We guarantee that we will make every possible effort to handle your data conscientiously and comply with the applicable legislation and regulations. As soon as we become aware of new developments and/or guidelines which require action on our part, we will amend the privacy and cookie policies. The most up-to-date versions of our privacy and cookie policies are always available on our website. The current version was last edited on 24/1/2017.
We save the information you enter whenever you use this e-learning platform, for example when you participate in a training course, or register for an event, or use the mailbox service. Whenever you participate in training courses, we process the information about the modules you have selected, your results and the amount of time you spend on a specific module. We also process information when you click a news item and select specific favourites and items on your account page.
Why do we process your data?
We process your data for a number of purposes; e.g.:
|•||to ensure that our e-training courses provide useful and usable content.|
|•||to ensure that the number of training courses adequately matches your information needs.|
|•||to improve the quality of our offer and develop new and useful applications.|
|•||to offer personalised content and promotions.|
|•||to optimise security by protecting against fraud and abuse.|
|•||to carry out analyses and measurements in order to understand more clearly how our services are used.|
|•||to combine data.|
|•||to send you information and/or offers via email that are tailored to your usage.|
We may also disclose your personal information for business purposes to:
|•||companies/organisations that offer a specific training course (in this case, only the following information is disclosed to them: participant’s name, company, town/city of residence and score) in relation to the module(s) they have provided or purchased.|
|•||companies which act on our behalf as a processor of personal data as referred to in the Dutch Data Protection Act (Wet bescherming persoonsgegevens).|
|•||government agencies at home and abroad in order to comply with legal obligations.|
Finally, we process your personal data for the following purposes: administration, customer service, relationship management, quality assurance, operational management and normal business activities, risk assessment, reorganising/restructuring/selling our company, security, preventing or detecting fraud and crime, monitoring, research and analysis, marketing, purchase preferences and trends among customers, product and service development.
Other than for these purposes, we will never disclose your personal data to third parties.
Electronic service provision
Electronic service provision is very important for this platform. When you register as a subscriber, you give us permission to use your email address for sending an email newsletter and/or other information such as invitations to participate in events and/or the launch of a new training module. Obviously, you can register or deregister for this email newsletter at any time. To do so, follow the deregistration instructions (newsletter button > deregister) which are also included in each email message (bulk email) which you receive from us, indicate your desire to do so when we talk to you by telephone, or contact us directly.
We record information about your visit to this website and your use of training courses, bulk emails and newsletters in order to generate statistics about the usage and effectiveness of the website, and to personalise your website experience and the way in which we contact you. We use various techniques for this, including "cookies". A cookie is a small piece of information that is sent by a website to your browser and subsequently stored on your computer. It acts like a label that identifies your computer. Among other purposes, cookies are used to measure the use of websites (e.g. the number of visitors and the duration of each visit) and the effectiveness of websites (e.g. the subjects in which the visitors show the most interest), but also for simplifying navigation and website function. In view of this, they are not linked to personal data of any kind, however they are sometimes used to tailor the way in which a website functions to suit a specific visitor, via a link to a profile and user preferences. As time passes, this provides valuable information which can contribute to improving the user experience. Cookies are also used when you open our newsletters and bulk emails. This allows us to determine whether messages have been opened and whether the links contained in the messages have been clicked.
Session cookies and persistent cookies
First-party cookies versus third-party cookies
Cookies that are sent to you from a domain during your visit to that domain are referred to as first-party cookies. So the cookies associated with viewing web pages on this website are first-party cookies. However, a website may also incorporate elements provided by other parties. Typical examples are embedded videos (such as YouTube links), adverts and social media buttons. If these elements transfer cookies from their own server, they are referred to as third-party cookies. Consequently, when you visit this website, you may receive third-party cookies for Facebook.com, Youtube.com and other third-party websites. Due to the way in which HTTP works and the security protocols relating to cookies, we have no influence on the transfer of third-party cookies. What should you do if you encounter cookies in this category on this website? Please inform us, or contact the relevant third party directly and ask what cookies they have transferred, the reason for transferring the cookies, how long the cookie(s) remain active and how your privacy is protected.
Among other things, cookies allow us to:
|•||track how many unique visitors click a news item, promotional item or content block.|
|•||retrieve information from previous visits for use during your next visit (e.g. where you left off in a training course, so that you can start from that position on the following occasion).|
|•||adapt the way in which the website operates to suit your requirements via so-called functional cookies.|
|•||record which adverts you have already seen to avoid displaying the same advert to you every time.|
|•||collect statistical data about the use of the website. Google Analytics is a well-known example of this. This exclusively involves anonymised statistical information, which we use to analyse and improve how the website works.|
The visitor profiles which this website creates based on first-party cookies will not be shared with third parties under any circumstances and are only used to improve the quality and relevance of this website.
4. Security measures
We want to protect your personal data and maintain its accuracy. The eTraining Company takes all reasonable steps to implement physical, administrative and technical security measures in order to protect your personal data against unauthorised access, unauthorised use and unauthorised disclosure.
Staff and processors of personal data
Only authorised staff and companies working at the instruction of our organisation have access to the data. We keep our software up-to-date and invest in innovations and improvements every year. The software is regularly subjected to a penetration test and, if required based on the resulting report, technical modifications are made. In the case of our servers, all communication takes place via the HTTPS protocol and all domains and sub domains have certificates.
Obligation to report data leaks - Dutch Personal Data Protection Act (Wet bescherming persoonsgegevens/Wbp)
In the unlikely event that a data leak occurs in spite of our stringent precautions, we will report it immediately to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens/AP). In addition, we will also inform you immediately if necessary.
5. Requesting personal data
Obviously, you can request your personal data, change it and/or ask The eTraining Company to correct it or remove it at any time.
If you wish to view a complete personal specification of your registered date, please refer to your account page. If you would like to receive a printed copy/statement, we request you to transfer an amount of €5.95 to IBAN NL59RABO0138047065 and state the following as the transaction reference: The eTraining Company Xist! bv “information regarding stored personal data”. This amount covers the administrative costs associated with your request, in accordance with Article 39 of the Dutch Data Protection Act (Wet bescherming persoonsgegevens).
Please also send your request by email to email@example.com, or send a letter specifying your contact details to the following address: The eTraining Company, Rokkeveenseweg 24, 2712 XZ Zoetermeer. State the reference as “information regarding stored personal data”. After receipt of the amount and your email or letter, we will send you a full specification by email.
6. Hyperlinks and 'white labelling’ websites
It is also possible that The eTraining Company's e-learning software is offered to you under a 'white label' website via a third party (the other party in a contractual agreement with The eTraining company). In these cases, the e-learning website has been modified to match the other party's look & feel and you will find the other party's training courses and content here. In such cases, The eTraining Company has no control over how the other party handles your personal data and therefore accepts no responsibility or liability for the way in which the other party protects your personal data. When using this learning website, always identify the organisation acting as the training course provider and find out how the other party protects your personal data.
As the supplier of the learning website and software, The eTraining Company will at all times act in accordance with the guidelines described above, however in the matter of property rights and responsibilities regarding your personal data, we explicitly refer you to the purchasing party (other party) which collaborates with The eTraining Company based on contractual agreements and the general terms and conditions of The eTraining Company. Clauses 4.5 and 4.7 of our general terms and conditions are particularly relevant here. They are worded as follows:
4.5 In relation to the data which course participants place on THE ETRAINING COMPANY’s server, THE ETRAINING COMPANY guarantees integrity and the property rights of the other party. Under no circumstances will data be used other than for purposes related to administration;
4.7 THE ETRAINING COMPANY shall endeavour to secure the connection or access to the data that is stored. THE ETRAINING COMPANY denies all liability for damages which may possibly arise in respect of data security, in spite of the precautions it has taken.
Do you have any additional questions, comments or complaints about the protection of your personal data? If so, please contact us:
The eTraining Company
2712 XZ Zoetermeer