SUMMARY OF OUR ONLINE PRIVACY COMMITMENT TO YOU
- We understand and respect that your privacy is important to you.
- We use and share personal information that you provide online only in ways that we tell you about.
- We use commercially reasonable efforts to secure personal information that you provide online to prevent it from being used and shared for other purposes.
Starweaver offers resources designed to provide professional development, training and performance management for individuals and companies. “Starweaver” means Starweaver Group, Inc. its successors, subsidiaries, divisions and groups worldwide, excluding joint ventures to which Starweaver is a party, a New Jersey, corporation.
How does Starweaver collect personal information online?
Starweaver collects personal information online through Web sites and other online resources. Starweaver also offers online resources in collaboration with other online service providers, from which Starweaver may receive personal information about users of such resources. These online collaborations are governed by agreements that require personal information to be protected appropriately. Individuals may access many parts of our Web sites and online resources without disclosing any personal information. There are three methods that Starweaver uses to collect personal information online:
- Information that you provide: Starweaver collects personal information and other data that you may enter into forms or data fields on our Web sites or online resources. Such information may include, but not be limited to, contact information (such as your name, postal address, e-mail address, telephone number, user ID and password), date of birth, professional credentials, experiences, activities, skills, preferences, hobbies and interests. Starweaver may also collect compensation and competency information about you that you provide by responding to our questions and surveys or through your use of online and downloadable tools we provide. Our Web sites do not collect credit card information, other than credit card confirmation data through third-party vendors, such as PayPal.
- Information from public or third party information sources: Starweaver may collect personal information about business professionals who register on our Web sites from public or third party information sources to verify their professional credentials and identity. In some cases, we may augment our existing user databases with information from third parties. Some of this information may be personal information, such as change of postal address information.
- Information collected from your computer or other electronic device: We collect information about your computer or other electronic device when you visit our Web sites and use our online resources. This information may include your Internet Protocol (IP) address, domain name, browser type, date and time of your request and information provided by tracking technologies, such as cookies and single-pixel tags. If you use a mobile device to access our web sites and online resources, we also may collect information about your device, such as your device ID and device type, as well as usage information about your device and your use of our mobile Web sites and other mobile resources.
Some of our Web sites and other online resources use tracking technologies to provide additional functionality that enables you to use these resources more effectively. Starweaver uses tracking technologies in ways that do not identify you personally, such as to track accurately numbers of users or referring sites or advertisements to our online resources, or to remember whether you have identified yourself as a business professional or a resident of a particular country. Starweaver may use other companies to deliver e-mail communications on our behalf or to place Starweaver advertisements on other web sites. Starweaver does not control the tracking technologies used by these other companies. If you want to limit anonymous data collection through tracking technologies, please refer to your choices as described below.
In some cases, Starweaver may use tracking technologies in ways that identify you personally, but only after you have entered personal information into a form or data field on our Web sites, or where we have registered you to use our online resources by providing a user ID and password based on information validated through other offline interactions with you. We may use tracking technologies to remember your personal preferences and selections, such as personal information that you have entered into data fields on our Web sites, answers that you have provided in response to our surveys, sections of our Web sites that you visit frequently, or to confirm whether you have read or clicked on certain e-mail communications we send to you so that we can make our communications more useful and interesting to you.
You may choose whether or not you want Starweaver to use tracking technologies to remember you when you visit our web sites, and/or to provide additional personalized services to you. If you want to limit data collection through tracking technologies, please refer to your choices as described below.
What are cookies?
A cookie is a small data file that is sent by Web servers to your computer’s hard drive, where your Internet browser files are kept. Cookies enable Web sites to store small bits of information on your computer and retrieve that information at a later time. Starweaver uses two types of cookies: session cookies, which are temporary cookies that are erased from your computer’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which exist on your computer’s hard drive until they expire, unless you delete them at an earlier time.
What are single-pixel tags?
Single-pixel tags, also known as web beacons or web tags, are graphics that function similar to cookies. Single-pixel tags are not visible because of their small size. They are used to collect information in web logs that does not identify you personally such as web pages viewed, the web site you came from and the advertisement you clicked on to visit our web sites. They also are used to determine whether certain promotional or other commercial e-mail messages we send are opened.
Why does Starweaver collect, use and disclose personal information?
- Generally: Starweaver collects personal information online as necessary to enable individuals to register for, customize and personalize certain of Starweaver’s online resources and communications. Starweaver uses personal information collected online to provide products, services and features and other resources that individuals have requested; for example, educational literature and related information about Starweaver’s business, e-mail programs, tools, quizzes, questionnaires, and surveys. Starweaver analyzes personal information collected online to identify and offer additional services that we believe you might find interesting. Starweaver evaluates use of some online resources and communications with non-identifiable or aggregate information only. Starweaver also may use personal information to audit its online resources for authorized access and security.
- Social Media: Online social media resources are interactive tools that typically enable you to collaborate and share information with others. Some examples of social media resources include social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague. Starweaver may collect personal information from you to enable you to use online social media resources we may offer from time to time. Starweaver may also enable you to use these social media resources to post or share personal information with others. You should consider carefully what information about yourself you choose to share with others when you use social media resources. Starweaver provides additional notice and choices about how personal information is collected, used and disclosed on our Web sites and other online resources that offer social media.
Does Starweaver consolidate personal information?
What choices do I have about how Starweaver collects, uses and discloses personal information about me?
You have four categories of choices. These include:
- No personal information collection: You may choose not to provide any personal information to Starweaver online by electing not to enter any personal information into a form or data field on our Web sites, and by not using any personalized services provided by our online resources. However, some of our online resources are available only to individuals who provide personal information or who use personalized services.
- Limitations and options regarding uses and disclosures for other purposes: Some Starweaver online resources may request your permission to use and disclose personal information about you in order to add you to our contact lists, to enable you to list yourself in a directory or a social media resource, and to identify and offer additional services and promotions that we believe you might find interesting. You can limit the use of personal information about you by checking or un-checking options provided at the time that you enter that information or that we may offer to you in the future. Additionally, you may change your communications preferences (such as to opt-out of communications you requested previously) by contacting us as hereinafter described.
- E-mail communications: You may choose to receive optional e-mail and other communications from Starweaver by signing up for or subscribing to these communications on our Web sites and other online resources. If you do not wish to receive optional e-mail communications, you may opt-out by visiting the web site or other online resources where you subscribed, where available, and update your e-mail communication selections, or you may follow the unsubscribe or opt-out instructions in the e-mail communications you receive from us. You also may opt-out by contacting us as hereinafter described. If you do not wish for Starweaver to confirm whether you have read or clicked on certain e-mail communications we have sent to you, you may opt out of e-mail communications tracking by opting out of receiving those e-mail communications altogether using one of the approaches described above. In some cases we will not be able to turn off e-mail tracking and still send the communication to you.
Who will have access to personal information about me?
Does Starweaver share personal information with third parties?
How does Starweaver secure personal information?
Starweaver will take reasonable steps to protect personal information as it is transmitted from your computer to our online resources and servers, as well as to protect personal information in its possession from unauthorized access, disclosure, alteration or destruction. It is your personal responsibility to secure your own copies of your passwords and related access codes for our online resources.
How does Starweaver protect the privacy of children?
Starweaver Web sites are not directed at children and most of the online services that we offer are designed for individuals who are 18 years of age or older.
How may I access and correct personal information about me?
To gain access to personal information about you collected online, and to keep it accurate, complete and current, you may contact us as hereinafter described. Where offered, you also may update personal information about you online by modifying information that you previously have entered into forms or data fields on our Web sites. Where permitted by law, your ability to access and correct personal information will be limited where access and correction would: inhibit Starweaver’s ability to comply with a legal or ethical obligation, inhibit Starweaver’s ability to investigate, make or defend legal claims, result in disclosure of personal information about a third party, result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to Starweaver or a third party.
What is Starweaver’s contact address for privacy questions?
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, Starweaver adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Starweaver or to which Starweaver discloses personal information for use on Starweaver’s behalf.
“Starweaver” means Starweaver Group, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of Starweaver to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Starweaver will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
NOTICE: Where Starweaver collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which Starweaver discloses that information, the choices and means, if any, Starweaver offers individuals for limiting the use and disclosure of personal information about them, and how to contact Starweaver. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Starweaver, or as soon as practicable thereafter, and in any event before Starweaver uses or discloses the information for a purpose other than that for which it was originally collected.
Where Starweaver receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: Starweaver 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.
For sensitive personal information, Starweaver will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Starweaver will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: Starweaver will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Starweaver will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
ACCESS AND CORRECTION: Upon request, Starweaver will grant individuals reasonable access to personal information that it holds about them. In addition, Starweaver will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: Starweaver will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
- for disputes involving all personal information received by Starweaver from Switzerland, Starweaver has agreed and to cooperate with the Swiss FDPIC;
- for disputes involving employment-related personal information received by Starweaver from the EEA, Starweaver has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
- for disputes involving all other personal information received by Starweaver from the EEA, Starweaver has agreed to TRUSTe dispute resolution. Individuals who submit a question or concern to Starweaver and who do not receive acknowledgment from Starweaver of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the TRUSTe Safe Harbor Dispute Resolution Program on the Internet, by mail or by fax. Inquiries by mail or fax should identify Starweaver as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether TRUSTe may share the details of the inquiry with Starweaver. TRUSTe will act as a liaison to Starweaver to resolve these disputes.
- a. http://watchdog.truste.com/pvr.php?page=complaint&url
b. Fax: 415-520-3420
c. Mail: Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105
- For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, visit TRUSTe on the Internet(http://watchdog.truste.com/pvr.php?page=complaint&url) or request this information from TRUSTe by mail or fax using the contact information listed above. The TRUSTe dispute resolution process shall be conducted in English.
- a. http://watchdog.truste.com/pvr.php?page=complaint&url
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Starweaver to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Starweaver Privacy Office
Starweaver Group, Inc.
330 112th Avenue NE, Suite 300
Bellevue, Washington 98004
Or by e-mail firstname.lastname@example.org
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