CRS Digital Trainings’ GDPR Policy
Last Updated April, 11th, 2019
II. What personal information we collect
When you create a CRS Digital Trainings User Account, purchase a product, download a software update, or contact us, we collect a variety of information, including your name, mailing address, phone number, e-mail address, and contact preferences. When payment, or payment information, is required, we will direct you to submit credit card information through a third-party such as Stripe.
When you, as a CRS Digital Trainings Account Holder, acquire information regarding your customers and then upload that information to CRS Digital Trainings, CRS Digital Trainings will store whatever personal information regarding your customers that you have uploaded on CRS Digital Trainings production servers.
III. How we use your personal information.
The personal information we collect allows us to keep you posted on CRS Digital Trainings’ latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by navigating to the unsubscribe link in the last e-mail you received from CRS Digital Trainings. You will have the option to unsubscribe from an individual list, or from all CRS Digital Trainings lists.
We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes.
We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of CRS Digital Trainings Account holders.
From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with CRS Digital Trainings, You may not opt out of receiving these communications.
We may also use personal information for internal purposes such as auditing, data analysis, and research to improve CRS Digital Trainings’ products, services, and customer communications.
IV. Collection and Use of Non-Personal Information. We also collect data in a form that does not identify any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
We may collect information such as business, language, zip code, area code, unique device identifier, referrer URL, and the time zone where a CRS Digital Trainings product is used so that we can better understand customer behavior and improve our products, services, and advertising.
We may collect information regarding customer activities on any of our websites. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is non personal information.
We may collect and store details of how you use our services. This information may be used to improve the relevancy of results provided by our services.
We gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. CRS Digital Trainings may use this information in our marketing and advertising services.
In some cases we use a “click-through URL” linked to content on the CRS Digital Trainings website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our marketing communications. We also use it to account for Affiliate activity and pay Affiliate commissions and bonuses.
VI. Disclosure to Third Parties. At times CRS Digital Trainings may make certain personal information available to strategic partners that work with CRS Digital Trainings to provide products and services, or that help CRS Digital Trainings market to customers. Personal information will only be shared by CRS Digital Trainings to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.
Affiliates. CRS Digital Trainings will provide your email address to affiliates or users who refer you to us, or through whom you create a CRS Digital Trainings account.
Service Providers. CRS Digital Trainings shares personal information with companies who provide services such as information processing, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, and assessing your interest in our products and services. CRS Digital Trainings also shares your information with financial institutions who provide payment (both to and from you) services. Finally, CRS Digital Trainings provides your personal information with API integrators you have chosen, and other third party software services to assist you with your sales funnels when you so direct us. These companies are obligated to protect your information and may be located wherever CRS Digital Trainings operates.
Legal. It may be necessary − by law, litigation, or requests from government authorities within or outside your country of residence − for CRS Digital Trainings to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.
Corporate Change. Additionally, in the event of a reorganization, merger, or sale of CRS Digital Trainings we may transfer any and all personal information we collect to the relevant third party.
VII. Protection of Personal Information. CRS Digital Trainings takes the security of your personal information very seriously. When your personal data is stored by CRS Digital Trainings, we use computer systems with limited access housed in facilities using physical security measures. When you use some CRS Digital Trainings products and services that by their nature are public facing, such as when you post on a CRS Digital Trainings forum, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and e-mail address in a forum posting, that information is public. Please take care when using these features.
IX. Access to Personal Information. You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account. For other personal information we hold, we will provide you with access (including a copy) upon your request. We may decline to process requests that are frivolous, vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by contacting compliance@CRS Digital Trainings.com.
X. Children & Education. We understand the importance of taking extra precautions to protect the privacy and safety of children using CRS Digital Trainings products and services. Children under the age of 18, are not permitted to create their own CRS Digital Trainings IDs; instead, a parent must obtain the account and provide the parent’s information to CRS Digital Trainings. If we learn that we have collected the personal information of a child under 18 we will delete the information as soon as possible.
XI. Third Party Sites and Services. CRS Digital Trainings websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
XII. Your Rights under the GDPR. If you are a citizen or a resident of a country in the European Union, the GDPR grants you the following rights:
a. Access to Your Personal Data. You have the right to receive a copy of your personal data that is subject to processing by CRS Digital Trainings. Ordinary requests will be granted without charge to you within one calendar month of when you make the request. In cases of excessive, unreasonable, or repeated requests CRS Digital Trainings may charge you a reasonable fee and may require additional time to grant your request. Also, CRS Digital Trainings may use reasonable means to confirm your identity before granting any request for data so as to prevent granting fraudulent requests. To request a copy of Your personal data, please contact us by e-mail at compliance@CRS Digital Trainings.com.
b. To have Your Data Corrected. If your personal data is erroneous or outdated, you have the right to have it corrected. To do so, please contact CRS Digital Trainings via e-mail at compliance@CRS Digital Trainings.com.
c. To be forgotten. You have the right to be forgotten by CRS Digital Trainings. You may exercise this right by e-mailing us at compliance@CRS Digital Trainings.com. We will comply with your request, at no charge to you, within one calendar month by deleting your account, along with all of your personally-identifiable data that is subject to any CRS Digital Trainings processing. Naturally, after we grant your request you will not have access to any CRS Digital Trainings products or services unless and until you open a new CRS Digital Trainings account. CRS Digital Trainings may use reasonable means to confirm your identity before granting any request for data so as to prevent the granting of fraudulent requests.
d. To Restrict Processing of Your Data. You can request that your data not be processed via CRS Digital Trainings partners. You can make that request by e-mailing us at compliance@CRS Digital Trainings.com and, if you wish, you can even specify which third parties to restrict from processing your data. We will respond to your request, at no charge to you, within thirty (30) days from when you make your request. Please be advised that some of our partners, e.g., Stripe, are essential to CRS Digital Trainings services, so that if you block processing by them, CRS Digital Trainings’ services may be unavailable to you.
e. Portability. You have the right to receive a copy of your personal data that is subject to processing by CRS Digital Trainings in a portable format, or to have it transferred directly from CRS Digital Trainings to another party. Ordinary requests will be granted without charge to you within one calendar month of when you make the request. CRS Digital Trainings may use reasonable means to confirm your identity before granting any request to transfer data to you or another party so as to prevent granting fraudulent requests. To request a copy of your personal data in a portable format, or to request a direct transfer of Your data, please contact us by e-mail at compliance@CRS Digital Trainings.com.
XIII. Your Responsibility under GDPR. If you are a CRS Digital Trainings User, then that probably means you are a business owner, using the CRS Digital Trainings software to sell goods and services to your customers. With respect to the customer data that You provide to CRS Digital Trainings, CRS Digital Trainings is a data processor and will comply with its obligations under the GDPR; but with respect to Your customers, You are probably a data controller, and if any of Your customers is a citizen or a resident of a country in the European Union, then You must ensure that You comply with Your obligations as a data controller under the GDPR; namely, You must ensure that You afford Your Customers the rights identified in section (a) above. CRS Digital Trainings sells software; it does not provide legal advice or legal services, nor does it sell a “done-for-you” GDPR compliance package. Please consult legal counsel of your own choosing for advice on what you need to do to comply with GDPR.
XIV. Our Companywide Commitment to Your Privacy. To make sure your personal information is secure, we communicate our privacy and security guidelines to CRS Digital Trainings employees and strictly enforce privacy safeguards within the company.
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