Last Update: June 2019
The Short Version
At ATS eLearning we care about your privacy. We do not sell or rent your personal information to third parties for their direct marketing purposes without your explicit consent. We do not disclose it to others except as disclosed in this Policy or required to provide you with the services of the Site and mobile applications, meaning – to allow you to buy, sell, share the information you want to share on the Site; to contribute on the forum; pay for products; post reviews and so on; or where we have a legal obligation to do so.
We collect information that you provide us or voluntarily share with other users, and also some general technical information that is automatically gathered by our systems, such as IP address, browser information, and cookies to enable you to have a better user experience and a more personalized browsing experience.
We will not share information that you provide us in the process of the registration – including your contact information, except as described in this Policy.
Information that you choose to publish on the Site (photos, videos, text, music, reviews, deliveries) – is no longer private, just like any information you publish online.
Technical information that is gathered by our systems, or third-party systems, automatically may be used for Site operation, optimization, analytics, content promotion and enhancement of user experience. We may use your information to contact you – to provide notices related to your activities or offer you promotions and general updates, but we will not let any other person, including sellers and buyers, contact you, other than through your user profile on the Site.
You can exercise your rights over your personal information, by opening a support ticket. If you do not have an active ATS eLearning account, please contact us at firstname.lastname@example.org. More details about the rights applicable to you are in the long version of the Policy.
The above are just the highlights. We encourage you to read more about the information we collect, how we use it, understand the meaning of cookie and more in the long version of our Policy below.
The Longer Version
ATS eLearning (including IA-Advanced Telecom Solutions, LLC) respects your privacy and is committed to protecting the personal information of its users – buyers, sellers, and visitors browsing the Site (“Users”). We believe that you have a right to know our practices regarding the information we may collect when you visit and/or use the Site. This Policy explains our privacy practices for the Site and services provided by ATS eLearning. By accessing and/or using the Site and its related sites, applications, services, goods and/or registering for an ATS eLearning account, you agree to the terms and conditions of this Policy, including to our collection, use, disclosure, processing and retention of your personal information. You can also learn how to limit the sharing of information in this Policy.
Information We Collect
When you register to the Site, we ask you to provide certain personal information, including a valid email address and location log in details and username. We may collect additional information you provide us, such as physical address, telephone number or other contact details, financial information (such as payment method and credit card number), and additional authentication information, to provide you with the services you need (such as payment or withdrawal of funds, sending physical goods), or to ensure the marketplace integrity (for example, prevention of fraud).
In addition, we collect information while you access, browse, view or otherwise use the Site. In other words, when you access the Site we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage, including geolocation information, IP address, device and connection information, browser information and web-log information, and all communications recorded by Users through the Site. We use that information to enhance the user experience, personalize your browsing experience as well as monitor the Site for preventing fraud and inappropriate content or behavior. We may also collect supplemental information obtained from third parties such as demographic and navigation data.
How do we collect Information?
How do we use the Information collected?
Where relevant under applicable laws, all processing of your personal information will be justified by a “condition” for processing. In most cases, processing will be justified on the basis that:
you have provided your consent for us to use your personal information for a specific purpose;
our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased);
the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or
the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you or to customize your browsing experience), subject to your interests and fundamental rights and provided it is always conducted in a way that is proportionate.
We will use your personal information for the following purposes:
to provide you with quality service and security. For example, we may use the information collected from you to verify your identity. We may also use this information to establish and set up your account, verify or re-issue a password, log your activity and contact you from time to time.
The information helps us improve our services to you and customize your browsing experience. In addition, this information helps us track any fraudulent activities and other inappropriate activities and monitor content integrity; or
to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law. Should you ever deactivate your account with us, we will keep your information for a limited period in order to meet the above purposes.
we will ask for your consent before using the information for a purpose other than those set out in this Policy.
We may use your personal information to send you direct marketing communications about our products, services or promotions from ATS eLearning that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements.
In most cases, our processing of your personal information for marketing purposes is based on our legitimate interest, although some cases (such as where required by law) may be based on your consent. You have a right to prevent direct marketing of any form at any time – this can be exercised by following the opt-out link attached to each communication or by sending an email to: email@example.com.
We take steps to limit direct marketing to a reasonable and proportionate level and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
How long do we keep your information?
We apply a general rule of keeping personal information only for as long as is required to fulfill the purpose for which it was collected. However, in some circumstances, we may retain your personal information for longer periods of time. We may retain your information for the following purposes:
if it is necessary and relevant for our operations, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and
we may retain personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and take other actions as permitted by law.
Minors Under the Age of 13
Our Site is not intended for minors under 13 years of age. No one under age 13 should provide any personal information to or on the Site. We do not knowingly collect personal information from minors under 13. Parents and guardians should always supervise their children’s activities. If we learn we have collected or received personal information from a minor under 13, we will delete that personal information. If you believe we might have any information from or about a minor under 13, please contact us at firstname.lastname@example.org.
Sharing Personal Information with Third Parties
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.
We may combine your personal information with information we collect automatically or obtain from other companies and use it to improve and personalize our services, content, and advertising. If you do not wish to receive marketing communications from us, you can opt-out through the link attached to each communication or by sending an email to email@example.com.
We may provide your personal details to third parties, only in order to operate the Site, provide our services to you, fulfill obligations imposed on us by applicable laws and regulations, and prevent fraud and illegal activities, as detailed below:
to service providers for the purpose of opening and operating your account as well as providing ancillary services (example – payment vendors, CRM systems, forum hosting, community management services, mailing systems or technical consultants). Our contracts with these service providers do not permit use of your information for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions;
to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of ATS eLearning, our customers, or the public;
to secure the site and protect it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and
Where We Store Your Personal Information
Some of the personal information you provide to us may be stored or processed on our behalf by third party suppliers and data processors and maybe in other jurisdictions whose laws may differ from the jurisdiction in which you live. Whether to third parties or internally, any transfers of personal information from the European Economic Area (“EEA”) to countries not deemed to provide an adequate level of data protection are governed by European Union (EU) standard contractual clauses, or in the case of the United States, the EU – US Privacy Shield, and/or equivalent data transfer regulations to protect the security and confidentiality of personal information. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
We take great care in maintaining the security of the Site and your information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. Among other things, we contractually ensure that any third party processing your personal information has in place the technology and procedures for keeping your information confidential and with the highest integrity of your data in a secure way. However, the transmission of data via the internet is not completely secure, and although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
Users who have registered to the Site agree to keep their password in strict confidence and not disclose such password to any third party. Further information about our data security practices can be provided on request.
Rights of Users Under EU Regulation
Under applicable EU regulation, as of May 25, 2018, you may have some or all the following rights in respect of your personal information:
·to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;
to rectify inaccurate personal information;
to erase your personal information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim;
to challenge processing which we have justified based on our legitimate interest;
to object to decisions which are based solely on automated processing or profiling;
to obtain a portable copy of your personal information, or to have a copy transferred to a third-party controller; or
to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.
In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.
We may ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. We reserve the right to charge a fee where permitted by law. We may also decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain personal information for a limited period for record-keeping, accounting and fraud prevention purposes.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits California residents that are users of our Site to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
Updating Your Information
We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. If you believe your information is in any way incorrect or inaccurate, please let us know immediately. We will make sure we investigate the matter and correct any inaccuracies as quickly as possible where necessary or give you ways to update it quickly or to delete it – unless we must keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request. If for any reason you have a problem with deleting your personal information, please contact ATS eLearning email@example.com and we will make reasonable efforts to delete any such information pursuant to any applicable privacy laws.
You can review and change your personal information by logging into the Site and visiting your account profile page.
If you delete your User Generated Content (“UGC”), as defined in the ATS eLearning Terms of Service, from the Site, copies of your UGC may remain viewable in cached and archived pages or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including UGC, is governed by our Terms of Service.
We reserve the right to change this Policy at any time, so please re-visit this page frequently.
Changes to this Policy are effective as of the stated “Last Update” and your continued use of the Site on or after the Last Update date will constitute acceptance of, and agreement to be bound by, those changes.
To exercise any of your rights in connection with your personal information, we kindly ask that you open a support ticket at firstname.lastname@example.org. Please include all the relevant details, so your ticket can be handled correctly. We will process any requests in line with any local laws and our policies and procedures. If you do not have an active ATS eLearning account, please contact us at email@example.com.
If you have any questions (or comments) concerning this Policy, please email us at firstname.lastname@example.org, and we will make an effort to reply within a reasonable timeframe.