards as defined by the “Sponsoring” organization, our customer. Heuristics Solutions, LLC (Company) is committed to respecting your privacy and the confidentiality of your personal data and content in a manner consistent with the policies of the Sponsoring organization.
The use of information collected through this platform is strictly limited to the purpose of meeting our contractual obligations to our customer, the Sponsoring organization, and providing the services requested by our customers, which are defined within our service agreements with them. We collect information at the direction of the Sponsoring organizations, and we have no direct relationship with their constituents, you, as an individual whose personal data we process.
2. WHAT INFORMATION DO WE COLLECT?
To provide you with use of our Services, we may gather and process some or all of the following information:
- Submissions: any information (as required by the Sponsoring organization) that is collected from or stored by you when you use our Services. This information may be used by the Sponsoring organization.
- Customer Service Communications: any information that is reported to us or the Sponsor about the operation of our Services, including bug reports or requests for enhancements, and stored in the system.
- Log Information: When you use some Services, our servers automatically record basic information pertaining to your use of the system. These server logs may include information such as your message, Internet Protocol address, other addressing information, the date and time of your request and an authentication token used to validate the identity of you and your computer.
3. HOW DO WE USE THIS INFORMATION AND FOR WHAT PURPOSE?
Primarily, we collect information for use with your relationship with your Sponsor.
We also collect information to provide you with an efficient user experience and improve the performance of the platform.
4. TO WHOM DO WE TRANSFER YOUR PERSONAL INFORMATION?
Except as provided below, we shall not sell, rent, trade or otherwise transfer any Registration Information or Submissions to any third party without your explicit permission, unless we are obliged to do so under applicable laws or by order of the competent authorities.
At the request of your Sponsor, we may share your information with their other service providers and third parties in connection with your use of our Services.
Information collected by us may be stored and processed in any country in which we and our affiliates maintain facilities. We reserve the right to transfer information outside of the country where you reside and/or from which you use our Services. By using our Services you consent to any such transfer of information.
As we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions as well as in the event all or substantially all of our assets are acquired by a third party, personal information of our users will generally be one of the transferred business assets. We reserve the right to include your personal information, collected as an asset, in any such transfer to a third party.
5. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We take appropriate organizational and technical measures to protect your information from unauthorized access. You should be aware that internet communications are not always secure. Although we take appropriate measures to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.
6. HOW LONG IS YOUR PERSONAL DATA KEPT BY US?
We will retain your information in accordance with the contractual agreement between us and the Sponsoring organization and as required by applicable law.
We only have control of information in our records and do not have control of information relating to you in Sponsor records; accordingly, when we change or delete Personal Data, your Personal Data may remain part of Sponsor records.
7. WHAT ARE COOKIES AND HOW DO WE USE THEM?
A cookie is a small piece of data sent from us and stored on your computer or mobile device and contains information about the user. Usage of a cookie will in no way linked to any personally identifiable information while using our Services. Once the user closes their browser, the cookie simply terminates. For instance, by setting a cookie on our Service, the user would not have to log in a password more than once, thereby saving time while on our Services. If a user rejects the cookie, they may still use our Services. The only drawback to this is that the user will be limited. Cookies can also enable us to track to enhance the experience using Services and for analytic purposes to help us understand the use of our Services.
8. California Privacy Rights.
California Civil Code Section 1798.83 permits customers who are California residents and who have provided us with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, please contact us by email at email@example.com, or by phone at 703.243.3376, or by mail at 1901 Ft Myer Dr, Suite 1105 Arlington, VA 22209.
9. Personal Data Rights
We are committed to helping you and our Sponsoring organizations understand and comply with General Data Protection Regulation (GDPR).
For the purposes of GDPR, the Sponsoring organization is the Data Controller, we are the Data Processor.
If you are a resident of or are located in the European Economic Area (“EEA”), you may also have certain rights under the General Data Protection Regulation (“GDPR”). Personal Data you provide in using our Services is only collected with your consent, and may be transmitted outside of the EEA to us or your Sponsor (or computer servers maintained for our or your Sponsor’s benefit) pursuant to that consent.
In general, under the GDPR you may:
- request access to your Personal Data held by us (right to access)
- have incomplete or incorrect Personal Data corrected (right to rectification)
- have your Personal Data deleted to the extent permitted by applicable data protection laws (right to be forgotten, right to erasure)
- suspend or restrict our processing of your Personal Data, or withdraw your consent
- request a copy of your Personal Data
- complain to a supervisory authority if you believe your rights under the GDPR are not being respected
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
Please contact Alison Neal, firstname.lastname@example.org, if you have concerns regarding your Personal Data, or wish to exercise any of these listed rights. Any exercise of these rights will be coordinated with the Sponsoring organization.
Note that, if you are in the EEA, we may transfer your Personal Data outside of the EEA, including to the United States. By way of example, this may happen if your Personal Data is transferred to our servers located in a country outside of the EEA. These countries may not have similar data protection laws to the EEA. By submitting your Personal Data, you are agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, it will take steps so appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.
10. HOW FAR DOES OUR RESPONSIBILITY EXTEND?