Privacy Policy.

EU-US and Swiss-US Privacy Shield

CONTENT ENABLERS, INC respects individual privacy and values the confidence of its customers, employees, business partners and others. CONTENT ENABLERS, INC collects only the information provided by the users' employer (typically name, email address, business unit and location) for the purposes of conducting online training programs on behalf of the employer. The data is never shared, sold or used for marketing purposes, nor does CONTENT ENABLERS process the data within the context of the human resources relationship This EU-US and Swiss US Privacy Shield (the "Policy") sets forth the privacy principles that CONTENT ENABLERS, INC follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU), Switzerland, Iceland, Liechtenstein and Norway) to the United States.


EU-US and Swiss-US Privacy Shield Framework

Content Enablers complies with the EU-US and the Swiss-U.S. Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. Content Enablers has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies 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 page, please visit https://www.privacyshield.gov


Scope

This EU-US and Swiss-US Privacy Shield (the "Policy") applies to all personal information received by CONTENT ENABLERS, INC in the United States from the European Economic Area, and Switzerland, in any format including electronic, paper or verbal.


Definitions

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that uses personal information provided by CONTENT ENABLERS, INC to perform tasks on behalf of and under the instructions of CONTENT ENABLERS, INC.

"CONTENT ENABLERS, INC" means its predecessors, successors, subsidiaries, divisions and groups in the United States of America.


Information We Collect

When you use with our Site, we may collect and use personally identifiable information about you, as well as other information. “Personally identifiable information” includes your name, address, email address, and other similar information that can be used to identify you. Personally identifiable information does not include information that is encoded or anonymized, or publicly available information that has been combined with non-public personal information. More specifically, when you use our Site, we may collect the following information:

  • Details of your visits to our Site and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, browser type, the date and time you accessed or left the Site, and which pages you viewed. Some parts of our Site use cookies, pixel tags (also known as “web beacons”), and other technologies to collect this information about your general internet usage. See the section below called “How We Use Cookies and Pixel Tags” to learn more.

  • Information that you provide directly to us by filling in forms on our Site, including your name, email address, street address, telephone number, or other information.

  • Information provided to us when you communicate with us for any reason, including information you provide in emails you send us, or submissions you may make to our blog.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, CONTENT ENABLERS, INC does not collect sensitive information.


How We Use Cookies and Pixel Tags

A “cookie” is a small computer file that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Keep in mind, however, that some website features or services may not function properly without cookies.

A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies.


"Do Not Track" Requests

CONTENT ENABLERS’ Site currently does not respond to “do not track” or similar signals.


Use of Your Information

We use the information we collect from you primarily to enable us to provide our services to you in the best possible manner. In addition, your information may be used for the following purposes:

  • To provide you, including via your email address, with information relating to our services;

  • To administer our Site, including by monitoring and analysing our Site traffic and usage patterns.

Privacy Principles

The privacy principles in this Policy are based on the EU-US and Swiss-US Privacy Shield Principles.

Notice: Where CONTENT ENABLERS, INC collects personal information directly from individuals in the EEA and Switzerland it will inform them about the purposes for which it collects and uses personal information about them. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to CONTENT ENABLERS, INC, or as soon as practicable thereafter, and in any event before CONTENT ENABLERS, INC uses the information for a purpose other than that for which it was originally collected.

Choice: CONTENT ENABLERS, INC. does not currently transfer personally identifiable data to third parties. In the event that CONTENT ENABLERS, INC. engages any future third party, CONTENT ENABLERS, INC will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

CONTENT ENABLERS, INC will provide individuals with reasonable mechanisms to exercise their choices.

Accountability for Onward Transfer: CONTENT ENABLERS, INC will obtain assurances in the form of a written contract from its agents including marketing automation software partner, that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-US and Swiss-US Privacy Shield Principles. Where CONTENT ENABLERS, INC has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, CONTENT ENABLERS, INC will take reasonable steps to prevent or stop the use or disclosure. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, Content Enablers is potentially liable.”

Security: CONTENT ENABLERS, INC uses commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect on our Site. These procedures include, but are not limited to, firewalls, encryption, intrusion detection, and Site monitoring. We also limit access to any personally identifiable information we receive to employees who need access to that information in order to do their jobs. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your personally identifiable information, we cannot guarantee that it will be 100% secure. Your transmission of your data to our Site thus is done entirely at your own risk.

Data Integrity and Purpose Limitation: CONTENT ENABLERS, INC will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. CONTENT ENABLERS, INC will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

We also 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.

When you provide us with personal information we also may use and share your personal information to contact you, including via email, to thank you for providing your request, to conduct satisfaction surveys, or for other administrative purposes related to your request.

Access: Content Enablers acknowledges the individual’s right to access their personal data. Upon request, CONTENT ENABLERS, INC will grant individuals reasonable access via email transmission of personal information that it holds about them. In addition, CONTENT ENABLERS, INC will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Recourse, Enforcement and Liability: CONTENT ENABLERS, INC will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that CONTENT ENABLERS, INC determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution: In compliance with the EU-US and Swiss-US Privacy Shield Principles Content Enablers commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Content Enablers at: privacy@contentenablers.com

Other Circumstances: We may disclose your personal information to third parties if we are involved in a merger, acquisition, or sale of any or all of our business and/or our assets to a third party, or if we have a good faith belief that disclosure is necessary to:

  • comply with applicable laws, regulations, legal process (such as a subpoena), or enforceable government request;

  • enforce applicable Terms of Service, including investigation of potential violations of such Terms, or to detect, prevent, or otherwise address fraud, security, or technical issues; and

  • protect against harm to the rights, property, or safety of CONTENT ENABLERS, our users, or the public as required or permitted by law.

Third Party Websites and Social Media Features
CONTENT ENABLERS’ Site may contain links to other sites, including those of third parties or business partners. While we seek to link only to sites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices other websites use. By accessing other third party websites or applications through our Site, you are consenting to the terms and privacy policies of those websites. It is possible that other parties may collect personally identifiable information about your online activities over time and across different web sites when you use CONTENT ENABLERS’ Site.

Content Enablers is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).


EU-US and Swiss-US Privacy Shield Principles

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Content Enablers commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquires or complaints regarding this policy should first contact privacy@contentenablers.com. Content Enablers has further committed to refer unresolved privacy complaints to the BBB EU PRIVACY SHIELD, an alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.


Internet Privacy

CONTENT ENABLERS, INC sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, business partners, and others. CONTENT ENABLERS, INC recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the "IPP") governing the treatment of personal information collected through web sites that it operates.

With respect to personal information that is transferred from the European Economic Area and Switzerland to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. CONTENT ENABLERS, INC's Internet Privacy Policy can be found at http://www.contentenablers.com/ceweb/privacy_policy.html


Review and Correction of Your Information

California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of personal information with third parties for direct marketing purposes. Content Enablers does not share any California consumer personal information with third parties for marketing purposes without consent.

California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.


Users Only of Legal Age of Majority

Our Site is designed and intended for those who are at least 18 years old. By using our Site, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age. No one under age 13 is authorized to submit any information, including personally identifying information, on our Site. Under no circumstances may anyone under age 13 use our Site. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf.


Human Resource Data Privacy:

Human Resources Data
Content Enablers also handles HR data within the HR relationship as it relates to our employee(s) with the EU.

EU individuals whose HR data we receive can address questions or comments regarding the handling of that information directly to us at privacy@contentenablers.com. We resolve to deal with all questions regarding this data and potential grievances arising from it in a timely manner.

Content Enablers commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by the respective authorities with regard to [human resources] data transferred from the EU and/or Switzerland [in the context of the employment relationship].


Privacy Policy Updates

This Privacy Policy was last updated on May 15th 2017.

We update the Privacy Policy from time to time, so please review it regularly. If we materially change our Privacy Policy, we will notify you by contacting you through your user account e-mail address or by posting a notice on our Site. Your continued use of the Site will be deemed your agreement that your information may be used in accordance with the new policy. If you do not agree with the changes, then you should stop using the Site and notify us that you do not want your information used in accordance with the changes.


Contacting Us

We welcome any questions, comments, or complaints you may have regarding this Privacy Policy. Please do not hesitate to contact us by email at privacy@contentenablers.com or by writing to:

CONTENT ENABLERS, INC
18 Division Street, Suite 308,
Saratoga Springs, NY 12866
privacy@contentenablers.com

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