Privacy Policies - RW3 LLC

Privacy Policies – RW3 LLC

RW3 LLC believes in protecting your privacy. When we collect personal information from you on our website, we follow the privacy principles the EU-US and Swiss-US PRIVACY SHIELD Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union and Switzerland, respectively.   These are our promises to you:

Affirmation Statement. RW3 LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. RW3 LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. RW3 LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

1. We collect your personal information on the registration page that consists of your name and email address, we will only use this information to provide a more customized and personalized experience on the site, to uniquely identify your account, provide basic aggregate site usage reporting (total number of registrants, monthly users and visits) to your employer, and to send you additional content that pertains to your course of study on the CultureWizard site. Where relevant, we may also use your name and email address when providing a list of site registrants to your employer.
2. The only personal information that you are required to enter on the site is your email address and your name, unless your company requires you to fill out other information (Such as Region, Department, etc.) indicated on the registration page. Several of the learning tools on the site include assessments that will provide personalized feedback based on the answers you provide. These specific responses will not be viewed or used by anyone except you, however, it is possible to share feedback charts and reports provided by some tools on the site by participating in a training program or a collaborative tool. You will be informed of your choice to share this information by agreeing to accept an invite to share your information or when asked to share it by a facilitator of a training program. Your company may have also provided functionality on the site that allows for interaction with other site users. In these cases, participation is at your discretion and should follow any guidelines for online interaction that your company may enforce.
3. We’ll collect only as much personal information as we need for specific, identified purposes, and we won’t use it for other purposes without obtaining your consent.
4. We’ll keep your personal information only as long as we need it for the purposes for which we collected it, or as permitted by law.
5. We take appropriate steps to make sure the personal information in our records is accurate.
6. We acknowledge the individual’s right to access their personal information. We provide ways for you to access your personal information, as required by law, so you can review and correct inaccuracies. You can change your information at any time by going to the My Account page.  You are also able to retake any of the assessments on the site to alter your feedback results.
7. We’ll take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
8. Except as described in this policy, we won’t share your personal information with third parties without your consent.
9. International Transfer. If we transfer your personal information to another country, we’ll take appropriate measures to protect your privacy and the personal information we transfer.
10. We’ll regularly review how we’re meeting these privacy promises, and we’ll provide an independent way to resolve complaints about our privacy practices.
11. RW3 may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

 

 PRIVACY SHIELD FRAMEWORKS

Although not used for data transfers as of July 16th 2020, RW3 LLC still complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. RW3 LLC certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Our accountability for personal data that we receive in the United States under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage. 

In compliance with the EU-US and Swiss-US Privacy Shield Principles, RW3 LLC commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact RW3 LLC at: 

Joshua Sturtevant

381 Park Avenue South, Suite 1011, New York NY 10016

privacy@rw-3.com

+1.646.681.2389                  

     

RW3 LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you. 

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at  https://www.privacyshield.gov/article?id=ANNEX-I-introduction    

RW3 LLC has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

 

RW3 LLC is subject to the investigatory and enforcement authority of the United States RW3 LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  RW3 LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  RW3 LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

 

 

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, RW3 LLC commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF should first contact RW3 LLC at:

 

Joshua Sturtevant

Joshua.Sturtevant@rw-3.com

  

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, RW3 LLC commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

 

 

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, RW3 LLC commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to [INSERT name of alternative dispute resolution provider], an alternative dispute resolution provider based in [INSERT the United States, the European Union, the United Kingdom, and/or Switzerland (as applicable)].  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers for more information or to file a complaint.  The services of BBB are provided at no cost to you.

 

 

 

Federal Trade Commission (FTC).

 

 

 

 

SHARING OF PERSONAL INFORMATION:

We will share your personal information with third parties only in the ways that are described in this privacy statement.

Service Providers

We may provide your personal information to companies that provide services to help us with our business activities such as processing your payments. These companies are authorized to use your personal information only as necessary to provide these services to us.

Legal

We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If RW3 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 website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We will only disclose your personal information to any other third party with your prior consent.

OPT-OUT PREFERENCES:

If you no longer want to receive content-related emails from us, you may opt out of receiving such emails by clicking the “unsubscribe” link at the bottom of any content email that you receive from us.

 If you are having difficulty unsubscribing from our content emails using the above methods, please contact us directly at the email privacy@RW-3.com.

EXERCISING YOUR RIGHTS:

You may submit a request for access (i.e. request information on personal data collected, used, disclosed or processed by RW3), as well as a request for integration, rectification, or erasure, or object to our processing of your personal data. Upon request, RW3) will provide you with information about whether we hold any of your personal information. Furthermore, you may also be able to exercise the following rights to restrict processing, data portability, and lodge a complaint with a data protection authority.

If you prefer that the processing of your personal data is carried out solely by means of traditional contact methods, you may object to the processing of your personal data by means of automated contact methods.

In order to exercise your rights above and/or submit inquiries or complaints with regard to our processing of your personal data, you may send a request to RW3 by writing to this email address privacy@RW-3.com. We will respond to your request within thirty (30) days.

SECURITY

The security of your personal information is important to us.

We follow generally accepted security standards and we have adopted commercially reasonable security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access. We may use third-party products and services to secure or store your information. For more information on where we store and how we secure your information, please see our compliance and security page.

By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. Depending on where you live, you may have a legal right to receive written notice of a data privacy or security breach. If you have any reason to believe that your interactions with the Services are no longer secure, please notify us immediately at privacy@rw-3.com.

If you have any questions about the security of your personal information, you can contact us at privacy@RW-3.com

 

HOW LONG WE KEEP INFORMATION:

How long we keep the information we collect about you depends on the type of information, as described in further detail below.  After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. 

Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services.  We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you. 

Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. 

Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your RW3account.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

 

DISCLOSURES SPECIFIC TO THE RW3 PLATFORM/SERVICE:

The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged RW3. RW3 collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. RW3 will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

TRACKING TECHNOLOGIES

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We also use cookies to enable your session on our platform and facilitate required functionality. In addition, we use cookies for tracking session information which we use for aggregate reporting to help us improve our product and report on overall site usage statistics.

We do not link this automatically collected data to other information we collect about you.

 

LINKS TO OTHER SITES

In several of our learning resources, we may occasionally include links to third-party websites. No data is transferred when you connect to these external sites, and they are provided solely to enhance your learning experience, should you desire to explore additional information not provided by our site. Please pay attention when you connect to these websites and read their terms and conditions of use and privacy policies carefully. We do not control or monitor such websites or their web content. This Privacy Statement does not apply to any third-party websites and we will are not responsible for the content, privacy policies, or processing of your Personal data while you are visiting any third-party websites.

 

CHANGES TO THIS PRIVACY POLICY:

We reserve the right to amend all or part of our Privacy Statements from time to time. The version published on the Sites is the version currently in force. Changes to our Privacy Statements are communicated by placing a notice on the Sites stating “Revised Privacy Statement(s).” Changes to our Privacy Statements will be effective immediately once published on the Sites unless otherwise noted. Your use of the Sites following any amendments indicates your consent to the practices described in the revised Privacy Statements. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We invite you to periodically review our Privacy Statements to be informed of any relevant changes, especially before providing any data to us