Privacy Policy Statement

30-11-2018

1) Introduction

This Privacy Policy Statement provides users of our digital learning product (Bolster Safety) and our company website (www.bolstersafety.com) information on how Bolster Workforce B.V. processes personal data.

Bolster Workforce B.V. value the privacy of our end users, and want to provide clear information about our use and protection of personal data.

Processing personal data in our digital learning product makes it possible to offer training courses to employees and enables employees to follow their own customized curriculum and learning paths. Employers are able to track the employee’s learning activities, monitor progress and, as a result, offer training that meet the needs of the individual employee.

Processing personal data in our corporate website makes it possible to provide customers and prospects with information about our products and services.

Bolster Workforce B.V. is committed to protecting the privacy of our customers and users of our products and services according to the AVG (GDPR) and other applicable laws.

This privacy policy statement covers

  1. Our digital learning product Bolster Safety that is provided by employers to their employees
  2. The company website bolstersafety.com

This privacy policy statement may be extended or amended in the future. All changes will be published on our website (www.bolstersafety.com).

 

2) Bolster Safety

 

2a) Who is the data controller responsible for data processing

Employers are the data controller and responsible for the processing of personal data of employees in Bolster Safety. Whenever Bolster Workforce B.V. processes personal data of employees who use our products, such data is processed on behalf of employers for training purposes, to guarantee the proper functioning of the digital learning tool, and for the development of training courses.

 

2b) What kind of data are processed and for what purposes

Bolster Workforce B.V. process personal data only for predefined purposes, mainly data that is necessary for enabling the usage of our e-learning product, and for product development purposes. The data types processed are the following:

User data

The data provided by users themselves or by the employer on behalf of the user e.g. name, age, department. The service require the creation of a user account (user name and password) to allow the users to log into Bolster Safety. We also process data that users provide during a training, e.g. progress, answers and results.

The data is used for the following purposes:

  • to identify and authenticate the user of the products and to determine the associated user rights;
  • to enable login via single sign-on process to Bolster Safety;
  • to deliver the training content and store the responses to exercises;
  • for personalized access to the services offered;
  • for providing support to the users of the e-learning platforms

 Data collected buy of the use of our digital learning product

We collect data on how users of our digital learning product are using the products, including data such as test results, authentication details, web logs, and information on how content is accessed or used.

This enables a manager to see which learning activities each of his/her employees executed with our product, and what the outcomes were of the learning activities. Bolster Workforce B.V. can provide this information to the manager through reports and dashboards.

We may use cookies and other similar online technologies, such as the browser's local data storage, to collect data from a user's terminal. Cookies are small text files that the browser saves in the user's device. Cookies often contain an anonymous individual identifier, which we can use to measure how many different browsers are visiting our websites, and how our online services are being used.

The collected data is used for the following purposes:

  • to provide feedback and reports on the training results of employees to the employee and employer;
  • to enable adaptive learning materials and personalized learning paths;
  • to analyze data on the use of digital learning products by employees and produce reports on the aggregate level to improve the quality of training;
  • for product security and fraud prevention services;
  • to improve training material and digital learning solutions.

 

2c) Does Bolster Workforce B.V. use data from the Bolster Safety product for marketing purposes?

Bolster Workforce B.V. does not use the data of employees who use our digital learning product for marketing or advertising purposes.

 

3) Company website

Bolster Workforce B.V. process personal data on our company website only for predefined purposes, mainly data that is necessary for providing customers and prospects with information about our products and services and to optimize the user experience of our website.

 We may use cookies and other similar online technologies, such as the browser's local data storage, to collect data from a user's terminal. Cookies are small text files that the browser saves in the user's device. Cookies often contain an anonymous individual identifier, which we can use to measure how many different browsers are visiting our websites, and how our online services are being used.

For customers and prospects who have given their consent for electronic direct marketing, we may send information such as information on our products, invitations to events, market research surveys, or newsletters.

 

 4) The legal bases for data use

  • When processing data for delivering and personalizing our products, our legal basis for processing the data is a contract.The data processed under contract is necessary for delivering the product or service and for serving the customer. It typically includes the customer’s contact details and the information necessary for using the functionalities of the service that the customer fills in or that are collected about the use of the service in order to enable the features. This data is described in more detail in the terms of the service.
  • When processing data for analytics that aim at improving and developing our products and services, our legal basis for processing the data is our legitimate interest as a company to improve our business.
  • When processing data for statistical reporting for business decision making and sales, our legal basis for processing the data is our legitimate interestas a company to improve our business.
  • When processing data for marketing, sales and customer service purposes, our legal basis for processing is our legitimate interest as a company to contact our customers and maintain customer relationship. In case of prospects our legal basis is consent.
  • When processing data for fraud prevention and information security purposes, our legal basis for processing is our legitimate interest as a company to prevent and defend against illegal activities against us or our customers.
  • When processing data for accountancy and taxation purposes, our legal basis for processing is our legal obligation as a data controller to keep records in accordance with the AVG/GDPR.

 

5) Who can handle my personal data?

Bolster Workforce B.V. may transfer personal data within Sanoma Group when it is necessary for administrative reasons for the purposes communicated in this Privacy Policy Statement.

Bolster Workforce B.V. may designate third-party processors to process the data on behalf of the Bolster Workforce B.V. Our typical processors include (cloud) hosting providers and IT service providers who help us with the technical maintenance of services, customer service, marketing activities or product development. In that case, we will ensure that the processor processes the data only for the mentioned purposes and that they provide adequate technical and organizational security safeguards to protect data. Bolster Workforce B.V. and the processor will enter into a written data processing agreement to ensure an adequate level of protection. Third party suppliers processing data on our behalf must handle personal data in compliance with this Privacy Policy Statement.

The Employer may ask us to disclose information, e.g. learning scores, to a third party administration system provider or other party that the employer has entered into agreement with for processing the data of employees. We may also disclose data to the employer, in connection with their obligations as the provider of training (for example, reports about the use of the service)

We typically store our data in the EU or the EEA. If any data is transferred outside the EU or EEA, we will ensure that the country to which the data is transferred is approved as having a sufficient level of privacy protection by the European Commission, and when necessary, we will use the standard contractual model clauses approved by the European Commission.

 

6) How does the company protect personal data?

The Company takes appropriate technical and organizational measures to protect personal data against unauthorized access, transfer, deletion or other processing that may compromise information security. Such methods include the use of firewalls, encryption technologies and safe server rooms, proper access control systems, the controlled provision of user rights and supervision of their use, providing instructions for data processors, and the thorough selection of competent subcontractors who comply with industry standards for information security management. Personal data is not kept for any longer than is necessary for the realization of the purposes for which they were collected or subsequently processed.

 

7) How long do we retain the data?

Data is retained according to the following principles:

  • Profiles in digital learning products: 2 years after ending of a contract in order to be able to reinstall user profiles in case of a contract renewal.
  • Customer/prospect contact details, invoice details for tax & accounting: retained according to law 6/7 years
  • Data in customer registers: retained for 2 years after the expiry of the subscription in order to allow customer relation management and marketing activities
  • Behavioral data from online stores / website without login (cookies, identifiers, events): 2 years
  • Analytics data (anonymized): 8-10 years

 

8) How can a user exercise his rights regarding personal data?

Users of Bolster Safety can exercise their rights regarding personal data by contacting their employer.  On request of the employer we will provide insight in, change, delete and/or transfer personal data of their employees.

Customers and prospects can withdraw their consent for the processing of personal data by using the link in the marketing messages, or by contacting Bolster Workforce B.V directly.

 

9) How do I contact Bolster Safety

By mail:
Parallelweg 1
3112 NA Schiedam
The Netherlands

By e-mail:
info@bolstersafety.com

By phone:
+31 85 902 12 01

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