Privacy Policy


  


Werfen Academy Privacy Policy

Introduction

Scope of our Privacy Policy

How we use your information and legal reason for the processing

How long does Werfen store your PII?

To whom we may share your PII

Your rights

How we protect your information

How to contact us

Introduction

Data privacy is important to us. At Werfen we recognize the importance of protecting your personal data and are committed to processing it responsibly and in compliance with the applicable laws.

This Privacy Policy is intended to describe how we, Werfenlife S.A. (hereinafter “Werfen”, “we” or “us”), a Spanish company holding tax identification number A-08754111, with corporate address at Plaza Europa 21-23, 08908, L’Hospitalet de Llobregat, Barcelona, Spain, and registered with the Commercial Registry of Barcelona under volume 4.853, book 4.172, folio 157 and sheet 54.551, process your personal identifiable information (“PII”) in our capacity as data controller.

We may update this Privacy Policy from time to time. When doing so, changes will be effective immediately upon posting the revised Privacy Policy on the site. As a result, we recommend that you check this Privacy Policy on a regular basis.

This Privacy Policy was last updated on November 17, 2020.

 

Scope of our Privacy Policy

This Privacy Policy applies to all PII we collect, use, share or otherwise process when using the Werfen Academy site https://academy.werfen.com (the “Site”), our e-learning platform for users to access Werfen educational courses and operator training content (the “Services”).

Our Site make use of cookies. For more information on this subject, please consult our Cookies Policy. Further, when using the Site or the Services, please read our Terms of Service.

Please note that another Werfen companies (“affiliates”), the corresponding Werfen legal entity which is located in your same country or region, may also process your PII in connection with the Services as data controllers, being such processing also within the scope of this Privacy Policy. To know the affiliates to whom we may share your PII, please see “Intra-group sharing” in the section “To whom we may share your PII”.

Information that you give us

We may gather your PII when you visit or use our Site or when you use our Services as explained below:

·       Information we automatically collect:

PII collected this way may include: Information about your IP address, type of browser, log information and performance and metric statistics to help improve and further develop our Services such as tracking information about the course/s that customers are taking.

·       Information you provide to us:

On one hand, if you only have access to the public section of the Services, PII collected may include: your name, surname, e-mail address, password, city, country. On the other hand, if you are given access to the restricted section of the Services some additional information about your professional profile such as your job title, institution or company you work for, postal code and client ID will be required.

For further information about the public and restricted sections of the Services, you can consult the Werfen Academy Terms of Service.

How we use your information and legal reason for the processing

We process your PII for the purposes indicated below on the following legal grounds:

·       To meet our contractual obligations or to take steps to enter into a contract with you:

o   To manage and provide you access to the Services.

o   To process requests and orders for courses, or information or features that you may perform.

o   To track your learning progress in order to make this information available and issue the corresponding course completion certificates.

o   To respond your requests for information or support related to either the Services or the Site.

o   To operate, protect and make your experience safer and better when visiting our Site or using the Services, as well to carry out the relevant administrative and maintenance tasks.

·       Because it furthers the legitimate interests of Werfen in business activities, such as the ones listed below, and because that handling does not unduly impact your interests, rights, and freedoms:

o   To share your PII with another relevant affiliates (the Werfen legal entity closest to you to provide a personalized and better service). As said, please note that in this case, the corresponding affiliate also becomes data controller for rendering the Services being this Privacy Policy also applicable to them.

o   To track customers who have registered for the Services. This will allow us to identify customers who are already registered and those who are not registered yet.

o   To track the courses that customers are taking. This will allow us and affiliates to identify the most popular educational content so we can improve our Services with similar and/or relevant educational content.

o   Some affiliates may also wish to contact you electronically to send a survey to assess the Services content and function, so that we can examine your degree of satisfaction and improve our Services.

·       To meet legal compliance obligations, regulatory requirements and claims:

o   We manage your PII as required by the applicable regulations (including administrative, tax, accounting and labor obligations).

o   To establish, exercise or defend legal claims.

o   Under certain circumstances where we believe that using or disclosing the PII is appropriate to protect the rights, safety, and property of Werfen or others (e.g., when required to make disclosures in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements).

We will not use your PII for any other purpose incompatible with the purposes listed above, unless it is authorized by you, or it is necessary for us to comply with a legal obligation, to resolve disputes and/or to prevent security issues or abuse.

How long does Werfen store your PII?

Your PII will be retained for as long as you are Member of the Site (as the term “Member” is defined in the Terms of Service) to address the related processing purposes outlined herein. Once this time has expired, certain regulations oblige us to keep such data for a longer period, especially to deal with possible complaints or comply with legal obligations. During this time, we will keep your PII blocked only to comply with these purposes.

To whom we may share your PII

We share your PII with other organizations in the following limited circumstances:

·       Intra-group sharing:

    • As a global company, your PII may be shared with affiliates world-wide and transferred to countries where we do business in accordance with this Privacy Policy. Between affiliates we only grant access to your PII on a need-to-know basis, necessary for the purposes for which such access is granted. Please click here to know who we are.

·       Third-party service providers:

    • We may use trusted third-party service providers who work on our behalf such as software and IT service providers. These third-party service providers are required not to use your PII other than to provide the Services and always in accordance with our instructions.
  • Acquisitions:
    • In connection with a corporate transaction, such as the sale of all or a portion of our business, a divestiture, merger, consolidation or an asset sale, the recipient company may acquire all or part of the PII collected by us and will assume the rights and obligations regarding your PII as described in this Privacy Policy. In the unlikely event of an insolvency, bankruptcy or receivership, your PII may also be transferred as a business asset, subject to applicable law.
  • Disclosures:
    • We may disclose your PII if we believe in good faith that such disclosure is necessary for our legitimate interest or prudent considering our obligations under applicable law:
      • In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or public administration.
      • To establish or exercise our legal right, to defend against legal claims or as otherwise required by law.
      • In connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
      • To protect and defend the rights, property or safety of Werfen, our employees, or others.
      • To investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or any applicable Terms of Use.

We and our third-party service providers may have operations in several locations in the world. Consequently, we and our third-party service providers may transfer PII to, or access them from, countries outside your country of domicile.

We take steps to ensure your PII receive an adequate level of protection in the countries in which we process them. In case our processing is subject to any EU data protection regulation and your PII is transferred from the EU to a third-party service provider for processing in any country outside the EU that is not recognized as providing an adequate level of protection for PII, we provide for appropriate safeguards by EU Commission’s standard contractual clauses or by any other appropriate safeguard as foreseen under the applicable data protection regulations.

You may contact us in the “How to contact us” section for further information regarding the international transfer of PII.

 

 

Your rights

We offer the options below for exercising your rights and choices about how we use your PII. Many of these are subject to important limits or exceptions under applicable laws:

  • Request a copy of the PII we hold about you.
  • Ask that we restrict the way in which we use your PII.
  • Ask that we update the PII we hold about you or correct any PII that you think is incorrect or incomplete.
  • Ask that we delete PII that we hold about you (the “right to be forgotten”).
  • Withdraw your consent, at any time for the future, to our processing of your PII (to the extent such processing is based on the legal grounds of your consent).
  • Object to us processing of your PII.
  • Request your PII be transferred to you or another data controller (the “data portability” right).

You may contact us with any concerns or complaints regarding our privacy practices or to exercise any of the aforementioned rights. If you would like to exercise these rights or understand if they apply to you, please click here to complete and submit an online request form. Alternatively, you can get in touch using the details set out at “how to contact us” below.

For your protection, we will only implement requests with respect to PII after we have verified your identity to our satisfaction, taking into consideration the nature of your request.

Whenever, in your opinion, the processing of your PII involves an infringement of the legal requirements, or if you are unhappy with the way we have handled your PII or any privacy query or request that you have raised with us, you have the right to complain to your local data protection regulator.

How we protect your information

We value the trust you place in us and how important it is to protect and manage your PII.

We use commercially reasonable technical and organizational measures to protect your PII against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access and against all other unlawful forms of processing. The PII you provide us with is stored on computer systems located in controlled facilities which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you.

Should, despite of our security measures, a security breach occur that is likely to result in a risk to your PII, we will inform the relevant affected parties, as well as relevant authorities when required by applicable data protection law as soon as reasonably possible. 

How to contact us

As a global company, Werfen has appointed a person as the Data Protection Officer (DPO) to guarantee Werfen complies with all the legal requirements of the regulation regarding the protection of PII. In addition to that, with the aim of facilitating the resolution of any doubt or concern regarding data privacy, Werfen has also appointed a Local DPO (representative of the DPO) or an equivalent figure in each affiliate.

Werfen global DPO can be reached by e-mail at DPO@werfen.com or by mail at Werfenlife, S.A., Plaza Europa, 21-23, 08908, L’Hospitalet de Llobregat, Barcelona, Spain.

Your local representative can be reached by e-mail or by mail at the corresponding affiliate address. You can find more information about how to contact them in the corresponding Privacy Policy of the different affiliates in the section “Select Country” via the following link: https://www.werfen.com/en.


 

Annex

 

You can use this form to submit a request regarding your personal data (“data”) processed by Werfen. Please complete this form and we will respond as soon as possible. For further details about how we use and protect your data please visit our Privacy Policy. Thank you.

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