When Insala acts as a Data Processor
As a leading global provider of talent development software and consulting, Insala's mission is to connect organizations and people throughout their shared career journeys.
Any data we process will not be further disclosed to third parties except where permitted or required by the processing contract, Privacy Shield, EU General Data Protection Regulation (GDPR) or the applicable Member State Data Protection law. The processing contract will specify that the processing will be carried out with appropriate data security measures. Insala has established and maintains security measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction.
Insala may be required to disclose personal information in response to lawful requests by public authorities, including requests to meet national security or law enforcement requirements. Prior to the transfer of personal information from the EU to the United States, Insala requires contractual acknowledgement from the relevant EU controller that the personal data has been provided to Insala in compliance with the applicable EU Member State Data Protection law, thereby ensuring the data subjects have been provided with proper notice regarding how their personal data will be used.
When personal data is collected directly from data subjects in the EU, Insala provides the data subject with notice concerning how the personal data will be used and transferred to third parties.
This Policy tells you, among other things, what information we gather from you through our Site, how we may use or disclose that information, and our on-going commitment to protect it. Please read this Policy carefully and feel free to contact us at email@example.com if you have any questions regarding its contents. If you have any complaints, the dispute resolution process is described below.
We use the personal information you provide to register you as a user of the Site, to administer Site usage to monitor traffic-levels, and to contact you regarding improvements we can make to our Site and our services, if necessary. We may use your e-mail address to contact you directly regarding services, products, or information that we believe may be of interest to you. We will not use your information for any purpose that you have not authorized.
From time to time, as stated above, we may also disclose personal information in response to lawful requests by public authorities including to meet national security or law enforcement requirements or if we believe, in good faith, that such disclosure is legally required or necessary to protect others' rights or to prevent harm.
If Insala is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our websites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
You may choose to restrict our use of your information. If you are a user of our websites, you may restrict distribution of your information by indicating such restrictions when asked. On our websites, you have the option to remove your name and personal information from any information that will or may be disclosed to a third party (opt out).
We do not typically collect sensitive categories of information, such as your medical or health conditions, ethnic or racial origin, political or religious beliefs, trade union membership or information concerning your health or sexual orientation, and if any of this type of information is collected within our Sites, we will not disclose such information to any third party without your affirmative authorization (opt in) on the Site.
We will not use your information for any purpose other than for those purposes you have authorized and we will not use your information for a purpose that is incompatible with the purpose for which it was originally authorized by you. We will treat as sensitive any information that we receive from a third party where the third party treats and identifies it as sensitive.
When you opt in to receive our communications you may later opt out in two ways.
1. You may opt out of receiving the communications by canceling your subscription. To cancel a subscription, send an email to firstname.lastname@example.org along with your username and, within the email subject or body, enter the words "Cancel Subscription."
2. You may also opt out of communications by clicking on the opt-out feature found at the bottom of any communication. When you click on this opt-out feature, follow the instructions provided as they change from time to time and you will no longer receive communication. You will be notified when your personal information is to be collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether to share your information with that party.
If your personal information changes, you may correct or update it by logging into your account and clicking on your full name at the top right-hand side of the page.
Surveys and Contests
From time-to-time, our sites request information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as postal codes or zip codes). Contact information will be used and/or shared with the contest or survey sponsors to notify the winners and award prizes. Anonymous Survey and Contest information will be used for purposes of monitoring or improving the use and satisfaction of this site. Users' personal information is not shared with third parties unless we give you prior notice and give you a choice to opt out. Though we may use an intermediary to conduct these surveys or contests, they may not use users' personal information for any secondary purposes.
Use of Log Files, Cookies, and Web Beacons
Like most standard website servers, we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personal information. IP addresses are tied to personal information to enable our Web-based service. We use software that reads log files to analyze user movement.
Cookies and Other Tracking Technologies
Technologies such as: cookies, beacons, tags and scripts are used by Insala and our partners, affiliates, or analytics or service providers including server health and usage (NewRelic, Google Analytics) and customer support (Zendesk). These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use Local Storage Objects (LSOs) such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
Onward Transfer (Transfers to Third Parties)
We will apply the Notice and Choice policies discussed above in the event we propose to disclose your information to a third party. If we propose to disclose your information to a third party that is acting as our agent or on our behalf, we will ensure that the third party has agreed to abide by the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield described below or can otherwise assure adequate protection of your information. We may seek to assure adequate protection, for example, by executing written agreements with third parties requiring such parties to provide at least the same level of privacy protection as is required by the Privacy Shield. These third-party service providers are authorized to use your information only as necessary to provide these services to us.
If, however, we are going to use users' personal information in a manner different from that stated at the time of collection, we will notify users via email or by posting a notice on our website for 30 days prior to the change becoming effective.
We post client testimonials on our website which may contain personal information such as the client's name. We do obtain the client's written consent prior to posting the testimonial to post their name along with their testimonial. If you wish to update or delete your testimonial, you can contact us at email@example.com.
Links to Other Sites
This website contains links to other sites that are not owned or controlled by Insala. Please be aware that we, Insala, are not responsible for the privacy practices of such other sites.
Social Media Widgets
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Compliance.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Compliance.
In compliance with the Privacy Shield Principles, Insala Limited commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Insala Limited) at: firstname.lastname@example.org
Insala Limited has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/ for more information or to file a complaint. The services of JAMS are provided at no cost to you. You may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Insala Limited commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
© Insala Copyright 2019.
Updated Policy: July 15, 2019.